PTAB

PGR2019-00036

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 Remote Control of Outdoor Cooking Appliances
  • Brief Description: The ’720 patent discloses a cloud computing platform for communicating with and controlling an outdoor barbecue grill or smoker. The system allows a user's mobile device to interact with the grill via the cloud, enabling features like analytics, advertising, remote diagnostics, and software updates.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lee and Henderson - Claims 4-7 and 20 are obvious over [Lee](https://ai-lab.exparte.com/case/ptab/PGR2019-00036/doc/1103) in view of [Henderson](https://ai-lab.exparte.com/case/ptab/PGR2019-00036/doc/1104).

  • Prior Art Relied Upon: Lee (Application # 2015/0134727) and Henderson (Application # 2015/0025687).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee disclosed a general cloud-based platform for managing various home appliances, including the core architecture of a cloud server with a processor, receiver, and transmitter for communicating with and controlling an appliance via a mobile device. While Lee taught the system, it did not specify an outdoor grill. Henderson supplied this missing element, disclosing a networked "smoking appliance" (e.g., a charcoal or gas grill) controllable by a mobile device. Petitioner asserted that Henderson also taught the features of the challenged dependent claims, including an "advertising platform module" (claim 4), tailoring ads based on usage data (claim 5), an "analytics module" (claim 7), and providing alerts based on food temperature (claim 20).
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Lee’s general cloud platform with Henderson’s specific networked grill as a natural progression of Internet of Things (IoT) technology. The combination was allegedly motivated by the predictable benefits of extending Lee’s system, such as allowing remote control from virtually anywhere and providing the improved data storage capacity of the cloud, which would be particularly useful for Henderson's data-collecting grill.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because Lee's system was designed for any home appliance and Henderson's grill already included a communication network, making the integration routine and predictable.

Ground 2: Obviousness over Lee, Henderson, Porter, and Ebrom - Claims 9-11 are obvious over Lee in view of Henderson, Porter, and [Ebrom](https://ai-lab.exparte.com/case/ptab/PGR2019-00036/doc/1110).

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Henderson (Application # 2015/0025687), Porter (a 2014 Harvard Business Review article), and Ebrom (Patent 9,164,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built on the Lee/Henderson combination to add teachings for remote diagnostics and failure prediction. Petitioner argued that Ebrom disclosed a "remote diagnostics module" for networked appliances (like an oven) that downloads and executes diagnostic tests from the internet. This mapped to the limitation of claim 9. For claim 10's requirement to "predict failures," Petitioner pointed to Ebrom’s system for detecting performance degradation and Porter’s description of how IoT product data can reveal "existing and future problems" and provide "early warnings about impending failure."
    • Motivation to Combine: A POSITA would be motivated to add the diagnostic capabilities taught by Ebrom and Porter to the smart grill of Lee/Henderson. This addition represented the integration of well-known IoT functionality to enhance product serviceability, reduce failures, and improve user experience. The combination involved applying known techniques to a known device to achieve predictable results.

Ground 3: Obviousness over Lee, Henderson, Amer, and Logue - Claim 30 is obvious over Lee in view of Henderson, [Amer](https://ai-lab.exparte.com/case/ptab/PGR2019-00036/doc/1105), and [Logue](https://ai-lab.exparte.com/case/ptab/PGR2019-00036/doc/1106).

  • Prior Art Relied Upon: Lee (Application # 2015/0134727), Henderson (Application # 2015/0025687), Amer (Application # 2016/0072638), and Logue (Patent 8,539,567).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 30, which added software update functionality. Petitioner argued that Amer taught a method for establishing direct and cloud-based connections for a smart appliance. Logue, a patent related to Nest smart devices, was cited for its explicit disclosure of a cloud-based software update process. Logue's system described a client device comparing its current software version to the latest version on a cloud server, and if outdated, requesting and installing the update from the server over the internet. This process directly mapped to claim 30's limitations of sending a request upon identifying outdated software and having the cloud system directly update the device.
    • Motivation to Combine: Petitioner asserted that a POSITA would be motivated to incorporate Logue's automated software update process into the connected grill system. This functionality was known to be highly beneficial for any smart device for remediating bugs, patching security vulnerabilities, and adding new features. The combination was a straightforward application of a standard feature for networked devices to improve the product over its lifecycle.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claim 8 over Lee, Henderson, and Porter (adding warranty claim verification); claims 17-18 over Lee, Henderson, and GMG Publication (adding use of ambient temperature data); and claims 13-15 over Lee, Henderson, GMG Publication, and Amer (adding a data store for recipes and custom smoking patterns).

4. Relief Requested

  • Petitioner requested institution of Post Grant Review and cancellation of claims 4-11, 13-15, 17-18, 20, and 30 of the ’720 patent as unpatentable under 35 U.S.C. §103.