PTAB

IPR2025-01366

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 ’649 patent discloses a urinal anti-splash device comprising a base configured to sit at the bottom of a urinal and an anti-splash body that extends upward along the rear wall. The device features protrusions to break up a urine stream and can be installed by folding or detaching the base from the anti-splash body at a coupling region.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fushimi, Brown ’098, and Brown ’394 - Claims 1-2, 5-6, 8-11, 13-18, 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, published in 1985, discloses the core elements of independent claim 1. Fushimi teaches a urinal splash prevention device with a horizontal base and a vertical anti-splash body, both covered in bristle-like protrusions. The device is L-shaped, with the base covering the urinal drain and the anti-splash body mounting to the rear wall. Petitioner asserted that Fushimi's “support (6)” connecting the base and body is a “coupling region” that can be “bent freely,” which a Person of Ordinary Skill in the Art (POSITA) would understand allows movement between a flat, parallel orientation for shipping and a perpendicular orientation for use. Brown ’098 was cited for its teaching of tapered protrusions (for claims 5 and 8) and modern materials like ethylene-vinyl acetate (EVA). Brown ’394 was cited for teaching the use of perforations to create a configurable coupling region (for claim 13) and for disclosing various shapes for the body and base (for claim 15).
    • Motivation to Combine: A POSITA would combine Fushimi with the Brown references to improve upon Fushimi's basic design using well-known, modern techniques. Because Fushimi’s disclosure is terse, a POSITA would look to more recent art like the Brown patents for specific details on manufacturing, materials, and protrusion design. A POSITA would incorporate Brown ’098’s tapered protrusions to improve splash-reduction efficacy and would use the manufacturing methods taught. A POSITA would also be motivated to incorporate the perforated and foldable coupling region from Brown ’394 into Fushimi’s L-shaped device to simplify manufacturing into a single piece and reduce shipping costs, which is a common engineering goal for products that are shipped flat and assembled for use.
    • Expectation of Success: Petitioner contended there was a high expectation of success. The combination involved applying known features (tapered bristles, perforated joints, modern materials) from modern urinal screens (Brown) to an older, fundamentally similar L-shaped design (Fushimi). This was a predictable substitution of known elements to achieve the improved, single-piece, foldable urinal screen of the ’649 patent.

Ground 2: Obviousness over Ground 1 Art in view of Valadez and/or Wise - Claims 6, 10, 15, and 17 are obvious over the prior art of Ground 1 in view of Valadez and/or Wise.

  • Prior Art Relied Upon: Fushimi, Brown ’098, Brown ’394, and additionally Valadez (Application # 2005/0144711) and/or Wise (Application # 2007/0044221).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground reinforces the arguments for specific dependent claims. To the extent the primary combination was deemed insufficient, Petitioner argued Valadez and Wise explicitly teach the limitations. Valadez discloses an anti-splash body with an “elongated” shape and dimensions (length of 8-16 inches) that satisfy the patent's definition for the limitations in claims 6 and 10. Valadez also discloses a rectangular-like anti-splash body with a separate, circular-like base, mapping to claim 15. Wise discloses an insert with an angled upper portion (an upper deodorizer attachment) that channels flush water over the device, mapping to the "angled surface" limitation of claim 17.
    • Motivation to Combine: A POSITA would have been motivated to modify the Fushimi/Brown device with the features from Valadez and Wise to improve performance and compatibility. Incorporating the elongated dimensions taught by Valadez and Wise would allow the device to fit a wider variety of urinals, a predictable and desirable goal. Likewise, adopting the specific rectangular body and circular base shapes from Valadez would be a simple design choice to match common urinal geometry. Adding the angled top surface from Wise is a known method to improve flushing and cleaning, providing a clear motivation for its inclusion.
    • Expectation of Success: These modifications were presented as routine design choices. Adapting the size and shape of a urinal screen to better fit urinals was a common practice in the art, and a POSITA would have reasonably expected success in applying the specific dimensions and features from Valadez and Wise to the base Fushimi/Brown combination.

4. Key Claim Construction Positions

  • Petitioner argued that no terms required construction beyond the explicit definitions provided in the ’649 patent’s specification, which Petitioner applied. These definitions are central to several obviousness arguments.
    • “elongated”: The specification defines this term as “having a length that is at least twice as long as a width.”
    • “rectangular-like”: The specification defines this as “having at least one pair of opposing parallel sides of equal length.”
    • “circular-like”: The specification defines this as “having at least two round edges.”

5. Relief Requested

  • Petitioner requests institution of the inter partes review (IPR) and cancellation of claims 1-2, 5-6, 8-11, 13-18, and 20 of the ’649 patent as unpatentable.