PTAB

PGR2019-00030

Sattler Tech Corp. v. HumanCentric Ventures, LLC

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1. Case Identification

2. Patent Overview

  • Title: VESA MOUNT ADAPTER BRACKET
  • Brief Description: The ’093 patent is a design patent for what is claimed to be an ornamental design for a VESA mount adapter bracket. The bracket is designed to enable specific HP Pavilion monitors, which lack native VESA compatibility, to be connected to standard VESA-compliant desk mounts, articulating arms, or other mounting systems.

3. Grounds for Unpatentability

Ground 1: Unpatentable under 35 U.S.C. § 171 for Lacking Ornamentality

  • Evidence Relied Upon: VESA Standard (Video Electronics Standards Association Flat Display Mounting Interface Standard, 2006), Metal Forming Paper (a 2018 paper from the 17th International Conference on Metal Forming), Gladiator Joe (a competitor VESA adapter for HP monitors), and VIVO (a second competitor VESA adapter for HP monitors).
  • Core Argument for this Ground: Petitioner argued that the single claim of the ’093 patent is unpatentable under 35 U.S.C. § 171 because the design is primarily functional, not ornamental. The petition contended that the overall appearance of the bracket, as well as each of its individual features shown in solid lines, is dictated entirely by functional and utilitarian requirements. These requirements stem from the need to interface with specific non-VESA HP monitors on one side and a standardized VESA mount on the other. The argument’s foundation is that if the design were altered, the bracket would cease to function for its intended purpose.
    • Functionality Mapping: Petitioner asserted that the solid-lined portions of the claimed design—the top and bottom tabs and the grommets—are dictated by function.
      • Tabs: The shape, size, and right-angle orientation of the top and bottom tabs were argued to be functionally necessary. The top tab must be shaped to fit and screw onto a specific protrusion on the back of certain HP monitors, while the bottom tabs must be shaped and positioned to interlock with pre-existing slots on the same monitors. Petitioner claimed these features are not a matter of design choice but are mandated by the physical constraints of the monitors the bracket is designed for.
      • Grommets: The location and spacing of the grommet holes were shown to correspond directly to the VESA Flat Display Mounting Interface Standard (FDMI™). The petition pointed to the standard’s requirement for 75 mm x 75 mm and 100 mm x 100 mm hole patterns, which the ’093 patent’s design incorporates. This adherence to an industry standard was presented as proof of function over ornament.
      • Raised Edges: Petitioner argued that the raised edges around the grommets are a known engineering technique for reinforcing sheet metal, not an aesthetic choice. Citing a technical paper on metal forming, the petition contended this feature serves the functional purpose of increasing the bracket's tensile strength to safely support the weight of a heavy monitor.
    • Key Aspects: A central part of the argument was the asserted lack of alternative designs. Petitioner presented evidence of two competitor products (Gladiator Joe and VIVO) that perform the exact same function and possess a nearly identical appearance to the claimed design. This, Petitioner argued, is compelling evidence that the design is dictated by its function, as different manufacturers independently arrived at the same solution to the same technical problem, leaving no room for ornamental variation. This lack of design alternatives was framed as a dispositive factor in evaluating functionality.

4. Key Claim Construction Positions

  • Petitioner asserted that the challenged claim requires no specific construction beyond its broadest reasonable interpretation in light of the patent’s specification. The petition stated that the figures of the ’093 patent alone provide a complete construction of the claimed design and that the claim language should be given its plain meaning to a person of ordinary skill in the art.

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner advanced a key technical contention that the raised edges of the grommets are a non-ornamental, functional feature. Citing a technical paper on metal forming processes, Petitioner argued that creating thickened hole edges with compressed rollover is a well-understood method for improving the fatigue strength of a steel sheet. This feature, therefore, provides functional reinforcement to ensure the bracket does not fail under the monitor's weight, directly contradicting any assertion that it is for ornamental purposes.

6. Relief Requested

  • Petitioner requests that the Board institute a post-grant review and cancel the single claim of Patent D 823,093 as unpatentable under 35 U.S.C. § 171 for being primarily functional and lacking ornamentality.