PTAB

PGR2024-00003

College Products Inc v. Intirion Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multiple Linked Appliance with Auxiliary Outlet
  • Brief Description: The ’745 patent relates to a combination microwave and refrigerator appliance featuring a control circuit that manages power distribution from a single power source. The system is designed to interrupt power to the refrigerator and any auxiliary outlets during microwave operation to prevent electrical overload. The invention also incorporates a smoke sensor for automated safety shutdown and provides for auxiliary power outlets, such as USB ports, for charging external electronic devices.

3. Grounds for Unpatentability

Ground 1: Obviousness over Emma and ISDU - Claims 1, 13, 15, 20, 22, and 24-25 are obvious over Emma in view of ISDU.

  • Prior Art Relied Upon: Emma (Application # 2009/0188911) and ISDU (“Integrated Smoke detector Unit for Commercial Microwave Ovens,” a 2007 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Emma, a parent application to the challenged patent, discloses the foundational microwave-refrigerator combination appliance. Emma teaches a microprocessor-based control circuit that manages power from a single cord, disabling power to the refrigerator and auxiliary outlets when the microwave is in use to prevent overloads. Petitioner asserted that ISDU, a publication describing a smoke detector for commercial microwaves, supplies the missing claim elements. ISDU discloses integrating a smoke sensor that, upon detecting smoke, sends a signal to the microwave's logic to interrupt power, thereby ceasing magnetron operation. ISDU further teaches that "acknowledgement of the alarm state will reinstate all normal microwave functions," mapping directly to the claimed "Reset Enable Function."
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the teachings of Emma and ISDU to enhance appliance safety. Since Emma already focused on safety by preventing electrical overloads, a POSITA would have been motivated to incorporate another known safety feature, smoke detection, to prevent fires. A POSITA would have seen the combination as an aggregation of known elements to solve known problems—fire risk and electrical overload—in a single, convenient appliance.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The integration involved applying a known safety module (ISDU's smoke detector) to a known appliance platform (Emma's microwave-refrigerator) to achieve the predictable result of a smoke-responsive power shutdown. ISDU expressly suggests integrating its sensor inside the microwave, providing a clear path for implementation.

Ground 2: Obviousness over Emma, ISDU/Smith, and Quezada - Claims 12, 14, 19, 23, and 26 are obvious over Emma in view of ISDU or Smith, and further combined with Quezada.

  • Prior Art Relied Upon: Emma (Application # 2009/0188911), ISDU (a 2007 publication) or Smith (Patent 4,496,817), and Quezada (Application # 2012/0276763).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds upon the base combination of Emma’s appliance with a smoke sensor from either ISDU or Smith. Petitioner argued that Emma explicitly discloses providing "low power" auxiliary outlets for charging devices like cell phones. To meet the limitations for a USB port, Petitioner relied on Quezada, which teaches a wall-mountable power receptacle that integrates a standard AC outlet with a USB port and the necessary AC-to-DC conversion circuitry. Adding Quezada’s teachings to the base combination would result in an appliance with a smoke sensor and a USB charging port.
    • Motivation to Combine: Petitioner asserted that a POSITA would be motivated to substitute Emma’s general-purpose auxiliary outlets with the specific USB port taught by Quezada to meet clear market demands. At the time of the invention, USB was the rapidly emerging global standard for charging the very devices Emma’s outlets were intended for. This modification would be an "obvious to try" design choice driven by the desire for convenience, smaller port size, and standardization, making the appliance more commercially desirable.
    • Expectation of Success: The combination would yield predictable results. Quezada’s USB circuitry is designed to be powered by a standard AC source, which is precisely what Emma’s control circuit supplies to its auxiliary outlets. A POSITA would reasonably expect that replacing the standard outlet with Quezada’s combined outlet would result in a functional USB port that would, per Emma’s control logic, be disabled when the microwave draws cooking power.

  • Additional Grounds: Petitioner asserted alternative obviousness challenges against the same claims using Smith (Patent 4,496,817) and Butt (Patent 8,446,048) in various combinations with Emma, arguing these references also taught resettable smoke sensor systems. Petitioner also presented a distinct ground that claims 1-28 are invalid as indefinite under 35 U.S.C. §112 because the claim term "operative connection with a cooking area" fails to inform a POSITA with reasonable certainty about its scope.

4. Key Claim Construction Positions

  • "level of smoke" / "amount of smoke": Petitioner noted that, based on the Patent Owner's contentions in co-pending litigation, it understood the Patent Owner to interpret these terms as simply requiring the detection of any smoke, rather than measuring a specific quantity. For the purposes of its obviousness arguments, Petitioner applied this broad construction, arguing the claims were invalid even under the Patent Owner's interpretation. Petitioner also reserved the right to argue that the lack of a clear standard for what "level" or "amount" is required renders the term fatally indefinite.

5. Relief Requested

  • Petitioner requests that the Board institute a post-grant review and cancel claims 1, 12-15, 19-20, and 22-26 of Patent 11,674,745 as unpatentable.