PTAB

IPR2013-00380

Aisin Seiki Co Ltd v. American Vehicular Sciences LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Weight Measuring Systems and Methods for Vehicles
  • Brief Description: The ’048 patent discloses methods and systems for determining the weight of an occupant in a vehicle seat. The invention utilizes strain measuring transducers mounted on a support structure beneath the seat cushion to measure the strain caused by the occupant's weight, which is then used to calculate the weight for applications such as controlling airbag deployment.

3. Grounds for Unpatentability

Ground I: Anticipation by JP ’929 - Claims 1, 2, 8-10, and 13 are anticipated by JP ’929.

  • Prior Art Relied Upon: JP ’929 (Japanese Utility Model Publication No. JP 3-19929 U).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the claims of the ’048 patent were allowed during prosecution because the Examiner could not find prior art disclosing a strain measuring transducer mounted on a support structure "through which the force exerted by the occupying item...is transferred to the substrate." Petitioner argued that JP ’929 teaches this exact configuration. JP ’929 discloses a vehicle seat supported by sliding bodies, which in turn are supported by elastic bodies containing strain gauges. These elastic bodies are mounted on cases anchored to the vehicle floor via supporting members, creating a direct load path from the occupant, through the strain-gauged elastic bodies, to the vehicle floor (substrate). This structure directly reads on the limitations of independent claims 1 and 9.
    • Key Aspects: The core of this ground was that JP ’929, which was not considered during prosecution, directly remedies the specific deficiency in the prior art that led to the allowance of the ’048 patent claims.

Ground II: Obviousness over JP ’929 and Gentry - Claims 7, 12, 14, 15, 17, 19-21, 23, and 25 are obvious over JP ’929 in view of Gentry.

  • Prior Art Relied Upon: JP ’929 (JP 3-19929 U) and Gentry (Patent 5,573,269).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that JP ’929 discloses the foundational weight measuring system, as argued in Ground I. However, JP ’929 does not explicitly teach adjusting the weight determination based on the angular position of the seat back assembly, a limitation present in this set of challenged claims (e.g., claims 7 and 12). Gentry, which was cited by the Examiner during prosecution, expressly teaches using an incline sensor to determine the seat back inclination angle to improve the accuracy of the occupant's weight measurement.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings of Gentry with the system of JP ’929 for the simple and predictable purpose of improving the accuracy of the weight determination. Gentry explicitly states that the seat back angle affects the sensed weight, providing a clear reason to incorporate this known technique into the base system of JP ’929.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining a known angle-correction technique (from Gentry) with a standard weight-sensing platform (from JP ’929) involves applying a known method to a similar system to yield a predictable result.

Ground III: Anticipation by DE ’074 - Claim 9 is anticipated by DE ’074.

  • Prior Art Relied Upon: DE ’074 (German Patent No. DE 38 09 074 C2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DE ’074, which was also not of record, discloses all limitations of claim 9. DE ’074 teaches a vehicle seat support system comprising guide rails (a slide mechanism) fastened to the vehicle floor and runners that are connected to the seat. The runners act as support members and include force sensors (11, 12) mounted on them. This arrangement creates a force-sensing system interposed between the seat cushion and the substrate (floor), where the force from an occupant is transferred to the floor via the runners and guide rails. This structure directly maps to the elements of claim 9.
  • Additional Grounds: Petitioner asserted numerous additional grounds, including:
    • Obviousness challenges combining JP ’929 with Gentry and Steffens, Jr. (Patent 5,413,378) to add teachings on fore-aft seat position sensing.
    • Obviousness challenges based on DE ’074 in view of Patentee's Admitted Prior Art, JP ’929, and Gentry to cover various claim limitations.
    • Separate anticipation grounds against claim 3 by JP ’662 (JP 9-150662 A), Mehney (Patent 6,039,344), and Verma (Patent 5,942,695), each argued to be valid prior art based on the later effective filing date of claim 3.

4. Key Claim Construction Positions

  • "strain measuring": Petitioner proposed this term be construed as "assigning a value or number to a mechanical characteristic, and in particular the mechanical characteristic of a change in length per unit length."
  • "slide mechanism": Petitioner proposed this term be construed as "any structure, such as a track, that allows another structure to slide." These plain-and-ordinary-meaning constructions were asserted to be consistent with the specification and necessary for mapping the prior art.

5. Key Technical Contentions (Beyond Claim Construction)

  • Effective Filing Date of Claim 3: A central contention was that claim 3 is not entitled to the patent’s earliest priority date of June 7, 1995. Petitioner argued that the combination of "support members for coupling the seat to the slide mechanisms" and arranging a transducer "on at least one of the support members" was new matter first introduced in an application filed on November 17, 1998. This later effective date was critical for establishing that references like JP ’662, Mehney, and Verma, which were filed after 1995 but before November 1998, qualify as prior art under §102 against claim 3.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3 and 6-25 of the ’048 patent as unpatentable.