PTAB

IPR2025-01530

RJ Brands LLC v. SharkNinja Operating LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dual Air Fryer Cooking System
  • Brief Description: The ’377 patent relates to a dual air fryer cooking system featuring a housing with two side-by-side internal compartments separated by a central dividing wall. Each compartment is configured to receive its own removable cooking container and contains a dedicated heating element and fan to allow for independent cooking operations.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 7-10, and 18 are obvious over Guo.

  • Prior Art Relied Upon: Guo (Chinese Utility Model # CN210354396U).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Guo, a multi-chamber food processor, discloses all limitations of the challenged claims. Guo’s horizontal configuration shows a housing with a first and second internal compartment separated by an integral dividing wall extending from the base. Each compartment receives a removable fryer assembly (cooking container), has its own heating device, and is serviced by a fan assembly. Petitioner asserted that Guo’s teachings of independent heating device operation and inhibition of "smell channeling" between compartments inherently require the fluidly separate structure recited in the claims. The vertical stacking of fans over heating elements, handles on cooking chambers, and a single motor driving both fans are also explicitly shown or described in Guo.

Ground 2: Claims 12-16 and 19-21 are obvious over Guo in view of Conrad.

  • Prior Art Relied Upon: Guo (Chinese Utility Model # CN210354396U) and Conrad (WO 2019/068193A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Guo provides the fundamental dual-chamber air fryer structure with independent heating and airflow systems. Conrad, which discloses an air fryer with dual, independently controlled cooking zones, was introduced to supply the limitations related to advanced electronic control not explicitly detailed in Guo. Specifically, Conrad was argued to teach a control system programmable for simultaneous cooking in separate modes, configured to receive user inputs (e.g., temperature, time), and capable of operating fans at different speeds to achieve different cooking conditions in each zone.
    • Motivation to Combine: A POSITA would combine Conrad’s advanced control features with Guo’s dual-chamber physical appliance. The primary purpose of a dual-fryer is to cook different foods at the same time, and incorporating Conrad’s programmable, independent controls would be a logical step to fully realize this capability, making the device more versatile and efficient.
    • Expectation of Success: Petitioner argued success would be highly predictable. Integrating known electronic control systems into an appliance with an established mechanical layout was a routine practice in the art, requiring only conventional engineering adaptation without undue experimentation.

Ground 3: Claims 7 and 11-17 are obvious over Philips in view of Moon.

  • Prior Art Relied Upon: Philips (WO 2018/095949A1) and Moon (Application # US 2017/0231430).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Philips teaches the base dual-cooking appliance, including two physically separated, side-by-side compartments, each with its own fan and heating element. Moon was cited to add specific ergonomic and performance-enhancing features. Moon explicitly teaches a "handled food basket" to satisfy claim 7's requirement for handles on each container. Furthermore, Moon’s drawer-style cooking container, which "substantially seals the chamber against heat loss," was argued to teach the limitation in claims 11 and 17 of a container that seals the opening to the internal compartment when inserted.
    • Motivation to Combine: A POSITA would be motivated to add Moon’s well-known handle design to Philips’ removable containers to improve user safety and ease of use when handling hot components. Similarly, a POSITA would incorporate Moon’s sealing drawer design to improve the thermal efficiency and cooking consistency of the Philips device by preventing heat leakage, a common objective in appliance design.
    • Expectation of Success: Petitioner asserted that success was expected because the proposed modifications involve the predictable application of conventional, known design elements to an analogous device. Adding handles and improving seals are standard ergonomic and efficiency enhancements in the field of cooking appliances.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 3 in the petition) based on Philips alone, arguing it taught the core features of claims 1-4, 8-10, and 18-22, including the inherent presence of a motor to drive the disclosed fans.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention applied across all grounds was that the ’377 patent is not entitled to its claimed July 15, 2019, priority date. Petitioner argued that the critical "dividing wall" limitation, which is recited in all challenged claims, lacks written description support in the ’193 provisional application. This element was allegedly first introduced as new matter in a subsequent PCT application filed on July 15, 2020. This later effective filing date, petitioner argued, renders references like Guo, which was published in April 2020, valid prior art against all claims.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-4 and 7-22 as unpatentable.