PTAB

IPR2014-00304

Johnson Controls Inc v. Wildcat Licensing Wi LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Assembly System for Monitoring Proper Fastening of an Article of Assembly at More than One Location
  • Brief Description: The ’573 patent discloses a "mistake-proofing" assembly system for articles like automotive seats. The system uses a sensor to detect the position of a fastening tool and an electronic controller to ensure fasteners are installed in a predetermined sequence and to a proper torque.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 24 over Gass and Sabatini

  • Prior Art Relied Upon: Gass (WO 00/17719) and Sabatini (a 2000 article from Automotive Manufacturing & Production).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gass disclosed all limitations of independent claim 24 except for a fixture holding the article of assembly. Gass taught a process system with a fastening tool (e.g., screwdriver), a sensor (imaging means), and an electronic controller that enforces a sequence of operations at different "process sites" or "bolting sites." The controller in Gass enables the tool only when it is at the correct site in the sequence and can provide an output display showing the process over time.
    • Motivation to Combine: Sabatini, an article directly related to the ’573 patent’s field of automotive seat assembly, explicitly disclosed the use of "poka-yoke fixtures" to hold seat components to ensure proper alignment and prevent assembly errors. A POSITA would combine the well-known fixture from Sabatini with the advanced control system of Gass to improve the reliability and efficiency of the assembly process. This represented a predictable combination of known elements for a known purpose.
    • Expectation of Success: Combining a standard fixture with a process control system was a well-known technique in manufacturing that would have yielded the predictable result of a more stable and accurate assembly operation.

Ground 2: Obviousness of Claim 25 over Gass, Sabatini, Admitted Prior Art, and Shingo

  • Prior Art Relied Upon: Gass (WO 00/17719), Sabatini (article), Admitted Prior Art (from the ’573 patent specification), Shingo I (1997 book on Zero Quality Control), and Shingo II (1986 book on Poka-yoke Systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Dependent claim 25 adds limitations related to an intermittent stop conveyor system, where a fixture is stopped at an assembly station and is released by the controller only after the fastening sequence is complete. Petitioner asserted that while Gass and Sabatini provided the base system of claim 24, the Admitted Prior Art in the ’573 patent itself acknowledged that modern assembly lines use fixtures on conveyors, including "intermittent stop and go" systems.
    • Motivation to Combine: Shingo I and Shingo II are seminal texts on "mistake-proofing" (poka-yoke) systems. They teach numerous examples of using sensors and controllers to interlock a process step with a physical stop; for example, releasing a part from a station only after a required operation (like installing the correct number of screws) is verified as complete. A POSITA would have been motivated to incorporate these well-known mistake-proofing techniques from Shingo into the Gass/Sabatini system to prevent defective assemblies from moving down the production line, thereby increasing efficiency and quality.
    • Expectation of Success: This was argued to be a simple application of a known quality control technique (interlocking a conveyor stop with process completion) to a known type of assembly system to achieve the predictable improvement of enhanced quality control.

Ground 3: Obviousness of Claim 24 over Wilhelm and Sabatini

  • Prior Art Relied Upon: Wilhelm (German Patent Publication No. 19609511) and Sabatini (article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Wilhelm as an alternative primary reference that taught the core invention. Wilhelm disclosed an auxiliary device for manually guided tools (e.g., an electric screwdriver) that uses a path detection device (sensor) to track the tool's position. A controller allows tool operation only at specific locations, with predetermined parameters (like torque), and in a "predetermined sequence of tool positionings," thereby ensuring processing occurs in the correct sequence.
    • Motivation to Combine: Similar to the argument in Ground 1, Wilhelm taught the core control and sequencing system but did not explicitly show a fixture. Sabatini provided the well-known element of a fixture used in the relevant industry. A POSITA would combine Sabatini's fixture with Wilhelm's control system for the same reasons as with Gass: to improve the stability and alignment of the workpiece during the controlled fastening process.
    • Expectation of Success: The combination was argued to be a predictable integration of a standard manufacturing component (a fixture) with a known type of process control system (Wilhelm's) to achieve a predictable benefit.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 24 and 25 based on combinations including Ri (a Japanese patent publication teaching alarm generation for process deviations) and further combinations of Gass and Wilhelm with the Admitted Prior Art and Shingo.

4. Key Claim Construction Positions

  • "fastening monitor indicating a fastening operation": Petitioner proposed this term should be construed as "the fastening tool includes a measuring device with the ability to measure parameters relating to the fastening operation, such as torque, run down speed, acceleration, or deceleration." This construction broadens the term beyond a simple indication that fastening occurred to include the measurement of specific parameters disclosed in the prior art.
  • "predetermined sequence program": Petitioner argued this phrase should be construed as "the electronic controller contains a program that requires that a fastening operation be performed at one of the first and second fastening locations only after a fastening operation is first performed at the other." This emphasizes the function of actively enforcing a specific order of operations.
  • "output indicating whether the predetermined sequence has been achieved": Petitioner proposed a broad construction wherein this "output" could simply be the enabling signal sent to the fastening tool that allows it to operate only at the correct location in the sequence. This interpretation was crucial for mapping prior art like Gass and Wilhelm, which use sequential enabling as the control mechanism, rather than a separate, final confirmation signal after all steps are completed.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 24 and 25 of Patent 6,763,573 as unpatentable.