PTAB

IPR2025-01366

FRESH PRODUCTS, LLC v. SANASTAR INC.

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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 cover a urinal drain and an anti-splash body that extends vertically up the urinal's rear wall. The base and body are connected by a configurable coupling region, allowing the device to be shipped flat and then installed in an L-shape. Both components feature protrusions to reduce urine splashback.

3. Grounds for Unpatentability

Ground 1: 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, a 1985 publication, discloses the core invention of the ’649 patent: an L-shaped urinal anti-splash device with a horizontal base and a vertical body, both having protrusions (called "brushes"). Fushimi teaches that the device is installed with the base covering the drain and the body on the rear wall. Petitioner asserted that Brown ’098 teaches specific features, like tapered protrusions, which are missing from Fushimi's general disclosure. Further, Brown ’394 was cited for teaching numerous well-known features, including the use of perforations to create a foldable or separable coupling region, the use of slits to allow for folding, and the concept of using a two-part screen (one for the wall, one for the drain). Petitioner contended that all limitations of independent claims 1, 8, and 18 are disclosed by these references. For example, Fushimi’s support structure (support 6) is the claimed “coupling region,” and its ability to be “bent freely” teaches the movement between a parallel (shipping) and perpendicular (use) position.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine these references to improve upon Fushimi's basic design using well-known, predictable solutions. A POSITA would have been motivated to incorporate the tapered protrusions from Brown ’098 into Fushimi’s device as a simple substitution of known elements to improve splash reduction. Similarly, a POSITA would look to Brown ’394 for manufacturing techniques, such as using perforations to create a single-piece, foldable device instead of Fushimi's two-piece "attached" mesh and frame, thereby reducing costs and simplifying shipping.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because the combination involves applying known features (tapered bristles, perforations, specific shapes) from analogous urinal screen devices to achieve their established functions in a predictable art.

Ground 2: 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: The prior art of Ground 1, further in view of Valadez (Application # 2005/0144711) and Wise (Application # 2007/0044221).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that should the primary combination be found insufficient, the addition of Valadez or Wise renders the dependent claims obvious. Valadez and Wise were cited to explicitly teach features that were only arguably implicit in the primary combination. Specifically, both Valadez and Wise disclose urinal screens with an "elongated shape" and "longitudinal length" (for claims 6 and 10), addressing the need to cover more of the urinal's back wall. Valadez teaches a rectangular-like anti-splash body and a circular-like base (for claim 15). Wise teaches an angled top portion on its anti-splash body to channel water (for claim 17).
    • Motivation to Combine (for §103 grounds): Petitioner asserted that a POSITA would have been motivated to incorporate the teachings of Valadez and Wise into the Fushimi-based design to enhance compatibility and performance. Both Fushimi and Valadez teach the importance of adapting a screen to fit a urinal's specific shape. A POSITA would naturally look to references like Valadez and Wise, which disclose specific dimensions and shapes (e.g., elongated, rectangular/circular), to improve Fushimi's general design for a wider variety of urinals.
    • Expectation of Success (for §103 grounds): Success would have been expected because Valadez and Wise demonstrate that features like elongated bodies and specific shapes were common and effective in the field of urinal anti-splash devices.

4. Key Claim Construction Positions

  • Petitioner argued that several key terms are explicitly defined in the ’649 patent specification and applied those definitions. These constructions are central to mapping the prior art.
    • "elongated": Defined as "having a length that is at least twice as long as a width." This is used for claim 10.
    • "longitudinal": Defined as corresponding to an "elongated direction" from a ground surface toward a ceiling. This is used for claim 6.
    • "rectangular-like": Defined as "having at least one pair of opposing parallel sides of equal length." This is used for claim 15.
    • "circular-like": Defined as "having at least two round edges." This is used for claim 15.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-2, 5-6, 8-11, 13-18, and 20 of Patent 10,294,649 as unpatentable.