College Products Inc v. Intirion Corp

1. Case Identification

• Case #: PGR2024-00004
• Patent #: 11,674,746
• Filed: October 9, 2023
• Petitioner(s): College Products, Inc.
• Patent Owner(s): Intirion Corporation
• Challenged Claims: 1-24

2. Patent Overview

• Title: Multiple Linked Appliance with Auxiliary Outlet
• Brief Description: The ’746 patent discloses a combination microwave and refrigerator appliance. The system features a control circuit that cuts power to the refrigerator and other auxiliary outlets when the microwave is in use, a smoke sensor that can shut down the microwave, and USB ports for charging electronic devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5-6, 8-11, 13-17, and 20-24 are obvious over Emma in view of ISDU.

• Prior Art Relied Upon: Emma (Application # 2009/0188911) and ISDU (a 2007 Northeastern University publication).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Emma, the parent application of the ’746 patent, disclosed the core combination microwave-refrigerator appliance with a control circuit for managing power distribution to prevent overloads, including disabling the refrigerator and auxiliary outlets during microwave operation. Petitioner asserted that ISDU taught the missing element: integrating a smoke detector into a commercial microwave oven. The ISDU system was described to temporarily disable microwave operation when smoke is detected and included a reset function to reinstate normal operation after user acknowledgement.
  • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the known safety feature from ISDU (a resettable smoke sensor) with the appliance combination of Emma. The motivation stemmed from the desire to improve the safety and functionality of the base appliance. As ISDU explicitly related to adding features to microwave ovens, incorporating its safety system into Emma’s microwave-refrigerator was presented as a predictable and logical step.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success. The integration of sensors into appliances was a common practice, and ISDU’s own teachings suggested placing the detector inside the microwave for optimal performance, leading to a predictable outcome.

Ground 2: Claims 1-3, 5-6, 8-11, 13-17, and 20-24 are obvious over Emma in view of Smith.

• Prior Art Relied Upon: Emma (Application # 2009/0188911) and Smith (Patent 4,496,817).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground presented an alternative combination for the same claims. As in Ground 1, Emma was asserted to teach the foundational microwave-refrigerator appliance. Smith was cited for its disclosure of a method for anticipating fire in a microwave oven by using a gas sensor to detect smoke or charring. Upon detecting a characteristic rate of change in gas concentration, Smith’s system turned off power to the magnetron to prevent combustion. Petitioner also argued that Smith’s power control relay, which de-energized the magnetron, implicitly enabled a reset function.
  • Motivation to Combine: Petitioner argued that a POSITA would be motivated to combine these references because both were directed toward optimizing the functionality and safety of electric cooking appliances. Emma’s teaching of adding power-cycling safety features would naturally lead a POSITA to consider other known microwave safety features, such as the smoke detection taught by Smith. The combination was argued to be a predictable aggregation of known elements performing their known functions.
  • Expectation of Success: The expectation of success was argued to be high because the combination involved implementing a known type of sensor (from Smith) into a known appliance configuration (from Emma) to achieve the predictable result of enhanced safety.

Ground 3: Claims 4, 7, 8, 12, 18, and 19 are obvious over Emma in view of ISDU or Smith, and further combined with Quezada.

• Prior Art Relied Upon: Emma (Application # 2009/0188911), ISDU or Smith, and Quezada (Application # 2012/0276763).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed the dependent claims reciting USB ports. Petitioner established the base smoke-sensing microwave-refrigerator appliance using the combinations of Emma with either ISDU or Smith, as argued in the grounds above. Petitioner contended that Quezada taught combining a standard AC electrical outlet with a USB port and associated AC/DC conversion circuitry into a single, wall-mountable unit for charging electronic devices.
  • Motivation to Combine: Petitioner argued that Emma explicitly taught using its auxiliary AC outlets for charging low-power devices like cell phones. At the time of the invention, USB had become a well-known, standardized method for charging such devices. Therefore, a POSITA would have been motivated to substitute or supplement Emma's conventional auxiliary outlets with the USB port technology taught by Quezada. This was framed as a simple substitution of one known element for another to obtain predictable results and improve convenience.
  • Expectation of Success: Petitioner asserted a high expectation of success, as substituting one type of power outlet for another was a simple design choice. Quezada’s system was designed to work with any standard power source, so integrating it into Emma’s existing power control circuit for auxiliary outlets would predictably result in a functional USB charging port on the microwave.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on Emma in combination with Butt (Patent 8,446,048), which also taught a resettable safety shut-off for kitchen appliances based on a smoke detector. Petitioner also raised indefiniteness challenges under 35 U.S.C. §112 against all claims.

4. Key Claim Construction Positions

• Petitioner argued that no claim terms required construction to find the claims invalid. However, to preemptively address potential disputes from a related district court case, Petitioner addressed the term "level of smoke." Petitioner stated that the Patent Owner interpreted this term as merely detecting the presence of smoke, rather than quantifying an amount. Petitioner proceeded with its invalidity arguments under the Patent Owner's broader interpretation, reserving the right to contest this construction and argue indefiniteness in parallel litigation.

5. Relief Requested

• Petitioner requests institution of Post Grant Review and cancellation of claims 1-24 of the ’746 patent as unpatentable.