PTAB

IPR2025-01369

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

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Power-Saving Method for an Induction Trash Can
  • Brief Description: The ’796 patent discloses a power-saving control method for an automatic trash can that uses an active infrared sensor. The method defines three distinct operational states for the microcontroller—"sleep," "working," and "standby"—to intermittently power the sensor, thereby reducing standby power consumption and extending battery life.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are obvious over Zheng

  • Prior Art Relied Upon: Zheng (CN 105425665 A)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zheng, which discloses a “smart environmentally-friendly trash bin,” teaches every limitation of the challenged claims. The central argument focused on mapping Zheng’s operational phases to the three distinct states recited in claim 1, which was the basis for allowance during prosecution.
      • Sleep State: Zheng’s microcontroller enters a “dormancy mode” where the infrared sensor is turned off to save power when no user is detected. This corresponds to the claimed "sleep state," where power to the sensor is cut off.
      • Working State: Before transmitting a detection signal, Zheng’s sensor is “powered on in advance of a third preset time” (e.g., 1.502 ms) to stabilize. Petitioner contended this power-on, pre-transmission period is the claimed "working state," where the sensor is powered but not yet actively detecting.
      • Standby State: After the initial power-on delay, Zheng’s microcontroller causes the sensor to transmit an infrared pulse waveform to detect a user. Petitioner argued this period of active transmission and detection is the claimed "standby state."
    • Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference. However, Petitioner argued that implementing Zheng's timed power cycling using a "watchdog timer," as claimed, would be obvious. Watchdog timers were routinely used in the art with microcontrollers to wake systems from a sleep state after a preset time to perform periodic tasks, precisely the functionality required by Zheng’s method.
    • Expectation of Success: A person of ordinary skill in the art (POSITA) would have a high expectation of success in using a standard watchdog timer to implement the periodic wake-up function in Zheng’s system, as it was a well-known and predictable application of the technology.

Ground 2: Claims 7-12 are obvious over Zheng in view of Wang

  • Prior Art Relied Upon: Zheng (CN 105425665 A) and Wang (CN 203740427U)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to specifically address the additional limitation in dependent claims 7-12, which requires the sensor’s induction area and window to be “located on the front can edge of the trash can.” While Petitioner argued this placement would be obvious from Zheng alone to detect a user approaching from the front, Wang was introduced as an explicit teaching of this feature. Wang discloses a conventional automatic trash bin and specifically teaches and depicts a "sensor 20 disposed on the front side" of the upper can body.
    • Motivation to Combine: A POSITA implementing Zheng’s power-saving control method would combine it with the conventional and logical sensor placement shown in Wang. Since both references relate to automatic trash cans designed to detect an approaching user, a POSITA would look to a known design like Wang’s for guidance on the optimal physical arrangement of the sensor. Placing the sensor on the top-front edge, as taught by Wang, is the most effective location to detect a user approaching to deposit trash.
    • Expectation of Success: There would be a high expectation of success in combining the references. The combination merely involved applying Zheng’s control logic to a trash can with a sensor located in a conventional, well-known position as exemplified by Wang. No technical challenges would arise from this simple integration.

4. Key Claim Construction Positions

  • Petitioner argued that the terms "sleep state," "working state," and "standby state" were central to the patentability of the claims and proposed the following constructions based on the specification and prosecution history:
    • "sleep state": The state in which the microcontroller cuts off power to the active infrared sensor.
    • "working state": The state in which the microcontroller is not sleeping and supplies power to the active infrared sensor, but does not necessarily cause it to transmit a signal for detection (e.g., a stabilization period).
    • "standby state": The state in which the microcontroller causes the active infrared sensor to emit a signal for detection.
  • These constructions were critical to Petitioner's argument that Zheng's disclosure of a power-off "dormancy mode," a pre-transmission power-on period, and an active signal transmission period directly maps to the three distinct states required by the claims.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-12 of the ’796 patent as unpatentable.