Guangzho EKO Trading Development Co., Ltd. (aka EKO Development Ltd.) et al.

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

Petition

Petition Analysis

## 1. Case Identification
- Case #: [IPR2025-01191](https://ai-lab.exparte.com/case/ptab/IPR2025-01191)
- Patent #: [10,822,165](https://ai-lab.exparte.com/patent/10822165)
- Filed: July 16, 2025
- Petitioner(s): [Guangzho EKO Trading Development Co., Ltd.](https://ai-lab.exparte.com/party/guangzho-eko-trading-development-co-ltd)
- Patent Owner(s): [Nine Stars Group (U.S.A.) Inc.](https://ai-lab.exparte.com/party/nine-stars-group-usa-inc)
- Challenged Claims: 1-24

## 2. Patent Overview
- Title: Waterproof Induction Container
- Brief Description: The ’165 patent discloses an automatically opening trash container designed to protect its internal components. The purported invention involves locating the electrical and mechanical components—such as the motor, sensor, and drive mechanism—within waterproof, sealed compartments inside the lid’s control housing to prevent contamination from moisture or corrosive gases.

## 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 is substantively indistinguishable from the ’165 patent, disclosing an identical trash can using the same figures and describing the same core functionality. Wang, published over two years before the ’165 patent’s filing date, was not considered during prosecution. Petitioner asserted that Wang explicitly discloses a "waterproof sensing trash can" with its "opening-closing apparatus" disposed in sealed "inner cavities" within the lid housing to protect them from moisture, corrosion, and garbage. This disclosure allegedly maps directly to every limitation of independent claim 1, including the "control housing," "first and second side concealed compartments," a "pivot shaft" with ends extending into those compartments, and an "automatic driving arrangement" (sensor, motor, transmission) also sealed within the compartments. Petitioner provided a detailed claim-by-claim analysis asserting that Wang also anticipates all dependent claims (2-24), teaching, for example, the use of a torsion spring to offset the cover's weight, a trapezoidal housing shape, and a sleeve to conceal the pivot shaft.

#### Ground 2: Claims 1-24 are obvious over Wang under 35 U.S.C. §103.
- **Prior Art Relied Upon:** Wang (CN 203740427 U) in view of the general knowledge of a Person of Ordinary Skill in the Art (POSITA).
- **Core Argument for this Ground:**
    - **Prior Art Mapping:** As a fallback argument, Petitioner contended that even if Wang does not explicitly anticipate every limitation, it renders all challenged claims obvious. The argument focused on minor differences in terminology between Wang and the ’165 patent’s claims. For any feature allegedly not explicitly taught by Wang, Petitioner argued a POSITA would have found it obvious to modify Wang’s device to include it, as such modifications would amount to nothing more than routine design choices using well-known components.
    - **Motivation to Combine (Modify):** The motivation to supplement Wang’s teachings with common knowledge stemmed from the desire to implement its described functions using standard, available technology. For example, while Wang does not use the term "servo motor," it depicts a motor structurally identical to the one claimed as such in the ’165 patent. A POSITA would be motivated to use a servo motor in Wang’s device to achieve the known benefits of precise, repeatable, and energy-efficient operation, which were desirable for an automatic lid. Similarly, a POSITA would find it obvious to use a "gear worm sector" (a known gear type) to transmit power or to size the gears of Wang's "gear reducer" to achieve a smooth, controlled "hydraulic manner" of movement.
    - **Expectation of Success:** A POSITA would have had a high expectation of success in making these modifications. Implementing Wang's design with conventional components like servo motors or specific gear types would involve applying known principles in a predictable system to achieve their expected functions, presenting no technical hurdles or unexpected results.

## 4. Relief Requested
- Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-24 of Patent [10,822,165](https://ai-lab.exparte.com/patent/10822165) as unpatentable.

Automatic trash can patent challenged for anticipation & obviousness. Wang prior art cited against all 24 claims for its identical sealed component design.