PTAB

IPR2026-00141

Bird Buddy Inc v. Woodstream Corp

Key Events

Petition

petition

Title: Self-Contained Bird Feeder
Brief Description: The ’242 patent discloses a self-contained, silo-style bird feeder with integrated electronic components. The device includes a built-in camera, computer, internal power source, and WiFi adapter to capture and transmit images of birds at a feed port over a wireless network.

Prior Art Relied Upon: Bennett (Application # 2016/0106072).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Bennett discloses every element of independent claim 1. Bennett teaches a self-contained bird feeder with built-in cameras, a computer controller, internal batteries, and wireless (WiFi) communication capabilities. Petitioner asserted that Bennett’s cameras (image sensors) are internally mounted within the feeder housing and aligned to observe feeding ports on the feeder bottom. For claim 3, Petitioner contended that Bennett’s sealing barrier, which separates the feed-containing upper chamber from the electronics-containing lower chamber, constitutes the claimed "feed compartment separator," and that feed is dispensed by gravity to the feed port.
- Motivation to Combine (for §103 grounds): This ground relies on a single reference, arguing it discloses all limitations. However, for the limitation of an internally mounted camera, Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to mount Bennett's cameras internally to weatherproof them and protect them from animal interference, a predictable design choice.
- Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in mounting components internally, as it is a simple and straightforward technique using standard fasteners.

Prior Art Relied Upon: Bennett (Application # 2016/0106072), Bevan (a 2015 publication on using Raspberry Pi for bird photography), and Raspberry Pi 2 Model B (a 2015 commercial product).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that while Bennett discloses a "controller," dependent claims 4-6 recite specific components of a computer (processor, display connector, multi-media interface, ethernet socket, USB ports, HDMI port). Petitioner asserted that the Raspberry Pi 2 Model B, a well-known microcontroller board available before the patent's priority date, inherently contains all of these specific components.
- Motivation to Combine (for §103 grounds): A POSITA would combine Bennett with a Raspberry Pi because it was a well-known, low-cost, and powerful controller for exactly the type of camera and sensor applications described in Bennett. Bevan explicitly taught using a Raspberry Pi to control a camera system for capturing images of birds at a feeder, providing a clear motivation. The patent owner’s own specification for the ’242 patent identifies the Raspberry Pi as a suitable computer, reinforcing its appropriateness for the claimed invention.
- Expectation of Success (for §103 grounds): A POSITA would expect success, as Bevan provided a guide for implementing a Raspberry Pi for this very purpose, and using a known controller like the Raspberry Pi to operate known sensors is a predictable implementation.

Prior Art Relied Upon: Bonham (Application # 2012/0048203).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Bonham discloses a self-contained bird house with all the electronic components required by claim 1: an internally mounted camera, a computer (microcontroller), an internal power source (batteries), and a wireless transceiver for internet connectivity. The entrance hole of the bird house functions as a feed port.
- Motivation to Combine (for §103 grounds): While Bonham discloses a bird house, Petitioner argued it would have been obvious for a POSITA to place bird feed inside it, thereby transforming it into a functional bird feeder. Bonham's discussion of monitoring "feeding rates" explicitly suggested the presence of food, making this modification a simple and obvious step to achieve the intended purpose of the device.
- Expectation of Success (for §103 grounds): Success would be reasonably expected because placing bird feed in a bird house is a trivial and uncomplicated task.
Additional Grounds: Petitioner asserted numerous additional obviousness challenges, including combinations of Bennett, Bonham, and Kin (a pet feeder) with Rofougaran (a USB WiFi dongle) to teach the WiFi dongle limitation of claim 2. Further grounds combined Bonham with Bennett and Humphries (a silo-style feeder) to teach the feed compartment separator of claim 3.

Petitioner argued for specific constructions based on statements made by the patent owner during prosecution to distinguish prior art.

"Built In": Petitioner contended this term should be construed as "functionally inseparable from [the bird feeder]." This construction was based on the applicant's arguments during prosecution that their invention's components were self-contained and integrated, unlike the stand-alone, separable OEM devices disclosed in the prior art reference Lovett.
"Internally Mounted": Petitioner argued this term should mean "inside and mounted to the feeder [housing]." This was based on the applicant's repeated arguments distinguishing Lovett by emphasizing that Lovett's camera, power source, and WiFi adapter were not inside the bird feeder.

Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-6 of Patent 11,627,242 as unpatentable under 35 U.S.C. §103.