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ARTICLE · 13 OCTOBER 2014

No Motivation To Combine Where Combination Requires Complete Redesign

The patent at issue is directed to a system for providing an uninterrupted stream of stranded material such as yarn to a machine for subsequent processing.

United StatesIntellectual Property

Shaw Industries Group, Inc. v. Automated Creel Systems, Inc.

In a final written decision for two consolidated inter partes review (IPR) proceedings, the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB, the Board) ruled that some of the challenged claims were patentable and some were unpatentable, finding that two proposed reference combinations did not render obvious certain of the claims because a person having ordinary skill in the art would not have been motivated to combine the references.  Shaw Industries Group, Inc. v. Automated Creel Systems, Inc., Case Nos. IPR2013-00132 and IPR2013-00584 (PTAB, July 24, 2014) (Arbes, APJ). 

The patent at issue is directed to a system for providing an uninterrupted stream of stranded material such as yarn to a machine for subsequent processing.  Specifically, the patent describes a mechanism for providing a "pre-configured supply of materials, carried on movable carts, or cartridges" for loading onto

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