IP Law Daily, PATENT—Fed. Cir.: PTAB’s rejection of automated kitchen system patent application affirmed on appeal, (Jun 11, 2026)

By Mandavi Singh, LL.M.

Substantial evidence supported the Board’s finding that a skilled artisan would have been motivated to combine prior-art references relating to automated food preparation systems.

In a non-precedential disposition, the U.S. Court of Appeals for the Federal Circuit has affirmed a Patent Trial and Appeal Board (PTAB) decision rejecting a patent application directed to an automated kitchen system, holding that substantial evidence supported the Board’s finding that a person of ordinary skill in the art would have been motivated to combine two prior-art references to arrive at the claimed invention. The court rejected the inventor’s arguments that the proposed combination contradicted the teachings of the prior art, would not function as intended, and violated the Administrative Procedure Act (APA) because the Board failed to address his arguments adequately (In Re Zhengxu He, No. 26-1177 (Fed. Cir. Jun. 9, 2026)).

Background. The appellant, Zhengxu He (Zhengxu), appealed a Patent Trial and Appeal Board decision affirming a patent examiner’s rejection of his U.S. Patent Application No. 16/997,933 (the ’933 application). The claimed invention was directed to an automated kitchen system for transporting ingredient containers between storage and cooking stations.

The patent examiner rejected claims 1–22 as obvious under 35 U.S.C. § 103. The examiner relied primarily on U.S. Patent Application Publication No. 2005/0193901 to Buehler, which disclosed an automated kitchen system containing ingredient storage modules, cooking receptacles, and robotic manipulators. For limitations not disclosed by Buehler, the examiner relied on U.S. Patent Application Publication No. 2014/0230660, another application by the same inventor (He ’660), which disclosed ingredient-cart unloading equipment and miniature vehicles that transported ingredient containers between storage and cooking stations. The examiner concluded that a skilled artisan would have been motivated to combine the references with a reasonable expectation of success. The PTAB affirmed, and Zhengxu appealed.

Motivation to combine. The principal issue on appeal was whether substantial evidence supported the Board’s finding that a skilled artisan would have been motivated to combine Buehler and He ’660. Zhengxu did not dispute that the combined references disclosed all elements of the claimed invention. Instead, he argued that the Board’s rationale for combining the references was unsupported because the automation-related benefits identified by the examiner did not apply to Buehler’s system.

The Federal Circuit disagreed. The court noted that He ’660 expressly described an automated system capable of delivering food ingredients dependably while minimizing space requirements, reducing idle time, and lowering labor costs. The examiner explained that incorporating He ’660’s miniature vehicles and unloading apparatus into Buehler’s automated kitchen system would automate ingredient transportation between storage and cooking stations without requiring the stations to be positioned in any particular configuration. The Board adopted that reasoning, and the Federal Circuit found that those findings constituted substantial evidence supporting the motivation-to-combine determination.

The court relied on In re Construction Equipment Co., 665 F.3d 1254 (Fed. Cir. 2011), which held that whether a skilled artisan would have been motivated to combine references is a question of fact reviewed for substantial evidence. Applying that standard, the court found no basis to disturb the Board’s factual findings.

Alleged contradiction. Zhengxu next argued that the examiner’s rationale improperly relied on He ’660’s ability to minimize space requirements even though Buehler disclosed storage and cooking modules positioned adjacent to one another as part of a compact kitchen unit. According to Zhengxu, He ’660 achieved its benefits only when storage and cooking stations were physically separated.

The Federal Circuit rejected that argument. The court explained that the Board reasonably found that the benefits disclosed in He ’660 were not limited to any particular physical arrangement of kitchen components. Although minimizing space was one of the benefits discussed in the reference, it was only one of several advantages identified by the examiner. The court concluded that substantial evidence supported the Board’s finding that the proposed combination would provide operational advantages without contradicting Buehler’s teachings.

Workability. Zhengxu also argued that the examiner’s proposed modification would not function properly because He ’660 employed engagement bars that allegedly would interfere with Buehler’s rotating storage shelves. The Federal Circuit rejected that contention as well.

Citing In re Keller, 642 F.2d 413 (C.C.P.A. 1981), the court emphasized that the obviousness inquiry does not require determining whether one reference can be physically incorporated into another. Instead, the relevant question is what the combined teachings of the references would have led a skilled artisan to conclude. The examiner found that a skilled artisan could attach engagement bars to Buehler’s ingredient containers without preventing the system's operation, and the Board agreed. The Federal Circuit concluded that Zhengxu failed to demonstrate that the proposed combination would have been uniquely difficult or technically infeasible.

APA challenge. Finally, Zhengxu argued that the Board violated the APA by failing to adequately address his arguments. The Federal Circuit disagreed, finding that the Board directly confronted both of his principal contentions, the alleged contradiction between the references and the alleged incompatibility of the proposed combination, and explained why it found them unpersuasive. Because the Board addressed the substance of the arguments and provided reasoned explanations for its conclusions, the court found no APA violation.

The Federal Circuit therefore affirmed the Board’s decision sustaining the examiner’s rejection of claims 1–22 of the ’933 application as obvious.

The Case is No. 26-1177.

Judge: Per Curiam.

Attorneys: Zhengxu He, pro se. Monica Barnes Lateef for the USPTO.

Cases: Patent FedCirNews