PTAB

IPR2025-01462

Toughbuilt Industries Inc v. Meridian Intl Co Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Stackable Storage System
  • Brief Description: The ’689 patent relates to a latching mechanism for connecting and holding a first storage container to a second storage container. The system utilizes a sliding mechanism on one container that engages with locking grooves on the other, featuring a slider that can be secured in locked and unlocked positions via an elastic arm and engaging protrusions.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1-4 and 14-15 are anticipated by Duvigneau.

  • Prior Art Relied Upon: Duvigneau (Application # 2007/0012694).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Duvigneau discloses every limitation of independent claims 1 and 14. Duvigneau’s system, comprising a detachable carrying bag (first container) that mounts onto a wheeled base cabinet (second container), was asserted to be a "stackable storage system." The "depression" on the bag's rigid base constitutes the claimed "locking groove," while the "sliding latch" on the cabinet's cover is the claimed "sliding mechanism" for connecting the containers. Petitioner contended that Duvigneau's drawings inherently disclose the sliding latch extending laterally when disengaged and becoming coplanar with the cabinet's side surface when engaged, thereby satisfying all limitations of the independent claims.

Ground 2: Obviousness over Duvigneau and Niles - Claims 5-7 and 16 are obvious over Duvigneau in view of Niles.

  • Prior Art Relied Upon: Duvigneau (Application # 2007/0012694) and Niles (Patent 4,974,740).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that while Duvigneau teaches the core sliding latch, it lacks an explicit mechanism for retaining the slider in distinct locked and unlocked positions. Niles was introduced to supply this missing element, as it discloses a latch assembly with a flexible slide that engages a first cavity for a locked state and a second cavity for an unlocked state. This teaching allegedly corresponds to the "first engaging groove for holding the slider in the unlocked position" and a "second engaging groove for holding the slider in the locked position" recited in dependent claim 5. Further, Niles's description of its latch being made of a flexible material like polyethylene was argued to teach the "elastic arm with an engaging protrusion" of claim 7.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would recognize that Duvigneau's slider was not secured in its end positions and would be motivated to implement a solution to prevent unwanted movement. Niles provides a simple, known mechanism using grooves for this exact purpose. A POSITA would combine Niles's teachings with Duvigneau’s system to improve its functionality and reliability.
    • Expectation of Success: The combination involved applying known mechanical elements for their intended and predictable purpose. Therefore, a POSITA would have a reasonable expectation of success in modifying Duvigneau's support arm to incorporate the slider-retaining grooves taught by Niles.

Ground 3: Obviousness over Brocket and Heinrichs - Claims 1-4 and 14-15 are obvious over Brocket in view of Heinrichs.

  • Prior Art Relied Upon: Brocket (EP Publication # 3492226) and Heinrichs (Application # 2007/0215015).

  • Core Argument:

    • Prior Art Mapping: Petitioner asserted that Brocket discloses a stackable tool container system but utilizes a pivotable latch rather than a sliding mechanism. Heinrichs was introduced to teach a sliding lock mechanism for connecting containers, comprising a lock slider and locking bolt that engages an interface fitting (the "locking groove"). Petitioner argued that combining Brocket's stackable containers with the sliding lock mechanism from Heinrichs renders independent claims 1 and 14 obvious.
    • Motivation to Combine: A POSITA would recognize that pivotable latches (Brocket) and sliding latches (Heinrichs) are well-known and interchangeable design choices for locking containers. A POSITA would be motivated to substitute Heinrichs' more compact and key-lockable sliding design into Brocket's system to obtain a predictable and secure locking mechanism.
    • Expectation of Success: The proposed modification was a simple substitution of one known type of latch for another to perform the same function. This would have been a routine design choice for a POSITA with a high expectation of success.
    • Key Aspects: Petitioner emphasized that Brocket was cited during the prosecution of a related European application against nearly identical claims but was not disclosed to the USPTO by the Patent Owner.

  • Additional Grounds: Petitioner asserted numerous other obviousness challenges. These grounds primarily built upon the Duvigneau reference by adding secondary or tertiary prior art to teach specific dependent claim limitations, including using Morel for an alternative engaging groove mechanism, Weng for a stopper to prevent slider removal, Frydenberg for cooperating guides to constrain lateral movement, and Brunner for a handle and gripping area. A second family of grounds was based on Brocket and Heinrichs combined with Morel.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 11,192,689 as unpatentable.