PTAB

IPR2025-01191

Guangzho Eko Trading Development Co Ltd v. Nine Stars Group USA Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Waterproof Induction Container
  • Brief Description: The ’165 patent discloses an automatically opening trashcan featuring a sensor that triggers a motor to lift the container's cover. The core purported invention is placing the electrical and mechanical components within waterproof, sealed compartments inside the cover unit to protect them from moisture and contamination.

3. Grounds for Unpatentability

Ground 1: Claims 1-24 are anticipated by Wang under 35 U.S.C. §102.

  • Prior Art Relied Upon: Wang (CN 203740427 U).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wang, a Chinese patent application published more than two years before the ’165 patent's filing date, discloses an identical trashcan. The petition asserted that Wang uses the same figures and functionally identical descriptive language as the ’165 patent. For independent claim 1, Petitioner mapped that Wang teaches a "waterproof induction container" comprising a container body and an induction-actuated cover. This cover includes a control housing with "first and second side concealed compartments" at its rear, a pivot shaft with ends extending into these compartments, and an "automatic driving arrangement." This arrangement, as disclosed in Wang, includes a sensor unit, an actuation unit (motor, transmission) concealed in a waterproof manner, and a torsion spring element to assist in opening the cover, thereby meeting all limitations of claim 1. Petitioner provided similar detailed mappings for all dependent claims, arguing that features like the servo motor, gear worm sector, and trapezoidal housing shape are also explicitly or inherently disclosed in Wang's figures and text.
    • Key Aspects: The core of the argument rested on the assertion that the disclosures are "indistinguishable," with some of the same inventors listed on both documents. Wang was not cited or considered during the prosecution of the ’165 patent.

Ground 2: Claims 1-24 are obvious over Wang under 35 U.S.C. §103.

  • Prior Art Relied Upon: Wang (CN 203740427 U), supplemented by the general knowledge of a Person of Ordinary Skill in the Art (POSITA).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that even if Wang is found not to anticipate every limitation literally, any differences are minor and would have been obvious to a POSITA. For example, while Wang discloses a motor (item 15) that is structurally identical to the "servo motor" (item 61) in the ’165 patent, Petitioner contended that even if Wang's motor was not considered a servo motor, it would have been obvious to use one. Similarly, Wang's disclosure of a "gear reducer" (item 14) that provides stable, reliable, and efficient speed reduction would make the claimed "hydraulic manner" of cover movement obvious. The petition further argued that other specific terms used in the claims, such as the "gear worm sector" and a "detachably coupled" battery cover, describe components that are either identical in Wang or represent obvious, routine design choices for implementing the functions described in Wang.
    • Motivation to Combine: The motivation for any modification was presented as simple design choice and the pursuit of predictable results. For instance, Petitioner argued a POSITA would have been motivated to use a servo motor in Wang’s design to improve operational accuracy, repeatability, and energy efficiency, as servo motors were routinely used in similar waste receptacle applications. Likewise, designing the pivot shaft and sleeve with corresponding non-circular cross-sections (claims 18, 20, 22) would be a well-known and obvious technique to prevent slippage and ensure proper lid operation.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success because implementing these features would involve applying known components (like servo motors or worm gears) for their intended purposes in a well-understood mechanical system. The combination would yield only predictable results without requiring any undue experimentation.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-24 of the ’165 patent as unpatentable.