PTAB

IPR2015-00208

Shinn Fu Co Of America Inc v. Tire HanGer Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Supporting Automotive Tires
  • Brief Description: The ’897 patent discloses methods for temporarily retaining a vehicle wheel to reduce physical strain on a mechanic. The method involves elevating a vehicle on a hoist and using a support arm attached to the hoist to hold a removed wheel at a convenient height, avoiding the need for the mechanic to bend over and place it on the floor.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 4 are anticipated by Heidle under 35 U.S.C. § 102

  • Prior Art Relied Upon: Heidle (Patent 5,813,659).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Heidle, which discloses a hoist apparatus for removing and installing a wheel, teaches every limitation of independent claim 1 and dependent claim 4. Petitioner asserted that Heidle's primary object is to allow a mechanic to "remove and replace a wheel upon a vehicle without having to lift the wheel to the floor or to the elevated vehicle." Heidle was alleged to teach elevating a vehicle on a hoist so a support arm is at wheel height, removing the wheel and placing it on the arm, and reversing the process to reinstall the wheel. The steps of removing the wheel from the vehicle and later from the support arm "substantially without bending over" were argued to be an inherent part of Heidle's disclosed process. For claim 4, Petitioner contended Heidle's support arm is installed on the hoist such that an individual does not have to bend significantly to guide the wheel over it.

Ground 2: Claims 3 and 5 are obvious over Heidle in view of AAPA and OSHA

  • Prior Art Relied Upon: Heidle (Patent 5,813,659), Applicant Admitted Prior Art (AAPA), and OSHA (OSHA Technical Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Heidle teaches the base method of claim 1. Dependent claim 3 adds the limitation that the support arm is installed at "about chest high to a person," and claim 5 adds that the support arm's height is "adjustable" and is adjusted to be "about chest high." Heidle discloses an adjustable support arm (via a strap 20 and adjustment clamp 36) installed on a vertical member of its hoist. The limitation not explicitly taught is setting the height specifically to "chest high."
    • Motivation to Combine: The ’897 patent’s own AAPA acknowledges that vehicles on lifts are typically elevated to about chest high and that bending while handling heavy tires was a known cause of injury. OSHA further teaches designing material handling tasks to minimize bending and awkward postures. A POSITA would combine these teachings with Heidle by simply adjusting Heidle’s support arm to chest height. This would be a predictable modification to achieve the known benefit of improved ergonomics and injury prevention by aligning the support arm with the wheel on the already-elevated vehicle.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved using Heidle’s existing adjustment features for their intended purpose in a well-understood ergonomic context to solve a known problem.

Ground 3: Claims 1-4 are obvious over Toyota in view of AAPA and OSHA

  • Prior Art Relied Upon: Toyota (JP Application No. H3-174596), AAPA, and OSHA.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Toyota, which discloses a tire hanger attached to a vehicle lift, explicitly teaches nearly every element of claims 1-4. Toyota shows elevating a vehicle, using a support arm at about the same height as the wheel, removing the wheel, and placing it on the support arm without putting it on the floor. Toyota's arm is also shown to be pivotable (claim 2), installed on a vertical member (claim 3), and positioned at chest height to prevent bending (claims 3-4). The only steps not explicitly detailed are "removing the wheel from the support arm" and "reinstalling the wheel onto the vehicle."
    • Motivation to Combine: Petitioner contended that reinstalling the wheel is an obvious and necessary completion of any vehicle service, such as the brake inspections mentioned in Toyota. The entire purpose of temporarily holding the wheel is to allow for its eventual reinstallation. A POSITA, motivated by the desire to complete the repair and by the ergonomic principles in AAPA and OSHA, would have found it obvious to remove the wheel from Toyota’s conveniently-located hanger and reinstall it on the vehicle. Performing this action without bending would be the natural result of Toyota’s chest-high placement.
    • Expectation of Success: Completing a vehicle repair by reinstalling the wheel is a routine and necessary step with a clear and predictable outcome, ensuring a high expectation of success for a POSITA implementing the complete method.

4. Key Claim Construction Positions

  • Method Step Sequence: Petitioner argued that unless a specific order is recited, the steps of a method claim, such as those in claim 1, are not required to be performed in the sequence they are written.
  • "the hanger": Petitioner proposed construing the term "the hanger" in claim 4 to mean "the support arm." This construction was based on claim 4's dependency on claim 1, which introduces the "support arm," and the functional context of guiding the wheel over the structure. Petitioner asserted this construction was necessary as "the hanger" otherwise lacked an antecedent basis.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-5 of Patent 6,681,897 as unpatentable.