PTAB

IPR2014-01005

Hyundai Mobis Co Ltd v. Autoliv ASP Inc

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1. Case Identification

2. Patent Overview

  • Title: Airbag Cushion Module with Adaptive Venting
  • Brief Description: The ’450 patent discloses an airbag cushion module featuring a cinch tube and a cord designed to provide adaptive venting. During a normal deployment, the cord becomes taut, tightening the cinch tube to restrict gas venting; however, if deployment is obstructed by an out-of-position occupant, the cord remains slack, leaving the vent open to allow gas to escape for a softer inflation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Inoue and Narin - Claims 1, 2, 6, and 20 are obvious over Inoue in view of Narin.

  • Prior Art Relied Upon: Inoue (JP 5-85295) and Narin (DE 10059956).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the applicant effectively conceded during prosecution that Inoue taught all elements of the claimed airbag except for a "cinch tube." Inoue discloses an airbag with a drawstring-controlled vent that remains open to protect an out-of-position occupant but constricts upon full deployment. Petitioner asserted that Narin, which was not considered by the examiner, supplied the missing element by teaching a tubular fabric nozzle (a "cinch tube"). Critically, Narin's nozzle decouples the cinching function from the tension in the main airbag fabric, a feature the patentee relied upon to overcome Inoue during prosecution.
    • Motivation to Combine: A POSITA would combine Narin's cinch tube with Inoue's airbag system to solve a known and recognized problem. Narin explicitly teaches that its tubular nozzle makes closure of the vent easier by isolating it from the distension of the gas bag fabric. Furthermore, Petitioner noted that Inoue itself suggests its vent structure could be formed by sewing on a separate "bag-shaped item," for which Narin's tubular nozzle is a direct and suitable implementation.
    • Expectation of Success: The combination involved applying a known solution from Narin to a known problem in the Inoue system. This direct substitution of one known element for another to achieve predictable results would have provided a POSITA with a strong expectation of success.

Ground 2: Obviousness over Inoue and Nonaka and/or Riedinger - Claims 1, 2, 6, and 20 are obvious over Inoue in view of Nonaka and/or Riedinger.

  • Prior Art Relied Upon: Inoue (JP 5-85295), Nonaka (Patent 2,116,037), and Riedinger (DE 344591).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to Narin, Petitioner argued that Nonaka and Riedinger teach the required cinch tube element. Both references relate to parachutes and disclose adjustable tubular vents controlled by cinch cords to regulate air pressure. Petitioner contended that parachutes are analogous art because they are inflatable fabric structures facing the same technical problem of pressure regulation. The tubular vents in Nonaka and Riedinger permit constriction of the vent opening without necessitating closure of the base end, thereby decoupling the cinching action from tension in the main canopy fabric, just as claimed in the ’450 patent.
    • Motivation to Combine: A POSITA would have found it obvious to incorporate the well-established parachute vent designs of Nonaka or Riedinger into Inoue's airbag. Petitioner argued these references are "reasonably pertinent" as they address a central problem faced by the ’450 patentee: adjusting pressure inside a bag by closing a tubular vent without having to overcome tension at the base of the bag.
    • Expectation of Success: Given the structural similarities and shared technical challenges between parachutes and airbags, a POSITA would have reasonably expected that applying the pressure regulation techniques from Nonaka or Riedinger to an airbag would be successful.

Ground 3: Obviousness with Additional References for Symmetrical Venting - Claims 8, 9, 11, 12, 16, and 18 are obvious over Inoue and Narin (or Nonaka/Riedinger) in further view of Pinsenschaum or Wolanin.

  • Prior Art Relied Upon: Inoue, Narin (or Nonaka/Riedinger), and Pinsenschaum (Application # 2004/0012179) or Wolanin (Patent 5,280,953).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring a second cinch tube and a symmetrical vent arrangement. Petitioner argued that both Pinsenschaum and Wolanin explicitly teach airbags with two symmetrical vent openings controlled by tethers. The addition of a second, symmetrical vent to the base prior art combination was characterized as a "mere duplication of parts" to achieve a predictable, improved result.
    • Motivation to Combine: Petitioner asserted that the motivation to add a second vent was clear and even recognized by the patent examiner during the original prosecution. The use of symmetrical vents provides for more symmetrical deflation, which creates uniform internal pressure and reduces the risk of injury to an out-of-position occupant, regardless of their specific point of impact with the airbag.
    • Expectation of Success: Duplicating a known component to achieve a known benefit (i.e., symmetrical performance) is a routine design choice in the art that carries a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 4, 10, 14, and 19 based on the core combinations in further view of Rogerson (disclosing tearable tack stitches to maintain a vent opening) and Kassman or Tajima (disclosing an additional passive vent for enhanced safety).

4. Key Claim Construction Positions

  • Petitioner proposed constructions for several key terms that were added or became points of contention during prosecution to distinguish over prior art.
  • "Terminal End": Petitioner proposed construing this term as "the edge of the cinch tube farthest from the airbag cushion." It was argued this construction was necessary because the term is not defined in the specification and was added during prosecution, thus its meaning should be limited to what is depicted in the patent's figures.
  • "Without Necessitating Closure of the Base End of the Cinch Tube": This phrase was proposed to mean "with no closure of the base end of the cinch tube." Petitioner argued this limitation was also added during prosecution to overcome prior art, so its scope must be interpreted based on the patent figures, which consistently show the base end of the tube remaining open.
  • "Cinch Tube": Petitioner proposed a broad construction of "a fabric tube having open ends, one of which is cinchable, and having any shape sufficient to enable gas venting." This construction was based on language from the specification and was important for demonstrating that the structures in Narin, Nonaka, and Riedinger met the limitation.
  • Means-Plus-Function Terms (Claim 20): Petitioner argued the terms "means for venting gas out of the airbag" and "means for restricting gas venting" in claim 20 invoke 35 U.S.C. §112, ¶ 6. Based on the specification, Petitioner contended these should be construed as their corresponding structures: "cinch tube" and "cinch cord," respectively. This construction makes claim 20 substantively similar to claim 1, allowing the same prior art combinations to be applied.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 2, 4, 6, 8-12, 14, 16, and 18-20 of the ’450 patent as unpatentable under 35 U.S.C. §103.