PTAB

IPR2026-00246

Klein Tools Inc v. Milwaukee Electric Tool Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Tool Attachment System
  • Brief Description: The ’064 patent relates to a tool attachment system for detachably connecting a tool pouch to a user's belt. The system uses a receiver with a channel that attaches to the belt and a corresponding tool attachment device on the pouch, which features a disk-shaped mating structure that slidably engages the channel and is secured by a locking pin mechanism.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, and 12 under §102

  • Prior Art Relied Upon: Albrecht (DE9308896U1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Albrecht, which discloses a device for carrying a handgun, anticipates every element of independent claim 1. Albrecht teaches a "tool attachment system" comprising a receiver ("carrying plate 3") with a channel ("insertion opening 6") and a locking hole ("pendulum bearing 7"), and a tool attachment device ("pendulum bar 2") coupled to a pouch. This device includes a body with front and rear surfaces, a disk mating structure ("retaining flange 13") that slidably engages the channel, a locking mechanism ("bolt 15") that protrudes into the locking hole, and an actuator ("push button 11") to release the lock. Petitioner further asserted that Albrecht's disclosure of a pivotable connection and a pouch attached via multiple "rivet holes" anticipates dependent claims 2 and 12, respectively.

Ground 2: Obviousness of Claims 3-9 and 16-20 under §103

  • Prior Art Relied Upon: Albrecht (DE9308896U1) and Gabriel (Patent 8,919,622).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that while Albrecht discloses the core system, the limitations in dependent claims 3-9 and independent claim 16 related to actuator placement and upward movement are rendered obvious by Gabriel. Gabriel, which discloses a detachable beverage carrier, explicitly teaches an actuator ("lower end portion 36") located below the mating structure ("disk 23") that moves upward to release the locking mechanism.
    • Motivation to Combine: A POSITA would combine Gabriel’s actuator design with Albrecht’s system to create a more ergonomic device. Locating the actuator below the mating structure and designing it for upward actuation allows a user to unlock and decouple the pouch from the receiver in a single, one-handed upward motion, a known advantage in the field of tool holders.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination. Both references address the same problem of releasably attaching a container to a belt, and modifying the location and actuation direction of a simple mechanical button is a routine design choice well within the skill of an ordinary artisan.

Ground 3: Alternative Obviousness of All Claims over Albrecht, Glock, and Gabriel

  • Prior Art Relied Upon: Albrecht (DE9308896U1), Glock (AT388448), and Gabriel (Patent 8,919,622).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative in the event the Patent Owner successfully argues that Albrecht’s locking mechanism does not protrude into a separate locking hole. Petitioner asserted that Glock, a gun holster patent, explicitly teaches this feature with its "button [15]" that "protrudes into the hole --5--" in the receiver body. A POSITA would modify Albrecht’s locking mechanism to incorporate Glock’s simpler pin-and-hole design. The teachings of Gabriel regarding actuator placement would then be applied to this modified Albrecht/Glock system for the same reasons articulated in Ground 2.
    • Motivation to Combine: A POSITA would be motivated to replace Albrecht’s "leaf spring 9" with Glock’s direct pin-in-hole mechanism to simplify the design and improve stability. Albrecht itself notes that the length of its leaf spring can result in "disruptive swinging and pendulum movements," providing a clear reason to seek an alternative, more compact locking solution like that shown in Glock.
    • Expectation of Success: Success was expected, as replacing one spring-loaded locking pin arrangement with another is a straightforward mechanical design choice. Both Albrecht and Glock relate to gun holsters, making the combination of their respective features particularly predictable.

4. Key Claim Construction Positions

  • Means-Plus-Function under §112(f): Petitioner contended that the terms "locking mechanism" and "mating structure" are generic nonce words that fail to recite sufficient structure and should be construed as means-plus-function terms.
    • "locking mechanism": Proposed function is "lock[ing] the tool attachment device to the receiver when the locking mechanism is in a locked position." The corresponding structure disclosed in the ’064 patent is "a locking pin 60 that extends through a pinhole 62 through disk 22" and its equivalents.
    • "mating structure" (as used in claim 16): Proposed function is to "slidably engage the channel of the receiver." The corresponding structure disclosed in the ’064 patent is "disk 22" and its equivalents.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate. Although the examiner was presented with the Gabriel reference in an Information Disclosure Statement, it was one of dozens of references cited and was never substantively analyzed, applied in a rejection, or considered in combination with Albrecht or Glock. Petitioner asserted the examiner therefore misapprehended or overlooked the significance of Gabriel's disclosures related to the actuator, warranting a fresh review.

6. Relief Requested

  • Petitioner respectfully requested that the Board institute IPR and cancel claims 1-9, 12, and 16-20 of the ’064 patent.