PTAB

IPR2014-00464

Mohawk Resources Ltd v. Vehicle Service Group LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Electronically Controlled Vehicle Lift and Vehicle Service System
  • Brief Description: The ’196 patent relates to vehicle lift systems comprising a moveable lift engagement structure to physically raise and lower a vehicle and an electronic control configured to manage the lifting operation and display various types of operational, maintenance, or service information to a user.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 39, 42, 44-51, 53, 55, 57-61, 63-65, 71, 76, 79, 84, 133-135, and 157 by Kogyo

  • Prior Art Relied Upon: Kogyo (Japanese Application # JP H8-333093).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kogyo, which discloses a vehicle maintenance lift, teaches every element of the challenged claims. For independent claim 39, Kogyo's "chassis bearing portion" and cylinder device constituted the claimed "moveable lift engagement structure." The claimed "electronic control" was met by Kogyo's combination of a data memory device, a diagnostic device with a CPU, and A/D converters, which collectively control the hydraulic unit for raising/lowering the lift and display lift data. Kogyo's system monitors various sensors (pressure, temperature, voltage) and displays this information, which Petitioner asserted constitutes the "lift data" required by the claims.
    • Key Aspects: Petitioner contended that Kogyo expressly teaches monitoring operational conditions, storing usage data (e.g., total hours), generating fault signals based on predetermined criteria (e.g., an "anomaly count" or "imbalanced load"), and displaying data indicative of a maintenance condition, thereby anticipating numerous dependent claims without modification.

Ground 2: Obviousness over Kogyo in view of de Bellefeuille - Claims 43, 68, and 70

  • Prior Art Relied Upon: Kogyo (Japanese Application # JP H8-333093) and de Bellefeuille (Patent 6,285,932).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kogyo taught the base vehicle lift system. De Bellefeuille, which discloses a "Computerized Automotive Service System," was used to supply limitations missing from Kogyo for specific dependent claims. For claim 43, de Bellefeuille taught the use of a "Menu mode" for user input, satisfying the "menu driven" limitation. For claim 68, de Bellefeuille taught that system sensors can communicate on an "internal shop network or Intranet," meeting the limitation of accessing another computer system through a network. For claim 70, de Bellefeuille's disclosure of data "dedicated to alignment procedures" was argued to be "service data," thus teaching the display of such data.
    • Motivation to Combine: A POSITA would combine Kogyo's lift system with de Bellefeuille's user interface and networking features to provide the user with easier navigation and ready access to a wider range of service and diagnostic information, a known goal in the field of automotive service equipment.
    • Expectation of Success: The combination involved applying conventional computer interface and networking technologies (menus, local networks) to a known type of electronically controlled mechanical lift. This integration was routine and predictable, presenting no technical hurdles that would undermine an expectation of success.

Ground 3: Obviousness over Kogyo in view of the SEFAC publication - Claims 56 and 77

  • Prior Art Relied Upon: Kogyo (Japanese Application # JP H8-333093) and the SEFAC publication (a 1991 user manual for a Mobile Electromechanical Lift).

  • Core Argument for this Ground:

    • Prior Art Mapping: For claim 56, which adds a "second user interface," Petitioner argued that the SEFAC publication taught a lift with both "main" and "secondary" control boxes, providing the second interface not explicitly shown in Kogyo. For claim 77, which recites a manual override feature to permit movement after a fault-based stop, the SEFAC publication taught a procedure to reinstate lift movement after a halt by using a "2-position reset switch" and turning the power to "on."
    • Motivation to Combine: A POSITA would be motivated to add a second user interface from SEFAC to Kogyo's lift for operator convenience, allowing control from different locations around the vehicle. Similarly, incorporating SEFAC's manual override feature into Kogyo's system was a common-sense addition to allow a vehicle to be removed from the lift for service after an automatic safety stop had been triggered.
    • Expectation of Success: Implementing a second control panel or a manual override switch on an electronically controlled lift were well-known design choices. A POSITA would have found it straightforward and predictable to add these features to Kogyo's system.

  • Additional Grounds: Petitioner asserted that, to the extent any elements were deemed missing from Kogyo for anticipation, all challenged claims would have been obvious over Kogyo in view of the general knowledge of a POSITA (Ground 2). Petitioner also asserted an alternative ground that independent claim 157 is obvious over Kogyo in view of Chu (German Application # DE 91 153 317), which explicitly teaches the "frame work" element of the claim (Ground 5).

4. Key Claim Construction Positions

  • Moveable Lift Engagement Structure: Petitioner proposed this term be construed as the "Vertically movable parts of a vehicle lift which engage a vehicle in a manner so as to move the vehicle vertically in either direction."
  • Electronic Control: Construed as "A system that: a) accepts electronic input signals...; b) processes them in the context of control logic; and c) outputs other electronic signals intended to effect physical state changes, in this case, to lift actuators."
  • Lift Data: Construed broadly as a "Plurality of information pertaining to the operation and control of the lift, including usage, operational fault, instructional, troubleshooting, and maintenance data." This broad construction was central to arguing that the sensor information disclosed in Kogyo met the claim limitation.
  • Service Data: Construed as "service information for a specific vehicle, such as service instructions, parts lists, service history, etc."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 39, 42-51, 53, 55-61, 63-65, 68, 70-71, 76-77, 79, 84, 133-135, and 157 of Patent 6,983,196 as unpatentable.