MWE Investments, LLC v. Champion Power Equipment, Inc.

1. Case Identification

• Case #: IPR2025-01185
• Patent #: 10,221,780
• Filed: July 22, 2025
• Petitioner(s): MWE Investments, LLC; Harbor Freight Tools USA, Inc.; Generac Power Systems, Inc.
• Patent Owner(s): Champion Power Equipment, Inc.
• Challenged Claims: 1-15

2. Patent Overview

• Title: Dual Fuel Lockout Switch for Generator Engine
• Brief Description: The ’780 patent discloses a mechanical fuel lockout switch for a dual-fuel (e.g., gasoline and LPG) generator engine. The switch is designed to prevent the simultaneous delivery of both fuel sources by physically blocking access to the inlet of the unused fuel line.

3. Grounds for Unpatentability

Ground 1: Obviousness over DuroMax and Elsdon - Claims 1-4, 6, 7, and 15 are obvious over DuroMax in view of Elsdon.

• Prior Art Relied Upon: DuroMax (DuroMax XP4400EH Operator’s Manual) and Elsdon (Patent 5,718,265).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that DuroMax, a publicly available manual for a dual-fuel generator, discloses all elements of the independent claims except for the "fuel lockout apparatus." DuroMax explicitly warns users not to run on gasoline and LPG simultaneously, identifying a known problem. Elsdon discloses a fuel conduit coupler with a rotating, hinged cap designed to physically block access to the coupler interface to prevent connection of a fuel hose. The combination of DuroMax's generator and fuel valve with Elsdon's physical blocking cap allegedly teaches the claimed invention.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Elsdon’s physical blocking cap with DuroMax’s fuel selection valve to solve the known safety and operational problem of simultaneous fuel delivery identified in the DuroMax manual. Linking the simple rotating cap of Elsdon to the rotating fuel valve handle of DuroMax is a predictable design choice to create an integrated safety mechanism.
  • Expectation of Success: A POSA would have a high expectation of success because Elsdon’s cap is a simple mechanical component described as suitable for retrofitting onto existing equipment. The mechanical challenge of linking the rotation of the DuroMax valve handle to the rotation of the Elsdon cap is straightforward.

Ground 2: Anticipation and Obviousness over Hallberg - Claims 1, 6, and 7 are anticipated by Hallberg; Claims 2 and 15 are obvious over Hallberg.

• Prior Art Relied Upon: Hallberg (Patent 4,492,207).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Hallberg anticipates claims 1, 6, and 7 by disclosing a complete dual-fuel system for an internal combustion engine that uses a single fluid dual valve control to select between gasoline and propane. When one fuel is selected, the system mechanically prevents the flow of the other fuel. Hallberg’s fluid dual valve control and associated structure were mapped to the ’780 patent’s "mechanical fuel valve" and "fuel lockout apparatus." The system inherently operates to ensure fuel from both sources is not delivered simultaneously.
  • Motivation to Combine (for obviousness): For dependent claims 2 and 15, Petitioner argued it would have been obvious to modify Hallberg’s system to prevent actuation of the fuel valve to the first position (gasoline) when the second fuel source (propane) is active. A POSA would understand that in Hallberg's design, the valve spool cannot be in two positions at once, inherently preventing actuation to the gasoline position when it is already in the propane position.

Ground 3: Obviousness over Rumao in view of DuroMax and Elsdon - Claims 8, 9, 11, and 14 are obvious over Rumao, DuroMax, and Elsdon.

• Prior Art Relied Upon: Rumao (Patent 10,337,399), DuroMax (DuroMax XP4400EH Operator’s Manual), and Elsdon (Patent 5,718,265).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targets the method claims, primarily independent claim 8, which recites a method of assembling a mechanical fuel lockout switch. Petitioner contended that Rumao teaches general methods for assembling portable dual-fuel generator systems. The physical apparatus of a fuel lockout switch was already rendered obvious by the combination of DuroMax and Elsdon (Ground 1).
  • Motivation to Combine: A POSA following Rumao's general instructions for assembling a generator would be motivated to incorporate the known safety feature taught by combining DuroMax and Elsdon. Assembling a generator by providing an engine (Rumao), coupling a known fuel valve (DuroMax), and adding a known lockout apparatus (Elsdon) to prevent a known hazard is an obvious assembly method.
  • Expectation of Success: Given that assembling dual-fuel generators was well-known in the art, as evidenced by Rumao and DuroMax, a POSA would reasonably expect to successfully incorporate the simple mechanical lockout feature of Elsdon into the assembly process of a DuroMax-type generator.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations incorporating Parlatore (Application # 2011/0100335) to teach features of a fuel regulator system and quick-disconnect hose couplings for claims 5, 12, and 13.

4. Key Claim Construction Positions

• "fuel lockout apparatus": Petitioner argued this term is a means-plus-function term under 35 U.S.C. §112(f) because the claim recites a generic nonce word ("apparatus") without sufficient corresponding structure for performing the lockout function. The corresponding structure disclosed in the ’780 patent’s specification is a flange that is rigidly coupled to the fuel valve handle and rotates to physically block the inlet for the unused fuel source.
• "prevent...coupling" and "permit...to couple": Petitioner contended these terms require preventing or permitting physical attachment of the second fuel line, not merely preventing or permitting fuel flow. This construction was based on the specification's sole embodiment, which shows a physical barrier, and statements made by the Examiner during prosecution distinguishing prior art that only stopped fluid flow but did not prevent physical connection of the hose.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-15 of the ’780 patent as unpatentable.