PTAB

IPR2025-01339

Fresh Products LLC v. SanaStar Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Urinal Anti-Splash Device
  • Brief Description: The ’154 patent discloses a urinal anti-splash device featuring a base that covers the urinal drain and an anti-splash body that extends vertically up the back wall of the urinal. The device can be installed as a single folded unit or as two separate pieces.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fushimi, Brown ’098, and Brown ’394 - Claims 1-4, 6-12, 14-16, 18, and 20 are obvious over Fushimi in view of Brown ’098 and Brown ’394.

  • Prior Art Relied Upon: Fushimi (Japanese Publication No. JPS 60-190865), Brown ’098 (Patent 10,145,098), and Brown ’394 (Patent 9,243,394).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fushimi, a 1985 publication, discloses the core invention: a urinal anti-splash device with a horizontal base and a vertical anti-splash body joined at a coupling region. Fushimi also teaches protrusions (brushes) on both surfaces. However, Fushimi lacks detail on the protrusion shape and the exact nature of the coupling. Petitioner asserted that Brown ’098 remedies this by teaching tapered protrusions (posts), a well-known feature for improving splash reduction, which maps to claim limitations requiring protrusions that "taper downwardly." Further, Brown ’394 was argued to teach the use of a perforated coupling region to join two parts of a urinal screen (e.g., date tabs), which allows the device to be manufactured as a single piece but used as separate components or folded, satisfying limitations in claims 6 and 14.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Fushimi with Brown ’098 as a routine design choice to improve the performance of Fushimi's generically described brushes with Brown ’098's more effective tapered posts. The combination with Brown '394 would have been motivated by the known engineering goal of simplifying manufacturing and shipping; creating a single, perforated unit that can be separated or folded is more efficient than producing two separate parts.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining these known elements—an L-shaped screen, tapered bristles, and a perforated joint—involves predictable mechanical principles and was a simple substitution of one known element for another to achieve a known benefit.

Ground 2: Obviousness over Fushimi and Valadez - Claims 11, 12, 14, 16, 18, and 20 are obvious over Fushimi in view of Valadez.

  • Prior Art Relied Upon: Fushimi (Japanese Publication No. JPS 60-190865) and Valadez (Application # 2005/0144711).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground focused on claims requiring an anti-splash body with a "longitudinal length," defined in the ’154 patent as being at least twice as long as it is wide. Petitioner contended that while Fushimi teaches the basic L-shaped structure, its depicted embodiment is not necessarily "elongated" under this definition. Valadez explicitly discloses an anti-splash guard with a range of dimensions, including a length of 8-16 inches and a width of 8-16 inches, which expressly covers embodiments that are twice as long as they are wide. Valadez also teaches different shapes for the base (round) and the anti-splash body (rectangular), mapping to limitations in claim 12.
    • Motivation to Combine: A POSITA would combine Fushimi's device with Valadez's teachings on dimensions for the clear purpose of adapting the device to fit a variety of urinal sizes. Both references teach the importance of fitting the device to the urinal. A POSITA would naturally look to known designs like Valadez to determine appropriate dimensions for Fushimi's screen, making it longer to cover more of the urinal's back wall and enhance splash protection.
    • Expectation of Success: Success would be expected because modifying the length of the anti-splash body is a simple dimensional change that uses known techniques to improve a known device for a predictable result (better coverage).

Ground 4: Obviousness over Fushimi and Wise - Claims 11, 12, 14, 16, 18, and 20 are obvious over Fushimi in view of Wise.

  • Prior Art Relied Upon: Fushimi (Japanese Publication No. JPS 60-190865) and Wise (Application # 2007/0044221).

  • Core Argument for this Ground:

    • Prior Art Mapping: Similar to Ground 2, this ground provided an alternative combination to demonstrate the obviousness of an elongated anti-splash body. Wise discloses a "splashless urinal insert" with specific measurements in its figures showing a center section with a width of 6.5 inches and a vertical length over 16 inches, clearly meeting the ’154 patent’s definition of "elongated." Wise also teaches an anti-splash body (rectangular) and a base (rounded front) of different shapes.
    • Motivation to Combine: The motivation is parallel to that in Ground 2: a POSITA would modify Fushimi's foundational design by incorporating the elongated body from Wise to increase the surface area for splash protection. This constitutes a simple substitution of one known anti-splash body for another, longer one to achieve the predictable benefit of improved performance and compatibility with taller urinals.
    • Expectation of Success: Modifying the dimensions of Fushimi's device based on the explicit teachings and figures in Wise would be a straightforward task for a POSITA with a high likelihood of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Fushimi with Valadez or Wise, further adding Brown ’098 to teach tapered protrusions (Grounds 3 and 5).

4. Key Claim Construction Positions

  • Petitioner argued that several key claim terms were explicitly defined by the patentee in the ’154 patent specification, and these definitions should control.
    • "elongated": Defined as "having a length that is at least twice as long as a width." This construction is central to the arguments in Grounds 2-5, which rely on Valadez and Wise to teach this specific proportion.
    • "longitudinal": Defined as a direction corresponding to the "elongated direction of the body." This links the term directly to the "elongated" definition.
    • "rectangular-like" and "circular-like": Defined as "having at least one pair of opposing parallel sides of equal length" and "having at least two round edges," respectively. These constructions are used to map the shapes of the prior art devices to claim limitations.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-4, 6-12, 14-16, 18, and 20 of the ’154 patent as unpatentable.