PTAB

IPR2013-00383

Aisin Seiki Co Ltd v. American Vehicular Sciences LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Arrangement for Sensing Weight of an Occupying Item in a Vehicular Seat
  • Brief Description: The ’416 patent discloses a vehicle seat with an occupant sensor system. The system uses at least one force-sensing device attached to a support member of the seat to determine the weight of an occupying item.

3. Grounds for Unpatentability

Ground I: Anticipation of Claims 1 and 3-7 under 35 U.S.C. §102 over DE '074

  • Prior Art Relied Upon: DE 38 09 074 C2 ("DE '074'").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DE '074 discloses every limitation of claims 1 and 3-7. DE '074 teaches a vehicle seat system with guide rails fastened to the vehicle floor (the claimed "track") and runners (the claimed "support member") that are guided along the rails to adjust seat position. Petitioner contended that DE '074’s runners, which slide with respect to the track, constitute the claimed "slide mechanism." Furthermore, DE '074 discloses force sensors mounted on the runners to measure forces indicative of occupant weight, and a control circuit that uses this weight data to classify the occupant and control the deployment of a "collision protection cushion" (the claimed "airbag").

Ground III: Obviousness of Claims 1 and 3-7 under 35 U.S.C. §103 over DE '074 and Protze

  • Prior Art Relied Upon: DE '074 and Protze (Patent 4,285,545).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this ground as an alternative, asserting that if DE '074 were found not to explicitly disclose the claimed "slide mechanism," Protze remedied this deficiency. Protze discloses a conventional passenger seat with a support structure (legs) coupled to a slider that moves within tracks fastened to the vehicle floor. The combination of DE '074's sensor and control system with Protze's seat support and slide mechanism renders the claims obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Protze’s well-known slide mechanism with the system in DE '074 for the predictable and known purpose of allowing an occupant to adjust the seat for personal comfort. Implementing a standard sliding structure, as taught by Protze, into the seat system of DE '074 was a simple design choice.
    • Expectation of Success: A POSITA would have a high expectation of success in combining these references, as both pertain directly to vehicle seat structures and the integration of a standard mechanical sliding feature into an electronic sensor system would involve routine engineering.

Ground VII: Anticipation of Claims 1-7 under 35 U.S.C. §102 over JP '662

  • Prior Art Relied Upon: JP 9-150662 A ("JP '662'").

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that JP '662 anticipates all challenged claims, including claim 2’s specific requirement of a "strain gage." JP '662 discloses a strain gage attached to a bracket (support member) that is coupled to both the seat frame (bottom portion of the seat) and a movable upper rail (slide mechanism). This upper rail slides with respect to a lower rail (track) anchored to the vehicle floor. The system further includes an airbag circuit that classifies an occupant based on the computed total load from the strain gage and suppresses airbag deployment if the load is below a preset threshold, thus teaching the processor and control limitations of claims 4, 5, and 7.
  • Additional Grounds: Petitioner asserted additional challenges, including:

    • Obviousness challenges combining DE '074 with Kargol (Patent 5,707,035) to provide a more detailed slide mechanism.
    • An anticipation challenge against claims 1-3, 5, and 6 based on Mehney (Patent 6,039,344), which was previously considered by the Examiner.
    • Obviousness challenges combining Mehney with DE '074.
    • An obviousness challenge over DE '074, Protze, and Schousek (Patent 5,474,327) to add specific teachings on classifying a rearward-facing infant seat.

4. Key Claim Construction Positions

  • "slide mechanism": Petitioner argued that while the ’416 patent specification refers to a fixed track as a "slide mechanism," this is inconsistent with claim language requiring the mechanism to be "configured to slide with respect to the track." Petitioner contended the term should be construed to mean any structure that slides relative to the track, which is a common and well-understood configuration in the art.
  • "classification of the occupant": Petitioner submitted that the plain and ordinary meaning is a systematic arrangement of occupants into groups or categories according to established criteria, such as weight or position.

5. Key Technical Contentions (Beyond Claim Construction)

  • Effective Filing Date: Petitioner dedicated significant argument to contending that the challenged claims of the ’416 patent were not entitled to the priority date of the earliest parent application (filed June 7, 1995). Petitioner argued that the parent application failed to provide adequate written support for the limitation of "a support member coupled to the slide mechanism and to the bottom portion of the seat," because the supports it disclosed were located entirely within the seat structure itself, not between the seat bottom and the slide mechanism. Consequently, Petitioner argued the claims' effective filing date is November 17, 1998, which qualifies several key references, including Mehney, as prior art.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-7 of Patent 8,235,416 as unpatentable.