PTAB

IPR2025-01120

Baby Generation Inc v. Baby Jogger LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Stroller System with Parallel Frame Portions
  • Brief Description: The ’729 patent discloses a stroller system capable of supporting one or two seats in an inline configuration. The claimed invention features a frame where the handle portion and front wheel support portion are parallel in the unfolded configuration, and a front seat attachment that can be releasably connected to support a front stroller seat.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dotsey, Zehfuss, and Britton - Claims 1-17 and 19-22

  • Prior Art Relied Upon: Dotsey (Application # 2009/0127810), Zehfuss (Application # 2010/0140902), and Britton (Patent 6,767,028).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dotsey disclosed a base stroller with all major frame components, including a front wheel support portion and handle portion that are "substantially parallel." Zehfuss, which Petitioner contended is prior art because the ’729 patent is not entitled to its priority date for the "parallel" limitation, taught a convertible stroller with a front seat attachment for a second seat that is reversible and positioned substantially over the front wheels for stability. Britton disclosed an adjustable stroller handle that can be pivoted to different angles for caregiver comfort.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Dotsey and Zehfuss to satisfy the known market demand for a convertible single-to-double stroller, using Zehfuss's front seat attachment on Dotsey’s frame. A POSITA would further modify Dotsey’s handle portion, as taught by Britton, to make it strictly "parallel" to the front wheel support. This modification was presented as a simple design choice to adjust handle height for better ergonomics, which is a predictable and desirable outcome.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success, as the combination involved integrating known stroller components (Dotsey's frame, Zehfuss's second seat concept, Britton's adjustability) to achieve their predictable functions.

Ground 2: Obviousness over Van Dijk and Schaaf - Claims 1-17 and 19-22

  • Prior Art Relied Upon: Van Dijk (Application # 2007/0194545) and Schaaf (Patent 6,209,892).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Van Dijk disclosed a stroller with versatile seat mounting mechanisms ("adapters" and "connecting pieces") allowing seats to be attached in forward- or rear-facing configurations. However, Van Dijk did not explicitly show a two-seat inline configuration. Schaaf taught a collapsible, two-seat inline stroller with a frame structure that includes parallel support members, providing a stable platform for two children.
    • Motivation to Combine: A POSITA would be motivated to modify Van Dijk’s stroller to support two children, a known need in the market. To do this, a POSITA would look to known two-seat designs like Schaaf and incorporate its stable inline seating arrangement and parallel frame structure into Van Dijk. This combination would leverage Van Dijk's versatile seat mounts within Schaaf's proven two-seat frame layout.
    • Expectation of Success: Success would be expected because the modification was a straightforward substitution of one known frame arrangement (single-seat) for another known arrangement (two-seat inline from Schaaf) to achieve the predictable result of a multi-child stroller.

Ground 3: Obviousness over Liao and Schaaf - Claims 1-17 and 19-22

  • Prior Art Relied Upon: Liao (Patent D593,459) and Schaaf (Patent 6,209,892).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Liao disclosed a two-seat inline stroller, but its front seat required a cumbersome, cantilevered attachment that included its own extra wheel and wheel support frame for stability. Schaaf disclosed a more elegant and stable two-seat inline design where the front seat is supported close to the main front wheels, eliminating the need for an extra wheel assembly.
    • Motivation to Combine: A POSITA would recognize the design of Liao as undesirable due to the added cost, complexity, and weight of the front seat’s extra wheel assembly. A POSITA would combine Liao with Schaaf’s teachings to improve the design by removing Liao’s separate wheel assembly and instead supporting the front seat closer to the main frame in an inline descending configuration, as taught by Schaaf. This modification would produce a more stable, lighter, and less expensive stroller.
    • Expectation of Success: A POSITA would expect success because the combination involved simplifying a known design (Liao) by applying principles from another known, more efficient design (Schaaf), a routine step in product design and improvement.

4. Key Technical Contentions (Beyond Claim Construction)

  • Loss of Priority Date: A central contention of the petition, primarily for Ground 1, was that the ’729 patent was not entitled to the benefit of its claimed priority applications. Petitioner argued that none of the priority documents provided written description support for the limitation that the "front wheel support portion and the handle portion are parallel." The figures in the priority applications allegedly depicted these components as being in-line (collinear), which is antithetical to being parallel. Therefore, Petitioner contended the effective filing date for the challenged claims was the filing date of the application that issued as the ’729 patent, which made the Zehfuss reference (published in 2010) available as prior art under 35 U.S.C. §102(a)(1).

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-17 and 19-22 of Patent 11,878,729 as unpatentable.