PTAB

IPR2014-00295

Continental Automotive Systems Inc v. Wasica Finance GmbH

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Device for Monitoring Air Pressure in Pneumatic Tires
  • Brief Description: The ’524 patent discloses a tire pressure monitoring system where transmitters mounted on vehicle wheels send pressure and identification signals to a receiver. The system features a "pairing mode," enabled by a switching device, which allows the receiver to learn and store identification signals from new or replacement transmitters as reference signals for subsequent operation.

3. Grounds for Unpatentability

Ground 1: Anticipation over Oselin

Claims 1, 2, 5, 6, 9-11, 13, 15, 18, 19, and 21 are anticipated by Oselin under 35 U.S.C. §102.

  • Prior Art Relied Upon: Oselin (Italian Patent No. 1,219,753).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Oselin discloses every limitation of the challenged claims. Oselin describes a tire pressure monitoring system with wheel-mounted transmitters that send coded signals, including transmitter identifiers (symbols S1-S4) and pseudorandom keys (symbols S5-S16), to a central receiver. Petitioner asserted that Oselin’s receiver includes a memory for storing these keys and a comparison unit (arithmetic-logic unit 201) to verify received signals against the stored keys, processing only valid messages. Crucially, Petitioner contended that Oselin’s disclosed "initial learning phase," activated by a pushbutton (200'), is the same as the ’524 patent’s claimed "pairing mode," as it enables the receiver to collect and store the unique keys from transmitters as reference signals.
    • Key Aspects: This ground asserted that the purported point of novelty of the ’524 patent—the switchable pairing mode—was fully disclosed in Oselin’s “learning phase.”

Ground 2: Obviousness over Williams in view of Heitschel

Claims 1-11, 13, 15, and 18-21 are obvious over Williams in view of Heitschel under 35 U.S.C. §103.

  • Prior Art Relied Upon: Williams (Patent 5,109,213) and Heitschel (Patent 4,750,118).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Williams, a tire pressure monitoring system, discloses the foundational components of claim 1, including a transmitter, receiver, display, and comparison device. The Examiner in the original prosecution found most claim limitations obvious over Williams. Petitioner contended that Heitschel, which describes a coding system for multiple garage door opener transmitters, supplies the remaining key limitations: a "program mode" and an enabling switch (switch 22). Heitschel’s program mode allows a receiver to learn and store a unique code from a specific transmitter in a designated memory location, which Petitioner argued is a direct analogue to the claimed "pairing mode" and "switching device."
    • Motivation to Combine: A POSITA would combine these references because Williams explicitly states that the electronics for its system are available in the electric-powered garage door industry. Faced with the need to pair new transmitters, a POSITA would have been motivated to incorporate the well-known "program mode" feature from an analogous system like Heitschel to add this functionality to the Williams system.
    • Expectation of Success: The combination involved applying a known technique (a program mode switch) from a related field (remote controllers) to a known system (a TPMS) to achieve a predictable result (pairing a new transmitter).

Ground 3: Obviousness over Oselin in view of Williams

Claims 3, 4, 7, 8, and 20 are obvious over Oselin in view of Williams under 35 U.S.C. §103.

  • Prior Art Relied Upon: Oselin (Italian Patent No. 1,219,753) and Williams (Patent 5,109,213).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claims whose limitations may not be explicitly disclosed in Oselin. Petitioner argued Williams teaches the missing elements. For instance, Williams discloses combining the emitter-control and signal-generating devices into a microprocessor controlled by stored memory (as required by claim 3). It also teaches containing the receiver's comparison device and memory in a single integrated chip for efficiency and cost reduction (as required by claim 4).
    • Motivation to Combine: A POSITA seeking to implement the system taught by Oselin would naturally look to contemporaneous art in the same field, like Williams, for conventional design choices. A POSITA would combine Williams's teachings on microprocessor control and integrated circuits with Oselin's system to improve its design and manufacturability.
    • Expectation of Success: Integrating microprocessors and creating integrated chips were standard, predictable practices in electronics design at the time, ensuring a high expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds based on Oselin in view of Schultz (Patent 5,083,457); Oselin in view of Barabino (Patent 4,067,376); Oselin and Schultz in view of Li (Patent 4,912,463); and various other combinations involving Williams, Heitschel, Schultz, Barabino, and Li.

4. Key Claim Construction Positions

Petitioner proposed constructions for several terms, arguing they should be given their plain and ordinary meaning. Key proposed constructions central to the invalidity arguments included:

  • "pairing mode" (claim 1): A mode of operation that allows an identification signal received directly from an associated transmitter to be processed and stored as an identification reference signal in the receiver.
  • "identification reference signal" (claim 1): Data capable of identifying a transmitter.
  • "switching device" (claim 1): Construed implicitly as the mechanism that enables the receiver to switch from a normal operating mode to the pairing mode.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’524 patent as unpatentable.