PTAB

IPR2014-01006

Hyundai Mobis Co Ltd v. Autoliv ASP Inc

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1. Case Identification

2. Patent Overview

  • Title: Airbag Module with Occupant Position Responsive Venting
  • Brief Description: The ’653 patent discloses an airbag module with a cushion, one or more closeable vents, and a cord. The cord connects the vent to the cushion, such that upon full inflation for a normally positioned occupant, the cord becomes taut and closes the vent. For an obstructed inflation involving an out-of-position occupant, the cord remains slack, allowing the vent to stay open and release gas.

3. Grounds for Unpatentability

Ground 1: Obviousness over Inoue in view of Pinsenschaum and/or Wolanin

  • Claims Challenged: 1-3, 5-9, 11-13, 15-17, 20-22, 24-25, 28-30, and 32 are obvious over Inoue in view of Pinsenschaum and/or Wolanin.
  • Prior Art Relied Upon: Inoue (JP 5-85295), Pinsenschaum (Application # 2004/0012179), and Wolanin (Patent 5,280,953).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Inoue taught the core concept of the ’653 patent: an airbag with a single closeable vent operated by a drawstring (cord) that responds to occupant position. The drawstring remains slack and the vent open for an out-of-position (OOP) occupant but tightens to close the vent upon full, unobstructed inflation. Petitioner asserted that Pinsenschaum and Wolanin both explicitly taught airbag assemblies with two closeable vents and tethers, meeting the dual-vent limitation of claim 1. Furthermore, both Pinsenschaum and Wolanin disclosed using break-away seams or rupturable stitches to hold folded portions of the airbag or vent covers, which directly correspond to the claimed "releasable temporary holding feature."
    • Motivation to Combine: A POSITA would combine these references as they all address the same problem of controlling airbag venting for occupant safety. A POSITA would have found it obvious to modify Inoue’s single-vent system to include two vents as taught by Pinsenschaum and Wolanin for known benefits like symmetrical deflation. Similarly, it would have been a predictable design choice to incorporate the break-away stitches from Pinsenschaum or Wolanin into Inoue’s folded airbag to implement the claimed temporary holding feature.

Ground 2: Obviousness over Inoue, Pinsenschaum/Wolanin, and Prescaro/Seymour

  • Claims Challenged: 1-3, 5, 9, 11-13, 15-17, 20-22, 24-25, 28-30, and 32 are obvious over Inoue in view of Pinsenschaum and/or Wolanin, further in view of Prescaro or Seymour.
  • Prior Art Relied Upon: Inoue (JP 5-85295), Pinsenschaum (Application # 2004/0012179), Wolanin (Patent 5,280,953), Prescaro (Patent 5,242,192), and Seymour (Patent 5,772,239).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative based on a potentially broad construction of "releasable temporary holding feature" to include a separate airbag cover. Petitioner argued that Prescaro and Seymour demonstrated that tack-stitched covers for folded airbag cushions were well-known. Prescaro disclosed a cover joined by "rupturable fastener means" to shield the airbag during shipping, and Seymour disclosed a fabric envelope with a "weak stitch pattern" (tear seam) holding the folded airbag. These structures, Petitioner contended, meet the functional limitations of the holding feature.
    • Motivation to Combine: A POSITA would combine Prescaro or Seymour with the primary combination for practical and known benefits. The references explicitly state that such covers shield the module during shipping and storage and can protect the vehicle dashboard, which directly relates to the claimed function of preventing vent closure during handling. Adding such a known cover to the airbag of Inoue/Pinsenschaum would have been a predictable and obvious improvement.

Ground 3: Obviousness over Inoue, Pinsenschaum/Wolanin, and Tajima

  • Claims Challenged: 18, 19, 26, 27, 33-37, 39, and 40 are obvious over Inoue in view of Pinsenschaum and/or Wolanin, further in view of Tajima.
  • Prior Art Relied Upon: Inoue (JP 5-85295), Pinsenschaum (Application # 2004/0012179), Wolanin (Patent 5,280,953), and Tajima (JP 2003-137060).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims reciting a "diffuser" and/or a "fixed vent." Petitioner argued that Tajima explicitly taught an airbag containing both a closeable vent and fixed side vents, as well as a "diffuser" (termed a "rectifying fabric") for redirecting inflation gas towards the vents. This disclosure directly taught the additional limitations present in this set of challenged claims.
    • Motivation to Combine: A POSITA would combine Tajima's features with the base airbag system of Inoue/Pinsenschaum/Wolanin to optimize performance. Adding fixed vents is a common method for passive venting, and using a diffuser to direct gas flow is a known technique for controlling inflation dynamics. Combining these known elements from Tajima with the occupant-sensing vent system of the primary references would have been an obvious path to an improved airbag system with predictable results.

4. Key Claim Construction Positions

  • "A Releasable Temporary Holding Feature": Petitioner argued this term, despite lacking the word "means," should be construed as a means-plus-function limitation under 35 U.S.C. §112, ¶ 6. Petitioner contended "feature" is a generic, non-structural term used as a substitute for "means," with the function of holding a fold in place. The corresponding structures disclosed in the ’653 patent are a tack stitch, fastener, adhesive, clip, knot, or hook and loop fastener. This construction was critical for mapping the claim to the specific break-away seams and stitches taught in the prior art.
  • "A Location Corresponding With A Base Of The Fold": Petitioner proposed this term should be construed as "a location corresponding with the bend of the fold." This construction relied on the plain meaning of "base" and "fold" and was crucial for demonstrating that Inoue taught the claimed anchoring position of the cord at the bend of a fold in the airbag.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 5-9, 11-13, 15-22, 24-30, 32-37, 39, and 40 of the ’653 patent as unpatentable under 35 U.S.C. §103.