PTAB

IPR2014-00754

Dyaco Intl Inc v. Johnson Health Tech Co Ltd

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Stationary Exercise Apparatus
  • Brief Description: The ’815 patent discloses a stationary exercise apparatus, such as an elliptical trainer, featuring a "guider assembly" that allows pedals to move in various closed-loop paths. The invention aims to provide users with an inclined foot path, variable stride length, and high-intensity exercise by using an adjustable guider mechanism and a shroud to cover moving parts.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 are obvious over Jang in view of Chen and further in view of Flick.

  • Prior Art Relied Upon: Jang (Taiwan Patent No. M273359), Chen (Application # 2005/0003932), and Flick (Application # 2006/0035757).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Jang, Chen, and Flick disclosed every limitation of the challenged claims. Jang was asserted as the primary reference, disclosing the foundational stationary elliptical exerciser. This included a frame, supporting members with pedals, and an adjustable guider assembly (baseplate with rails) that could be inclined using an elevating motor to vary the exercise path. Petitioner contended Jang taught nearly all claimed elements but lacked a guider assembly operatively engaged with a rear portion of a base frame and a shroud covering the adjustment mechanism. To remedy this, Chen was introduced to teach a guider assembly (two rails) pivotally connected to the back end of a base frame, with an adjustment mechanism (lifting devices) mounted between the rails and the frame. This configuration provided a stable, frame-based adjustment system. Finally, Flick was introduced to supply the claimed shroud, teaching that shrouds are conventionally used on exercise equipment to cover elevation motors for aesthetic and protective purposes, and that such shrouds are connected to and move with the structural elements they cover.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Jang and Chen to improve the stability and predictability of the incline adjustment mechanism. The adjustment mechanism in Jang relied on the floor for support, which could be uneven and cause inconsistent operation. A POSITA would have looked to solutions like that in Chen, which used a dedicated frame element as a known, stable surface for the adjustment mechanism, yielding the predictable result of more reliable operation. A POSITA would then be motivated to add the shroud taught by Flick to the combined Jang/Chen apparatus to gain the well-known benefits of an improved aesthetic appearance, protection of internal components from dust and debris, and user safety from moving parts.
    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in making this combination. Each reference operated according to known mechanical principles, and combining them simply involved applying a known component (Chen’s frame-based support) to an existing device (Jang’s elliptical) and adding a conventional feature (Flick’s shroud) for its intended purpose. The combination would have yielded only predictable results.

4. Key Claim Construction Positions

Petitioner argued that several terms required construction under the broadest reasonable interpretation standard to properly assess the prior art.

  • “operatively engaged”: Proposed as a general descriptive term indicating a functional relationship between claimed elements, rather than a specific structural connection. This construction was argued to be consistent with its use during the patent's prosecution.
  • “adjusting assembly”: Argued to encompass, at a minimum, a motor, a screw rod, and a screw tube assembly, as these components were described in the patent’s examples. This construction ensures the term covers the core mechanism disclosed for adjusting the guider.
  • “moving member”: Construed as a structural element that moves relative to the frame and is connected between the adjusting assembly and the guider. Petitioner noted the patent and claims were inconsistent as to whether the moving member was part of, or merely joined to, the adjusting assembly, and argued the construction should encompass both arrangements.
  • “a guider assembly” or “a guider”: Petitioner argued these terms were used interchangeably in the patent and should be construed to mean the same thing: a structural element that moves relative to the frame and directs the movement of the pedals.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-18 of the ’815 patent as unpatentable under 35 U.S.C. §103.