PTAB

IPR2025-01178

Starbucks Corp v. Pi Design AG

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Plunger-Filter Beverage-Making Machine with a Closable Pouring Opening
  • Brief Description: The ’486 patent discloses a French Press-style beverage maker that incorporates a lid with a pouring opening and a finger-actuated, pivoting lever designed to seal that opening to prevent heat loss and spillage.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 14-17 and 19-21 by US349

  • Prior Art Relied Upon: US349 (Application # 2009/0057349).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that US349, which discloses a carafe with a lever-actuated closure mechanism, teaches every limitation of independent claim 14. Specifically, US349 was alleged to show a cylindrical vessel, a lid with a top wall, a spout, a pouring opening, and an elongated lever that pivots on a horizontal axis to close the opening. Petitioner further asserted that US349 discloses the dependent claim limitations, including a spring-loaded lever (claims 15-17), a closure body made of a softer material (claim 19), a circumferential skirt on the lid (claim 20), and an upwardly protruding retaining web around the pouring opening (claim 21).

Ground 2: Obviousness of Claims 1-9 and 14-21 over US349 in view of Brady

  • Prior Art Relied Upon: US349 (Application # 2009/0057349) and Brady (Application # 2003/0185949).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that while US349 teaches the claimed lever-closure lid, it lacks the standard French Press components recited in claims 1 and 5, namely the "Piston Assembly" (filter piston, piston rod, and grip). Brady, which discloses a conventional French Press, was asserted to supply these missing elements. The combination of US349's lid mechanism with Brady's French Press body and piston assembly allegedly renders the claims obvious.
    • Motivation to Combine: A POSITA would combine Brady’s well-known Piston Assembly with the carafe and closable lid of US349 to create an improved, integrated French Press. The motivation would be to gain the benefit of US349's one-handed, spill-resistant pouring mechanism in a traditional brewing device, a simple substitution of one known lid type for another to improve functionality.
    • Expectation of Success: Petitioner contended that incorporating a standard piston assembly into a beverage container and modifying a lid to accommodate the piston rod would be a routine task for a POSITA with a high expectation of success.

Ground 3: Obviousness of Claims 1-9 and 14-22 over US349 in view of Brady and Geroult

  • Prior Art Relied Upon: US349 (Application # 2009/0057349), Brady (Application # 2003/0185949), and Geroult (Application # 2007/0295760).
  • Core Argument for this Ground:
    • Prior Art Mapping: Geroult was introduced as teaching an alternative lever and lid design that could be incorporated into the US349/Brady combination. Specifically, Geroult was argued to disclose a two-part lid (claim 22) and a lever assembly with a pre-existing central aperture. This aperture could accommodate the central piston rod from Brady without the need for modification that the solid lever of US349 would require.
    • Motivation to Combine: A POSITA would be motivated to incorporate Geroult's two-part lid to protect the lever mechanism from damage and environmental debris. Further, Geroult’s lever design with a central opening would be an attractive and obvious alternative for a POSITA seeking to combine a closable lever with a centrally-located piston rod, as it provides an express design solution for the integration.
    • Expectation of Success: Substituting known lid and lever components to combine their respective known benefits was presented as a predictable design choice with a clear expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Porter (a French Press travel mug), US623 (a heat-retaining coffee pot), Wickman (a pouring dispenser), and others to teach further features such as guide sleeves and latched components.

4. Key Claim Construction Positions

  • "Elongated Lever": Petitioner argued this term should be construed as "a unitary bar," not a multi-component assembly. This position was based on a theory of prosecution history disclaimer, where the Patent Owner allegedly distinguished the invention from the prior art Lin reference by characterizing Lin's structure as a multi-part "lever assembly" and not the claimed "elongated lever."
  • "Closure Body": Petitioner proposed construing this term as "the area of the elongated lever that contacts and releasably seals the pouring opening." This argument was also based on statements made during prosecution to distinguish prior art, asserting that the closure body was an integral part of the lever itself.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. The petition asserted that it presents prior art references (including US349, Geroult, and Porter), prior art combinations, and invalidity arguments that are substantially different from those considered by the Examiner during the original prosecution of the ’486 patent.

6. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-22 of Patent 8,695,486 as unpatentable.