PTAB

PGR2019-00035

GMG Products LLC v. Traeger Pellet Grills LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cloud-Based Control of a Wood-Pellet Grill
  • Brief Description: The ’833 patent discloses a system for remotely monitoring and controlling an electronically-controlled wood-pellet grill. The system uses a software application on a mobile device that communicates with the grill via a cloud-based computer system to manage functions like temperature and cooking cycles.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lee, Tucker, Henderson, and Amer - Claims 11-25 are obvious over Lee in view of Tucker, Henderson, and Amer.

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Tucker (9,759,429), Henderson (Application # 2015/0025687), and Amer (Application # 2016/0072638).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these four references taught every limitation of the challenged claims, which merely apply standard Internet of Things (IoT) and cloud-computing principles to a conventional outdoor grill.
      • Lee taught the foundational system architecture: a cloud-based data server allowing a user to manage a network of various household electronic appliances via a smartphone application. Lee disclosed the core communication sequence of a user's mobile device sending control signals to an appliance through the cloud and receiving status notifications in return.
      • Tucker taught the specific appliance missing from Lee: an “automated pellet grill” that could be controlled wirelessly by a smartphone. Petitioner contended that substituting Tucker’s known wood-pellet grill for one of Lee's generic home appliances was an obvious design choice. Tucker disclosed key grill-specific features, including a controller that adjusts a fuel feed motor to maintain a desired temperature based on user input.
      • Henderson taught the specific user interface (UI) functionalities and smart features recited in the dependent claims. It disclosed a networked "smoking appliance" controlled by a mobile app that could set alerts for timers and temperature, program and modify custom "smoke plans" (smoking cycles) in real-time, and store recipes.
      • Amer taught the initial network configuration process. It disclosed a cloud-based architecture for managing appliances, including a Wi-Fi direct mode where an appliance connects directly to a smartphone to receive network credentials (e.g., password) before establishing a persistent connection to the cloud via a home Wi-Fi router. This process maps directly to the claimed steps of receiving user permission for the grill to communicate with the cloud.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references for several reasons. Applying cloud technology to outdoor grills was a natural progression of the broader IoT trend, incentivizing manufacturers to develop smart home devices. Lee provided a general-purpose, cloud-based platform and expressly encouraged connecting any home appliance to its network. A POSITA would have seen Tucker’s and Henderson’s networked grills as ideal candidates for integration into Lee's system. The combination was motivated by the desire to achieve predictable benefits, including true remote control from any location, improved data storage capacity for cooking data (a need identified in Henderson), and continuous data collection by the cloud even when the user’s mobile device is offline.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The integration involved applying well-understood cloud protocols (from Lee and Amer) to a known type of network-enabled appliance (from Tucker and Henderson). This was a simple substitution of known elements to obtain predictable results, as each reference was directed to a different, well-known aspect of IoT and grilling technology. No unexpected results were produced by the combination.

4. Relief Requested

  • Petitioner requested the institution of a Post-Grant Review and cancellation of claims 11-25 of the ’833 patent as unpatentable under 35 U.S.C. §103.