PTAB

PGR2019-00034

GMG Products LLC v. Traeger Pellet Grills LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Cloud-Based Grill Control System
  • Brief Description: The ’833 patent discloses a method and system for controlling an electronically-controlled wood-pellet grill using a software application on a mobile device. The system architecture involves the mobile device, the grill, and a remote cloud computing system that facilitates communication and control.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lee, Tucker, and Henderson - Claims 1-2 and 6-10 are obvious over Lee in view of Tucker and Henderson.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Tucker (Patent 9,759,429), and Henderson (Application # 2015/0025687).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches every limitation of the challenged claims. Lee discloses the core cloud-based architecture: a system for remotely managing various home appliances from a smartphone app via a "cloud-based data server," including the claimed communication sequence of receiving status notifications and sending control signals. Tucker discloses the specific appliance: an "automated pellet grill" with a hardware controller that can be wirelessly controlled by a smartphone to adjust temperature by feeding fuel pellets from a hopper. Henderson discloses the sophisticated user interface and app functionality, teaching a "mobile application" for a smoking appliance that allows a user to monitor and control functions like temperature, store recipes, and receive notifications.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine these references to achieve predictable results. A POSITA would have been motivated to apply Lee’s general cloud-based appliance control system to the specific wood-pellet grill taught by Tucker. This reflects a natural progression of Internet of Things (IoT) technology. Lee expressly encourages adding any home appliance to its network. Incorporating Henderson’s advanced app interface would have been a simple substitution of one known user interface for another to provide a more user-friendly experience for controlling the networked grill.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these known elements, as it involved applying a known cloud platform to a known network-capable appliance to gain well-understood benefits like remote access, improved data storage, and continuous data collection.

Ground 2: Obviousness over Lee, Tucker, Henderson, and Amer - Claims 3 and 5 are obvious over Lee in view of Tucker, Henderson, and Amer.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Tucker (Patent 9,759,429), Henderson (Application # 2015/0025687), and Amer (Application # 2016/0072638).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination in Ground 1, adding Amer to teach the specific limitations of claims 3 and 5. For claim 3 ("receiving an indication... that the grill is attempting to communicate"), Petitioner asserted that Amer discloses an initial setup protocol where an appliance connects directly to a smartphone in a "Wi-Fi Direct Mode" to obtain network credentials. This connection itself serves as an indication to the user's app that the appliance is attempting to join the cloud network. For claim 5 ("displaying a user interface that prompts... demographic information"), Petitioner argued that Amer’s user registration process—which prompts for a username, email address, and password to create an account and register a device—discloses this limitation.
    • Motivation to Combine: Petitioner argued that Lee does not detail how an appliance initially connects to a user’s Wi-Fi network. Amer provides a common and convenient solution to this problem. A POSITA seeking to implement Lee’s system would have been motivated to incorporate Amer’s direct-connection setup method to provide a seamless user experience. Similarly, Amer's user registration system would have been a known technique to improve Lee's system by allowing for enhanced organization and management of multiple users and devices.

Ground 3: Obviousness over Lee, Tucker, Henderson, and Jablokov - Claim 4 is obvious over Lee in view of Tucker, Henderson, and Jablokov.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Tucker (Patent 9,759,429), Henderson (Application # 2015/0025687), and Jablokov (Patent 9,928,672).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Jablokov to the base combination to teach the limitations of claim 4, which recites disabling functionality when the user is outside a specified distance from the grill. Petitioner contended that Jablokov discloses a "watchdog safety shutoff" feature for cloud-controlled appliances, including outdoor grills. Jablokov’s system uses a proximity detection device (e.g., Bluetooth) to scan for an authorized user's smartphone. If the user's device is not detected within a pre-determined range, the system disables control of the appliance or shuts it off entirely, directly mapping to the claim limitation.
    • Motivation to Combine: Petitioner argued that a POSITA would have been motivated to add Jablokov’s proximity-based safety feature to the cloud-controlled grill system. For a potentially dangerous appliance like a grill that can be operated from anywhere in the world, incorporating a "safety precaution" that prevents unattended operation is a desirable and obvious improvement. This feature would naturally be considered to reduce the risk of uncontrolled fires.

4. Relief Requested

  • Petitioner requests institution of Post Grant Review and cancellation of claims 1-10 of the ’833 patent as unpatentable under 35 U.S.C. §103.