PTAB

IPR2025-01122

Evenflo Co Inc v. Baby Jogger LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Configurable Children's Stroller
  • Brief Description: The ’682 patent describes a stroller that can be converted from a single-seat to a double-seat configuration. The system uses seat attachment housings coupled to the stroller frame and corresponding seat attachment adapters to mount seats at different vertical positions, allowing for an inline descending arrangement.

3. Grounds for Unpatentability

Ground 1: Claims 1-16 are obvious over Rolicki

  • Prior Art Relied Upon: Rolicki (Patent 8,882,134).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that this ground applies if the ’682 patent is not entitled to a priority date before March 2016. Rolicki was argued to disclose a stroller with all elements of claim 1. Specifically, Rolicki taught upper and lower frame supports, "seat mounts" (claimed "adapters") for removably coupling upper and lower seats, and "housings" at the front end of the stroller for coupling the lower seat mounts. Petitioner asserted that Rolicki's figures clearly show the upper seat mounted higher and rearward of the lower seat, resulting in the claimed "inline descending configuration."
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, the argument focused on how a person of ordinary skill in the art (POSITA) would have understood Rolicki's disclosed components and configurations to meet the claimed limitations based on conventional stroller design principles.
    • Expectation of Success (for §103 grounds): A POSITA would have expected success in implementing Rolicki’s stroller design as it disclosed a complete and functional system.

Ground 2: Claims 1-9 and 13-16 are obvious over Liao

  • Prior Art Relied Upon: Liao (U.S. Design Patent No. D593,459 S).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Liao's detailed design patent drawings disclosed all features of the challenged claims. Liao illustrated a stroller frame with distinct handle and front-end portions, upper connection points for a first seat, and lower "seat attachment housings" for coupling a removable second-seat subassembly. The drawings showed the upper seat positioned closer to the handle and the lower housings positioned below the first seat and closer to the front, creating an inline descending arrangement. Petitioner noted that an Examiner in a related application rejected similar claims as anticipated by Liao alone, confirming its detailed disclosure.
    • Motivation to Combine (for §103 grounds): This ground was based on a single reference, arguing that Liao's design inherently contained all the claimed elements.
    • Expectation of Success (for §103 grounds): A POSITA would have understood from Liao's detailed engineering drawings how to construct the depicted convertible stroller.

Ground 3: Claims 1-16 are obvious over Offord ’341 in view of Offord ’797

  • Prior Art Relied Upon: Offord ’341 (Patent 8,672,341) and Offord ’797 (WO 2008/040797).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Offord ’341 taught a convertible stroller with "interface portion components" that form a sub-frame for mounting two seats in an "echelon formation." To teach the claimed inline descending configuration, Petitioner pointed to Offord ’797, which Offord ’341 expressly referenced as disclosing a "similar sub-frame arrangement." Offord ’797 explicitly taught that its sub-frame could be rotated 180 degrees to reverse the vertical positioning of the seats, achieving either a front-low/rear-high or front-high/rear-low configuration.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references because Offord ’341 directly cited Offord ’797. This express reference would have motivated a POSITA to apply the seat-reversing technique taught in Offord ’797 to the similar sub-frame components of Offord ’341 to achieve different, desirable seating arrangements.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because the modification involved applying a known technique (reversing a sub-frame) to a similar, explicitly cross-referenced device to achieve a predictable result (a different seat orientation).
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 10-12 based on Liao in view of Cheng (Application # 2006/0071451). This ground argued for substituting Liao's central coupling with Cheng's known folding mechanism to add frame collapsibility, a predictable improvement.

4. Key Claim Construction Positions

  • "Handle Portion" (claim 1): Petitioner argued that, based on amendments made during the prosecution of a related patent, this term should be construed as the "portion of frame coupled to the left and right upper tube support frame." This construction is critical to Petitioner's priority date argument, as it contends that the pre-2016 disclosures describe a different handle portion structure that is not coupled to "upper tube support frames," which were allegedly new matter added in 2016.

5. Key Technical Contentions (Beyond Claim Construction)

  • Loss of Priority Date: Petitioner’s central contention, underpinning Ground 1, was that the ’682 patent was not entitled to its claimed priority date earlier than March 21, 2016. The argument was based on the introduction of new matter and a new inventive entity (Lee, Roe, and Simpson) in a 2016 provisional application. Petitioner asserted that key claim limitations, including the "seat attachment housings," "seat attachment adapters," and the specific "handle portion" structure, lacked written description support in the original 2008 provisional filed by the sole inventor Zehfuss. Therefore, intervening prior art like Rolicki should apply.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-16 of the ’682 patent as unpatentable.