PTAB

PGR2019-00024

GMG Products LLC v. Traeger Pellet Grills LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: A Cloud-Based Grill
  • Brief Description: The ’720 patent describes a system for remotely controlling an outdoor barbecue grill or smoker using a cloud computing platform. The system allows a user's mobile device to communicate with the cloud, which processes instructions and relays them to the grill, thereby enabling control from any location with an internet connection and overcoming the range limitations of direct-connection technologies like Bluetooth.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lee and Henderson - Claims 1-3, 16, 19, and 21-22 are obvious over Lee in view of Henderson.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727) and Henderson (Application # 2015/0025687).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary prior art references collectively disclose the core invention. Lee taught a cloud-based platform for managing a network of various household electronic appliances (e.g., refrigerators, air conditioners) from a mobile device via a cloud server. Henderson taught a networked "smoking appliance" or "gas-fired grill" that could be remotely monitored and controlled. Petitioner contended that combining Lee’s general cloud architecture with Henderson’s specific smart grill appliance discloses the fundamental system of independent claim 1, which recites a cloud platform receiving inputs and sending control instructions to an outdoor barbecue smoker.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to apply Lee’s known cloud technology to Henderson’s networked grill. This combination represented a natural progression in the Internet of Things (IoT) field, where applying cloud connectivity to new types of appliances was a well-established trend. The motivation was to achieve predictable benefits like true remote control without geographic limits, enhanced data storage for recipes and usage history, and continuous monitoring—all of which address the problems the ’720 patent purports to solve.
    • Expectation of Success: The combination involved applying a known technology (cloud management) to a known device type (smart grill) to achieve a predictable result. As such, a POSITA would have had a high expectation of success in creating a functional cloud-controlled grill.

Ground 2: Obviousness over Lee, Henderson, and Amer - Claims 12, 23-26, and 28 are obvious over Lee in view of Henderson and Amer.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Henderson (Application # 2015/0025687), and Amer (Application # 2016/0072638).
  • Core Argument for this Ground: This ground argued that adding Amer to the core combination of Lee and Henderson would have rendered additional claims obvious by teaching specific connectivity and setup features.
    • Prior Art Mapping: Petitioner introduced Amer to teach a specific method for onboarding a smart appliance. Amer disclosed an initial, temporary direct connection (e.g., Wi-Fi Direct) between a mobile device and an appliance, used to securely transfer Wi-Fi credentials. After this setup, the direct link is terminated, and the appliance and mobile device establish separate, independent connections to the cloud platform. This process was argued to map directly to limitations in claims 12 and 23 concerning initial device linking and subsequent independent operation.
    • Motivation to Combine: Petitioner argued that while Lee and Henderson provided the overall system, they did not detail the initial network setup. A POSITA seeking to build a consumer-friendly product would need a convenient method for connecting the grill to a user's home Wi-Fi. Amer’s method was a common and well-understood solution for this exact "first time setup" problem in the smart device industry, making its inclusion an obvious design choice to improve user experience.

Grounds 3 & 4: Obviousness over the Core Combination plus Tucker or Logue - Claims 27 and 29 are obvious over the primary combination in view of Tucker and Logue, respectively.

  • Prior Art Relied Upon: The combination of Lee, Henderson, and Amer, plus Tucker (Patent 9,759,429) for claim 27 and Logue (Patent 8,539,567) for claim 29.
  • Core Argument for these Grounds: Petitioner argued that claims 27 and 29 recite conventional features that would have been obvious additions to the primary cloud-connected grill system.
    • Prior Art Mapping: For claim 27, which requires the fuel to comprise wood pellets, Petitioner cited Tucker. Tucker disclosed an automated, networked pellet grill that operates by burning fuel pellets. For claim 29, which requires a function to identify and install software updates, Petitioner cited Logue. Logue, a Nest patent, disclosed a process for smart home devices to communicate with cloud-based servers to check their current software version and automatically install updates.
    • Motivation to Combine: A POSITA would be motivated to use wood pellets (per Tucker) as a fuel source in the Henderson grill, as this constituted a simple and predictable substitution of one known fuel type (wood chips, already suggested by Henderson) for another. Similarly, a POSITA would be motivated to incorporate Logue's automated software update functionality into the cloud-based grill system. This was a well-known and essential feature for any modern, networked device to ensure security, fix bugs, and improve functionality over time.

4. Relief Requested

  • Petitioner requested institution of Post-Grant Review and cancellation of claims 1-3, 12, 16, 19, and 21-29 of the ’720 patent as unpatentable under 35 U.S.C. §103.