PTAB

IPR2014-00755

Dyaco Intl Inc v. Johnson Health Tech Co Ltd

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Stationary Exercise Apparatus
  • Brief Description: The ’936 patent discloses a stationary elliptical exercise apparatus with a mechanism to vary the user’s pedal footpaths. The invention uses an adjustable guider and an elevating assembly to alter the incline angle of the path, thereby changing the exercise intensity.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rodgers and Maresh - Claims 1-11 are obvious over Rodgers in view of Maresh.

  • Prior Art Relied Upon: Rodgers (Patent 5,653,662) and Maresh (Patent 5,997,445).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rodgers discloses nearly all elements of the claimed stationary exercise apparatus. This includes a frame, supporting members with one end rotating about an axis and the other end reciprocating along a guider, pedals, and control links connecting the pedals to the supporting members. However, Rodgers taught a guider with a fixed incline. Petitioner asserted that Maresh remedies this deficiency by teaching an elliptical exercise apparatus with a guider whose incline is adjustable via a motorized, screw-driven actuator, which corresponds to the claimed "elevating assembly." Maresh’s actuator includes a screw rod, motor, and threaded tube pivotally connected between the frame and the guider. The combination of Rodgers’s linkage structure with Maresh’s adjustable guider mechanism allegedly discloses every element of the independent claims. Petitioner further argued that this combination inherently satisfies the functional limitations of the dependent claims, such as the differential stride length between a user's heel and toe when the incline is increased.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the teachings of Rodgers and Maresh to achieve a predictable result. The motivation was to add the known and desirable feature of incline adjustability, as taught by Maresh, to the exercise apparatus of Rodgers. This modification would allow a user to vary the exercise intensity, a well-understood goal in the field of fitness equipment. The combination represented a simple substitution of a known adjustable guider (Maresh) for a fixed one (Rodgers) to obtain the expected benefit of a more versatile workout.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these references. Both Rodgers and Maresh relate directly to elliptical exercise machines, and the integration of a known motorized actuator from Maresh to control the incline of a guider in an apparatus like Rodgers would be a straightforward application of conventional engineering principles without undue experimentation.

4. Key Claim Construction Positions

Petitioner proposed several constructions under the Broadest Reasonable Interpretation (BRI) standard, arguing they were necessary for a proper analysis of the prior art.

  • Correction of Claim Language: Petitioner argued that independent claims 1, 6, and 9 contain an error, omitting the word "links" in the clause reciting the "first and second control [links]." For the purpose of the IPR, Petitioner proposed construing the claims as if the word "links" were present.
  • "elevating assembly": Recited in claims 1-3, Petitioner argued this term should be construed to include the specific elements disclosed in the ’936 patent’s exemplary embodiment and recited in dependent claim 2: a screw rod pivotally connected to the frame, a motor coupled to the screw rod, and a tube threaded by the screw rod. This construction was critical, as Rodgers lacked this specific assembly, which Maresh provided.
  • "stride length... being greater... when the incline level of the guider is increased": Recited in claims 4 and 10, Petitioner construed this functional language to mean that the stride length of the user’s heel (the second closed loop path) increases more than the stride length of the user’s toe (the third closed loop path) as the guider’s incline increases.
  • "stride length... being longer...": Recited in claims 5 and 11, this phrase omits the "when the incline is increased" condition. Petitioner construed this as a "snapshot" condition where the heel's stride length is simply longer than the toe's stride length at a given incline, regardless of whether the incline is actively changing.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11 of the ’936 patent as unpatentable.