PTAB

PGR2019-00030

Sattler Tech Corp v. HuMancenTriC Ventures LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: VESA MOUNT ADAPTER BRACKET
  • Brief Description: The ’093 patent claims an ornamental design for a VESA mount adapter bracket. The bracket is designed to enable specific, non-VESA compliant computer monitors to be attached to industry-standard VESA mounting systems, such as articulating arms or wall mounts.

3. Grounds for Unpatentability

Ground 1: Lack of Ornamentality under §171 - The claim is unpatentable under 35 U.S.C. § 171 because the design is primarily functional.

  • Evidence Relied Upon: VESA Standard (the Video Electronics Standards Association Flat Display Mounting Interface Standard), Metal Forming Paper (a 2018 conference paper on improving sheet metal fatigue strength), Gladiator Joe (a commercially available VESA adapter), and VIVO (another commercially available VESA adapter).
  • Core Argument for this Ground:
    • Petitioner argued that the claimed design of the ’093 patent is not ornamental but is instead dictated entirely by functional requirements. The overall appearance of the bracket is not a matter of aesthetic choice but is a necessary result of the article’s function: to securely interface a specific model of HP Pavilion monitor with a standard VESA mount. Petitioner asserted that if any of the claimed design elements were changed, the bracket would fail to function for its intended purpose. The argument was detailed across four key features of the design.
    • Functionality of Tabs: The claimed top and bottom tabs, which are shown in solid lines, were argued to be purely functional. Their specific shape, size, and ninety-degree angle relative to the backplate are dictated by the need to mate with corresponding physical features on the rear housing of the target monitors. The top tab must fit over and screw into a specific bump, while the bottom tabs must interlock with pre-existing slots. Their appearance is therefore a functional necessity, not an ornamental choice.
    • Functionality of Grommets (Mounting Holes): The placement, spacing, and size of the grommets were argued to be dictated by the VESA Flat Display Mounting Interface Standard. To function as a VESA adapter, the bracket must have holes conforming to the 75 mm x 75 mm or 100 mm x 100 mm VESA patterns. This adherence to a functional standard removes the grommet layout from the realm of ornamental design.
    • Functionality of Raised Grommet Edges: Petitioner contended that the raised edges around the grommets are a known engineering feature used to increase the structural strength and fatigue resistance of holes in sheet metal. Citing a technical paper, Petitioner argued this feature serves the functional purpose of ensuring the bracket can safely support the weight of a heavy monitor without the metal tearing at the attachment points.
    • Lack of Alternative Designs: As evidence that the design is dictated by function, Petitioner presented two competitor products (Gladiator Joe and VIVO) that perform the exact same function and possess a nearly identical overall appearance to the claimed design. Petitioner argued this demonstrates that there are no alternative designs available, because the functional constraints leave no room for ornamental variation. The owner of the ’093 patent itself markets the product by highlighting its functional compliance with VESA standards and its specific fit with certain monitors, further underscoring that the design is driven by utility rather than aesthetics.

4. Key Technical Contentions (Beyond Claim Construction)

  • VESA Standard Compliance as a Functional Mandate: Petitioner’s central technical contention was that compliance with the dimensional specifications of the VESA Standard is a functional requirement, not a design choice. Any product intended to function as a VESA adapter must incorporate the standard’s specified mounting hole patterns (e.g., 100mm x 100mm), which directly dictates a significant portion of the patented design’s appearance.
  • Structural Reinforcement as a Functional Feature: Petitioner asserted that the raised edges of the grommets represent a known technique in metal forming to improve the load-bearing capacity of a pierced metal sheet. This feature was presented not as an aesthetic flourish but as a necessary engineering solution to the functional problem of supporting a monitor’s weight, thereby preventing material failure.

5. Relief Requested

  • Petitioner requests institution of post-grant review and cancellation of the single claim of the ’093 patent as unpatentable for being primarily functional under 35 U.S.C. § 171.