PTAB

IPR2015-00609

Hopkins Mfg Corp v. Cequent Performance Products Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Brake Control Unit for Towed Vehicle
  • Brief Description: The ’993 patent discloses a brake control unit for a towed vehicle that includes a processor and an accelerometer. The system is designed to automatically acquire an "operating point"—a reference level from the accelerometer's output—when mounted in various orientations, eliminating the need for manual leveling or adjustment by an operator.

3. Grounds for Unpatentability

Ground 1: Anticipation over McGrath - Claims 1, 2, 9, 11, 14, 15, 22, and 24 are anticipated by McGrath

  • Prior Art Relied Upon: McGrath (Patent 5,620,236)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that McGrath discloses every element of the challenged claims. McGrath teaches an electronic brake controller with a microprocessor and a pendulum-based deceleration sensor (an accelerometer). Critically, McGrath discloses a "zeroing process" that automatically initiates when the microprocessor is energized or can be manually initiated. This process electronically reduces the bias voltage from the pendulum sensor to zero, compensating for the controller being mounted in a range of operating positions. Petitioner contended this "zeroing process" is equivalent to the ’993 patent's claimed feature of "automatically acquir[ing] an operating point of the brake control signal." McGrath also discloses a display for status information and mounting the sensor on a printed circuit board (PCB), anticipating various dependent claims.

Ground 2: Obviousness over McGrath in view of Robinson - Claims 5, 7, 18, 20, 27, 28, 31, 33, 35, and 37 are obvious over McGrath in view of Robinson

  • Prior Art Relied Upon: McGrath (Patent 5,620,236) and Robinson (Patent 6,837,551)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that McGrath provides the base brake controller system that automatically adjusts for mounting orientation, as detailed in Ground 1. Robinson was introduced to teach additional features recited in certain dependent claims. Specifically, Robinson discloses a method for determining whether a brake load is present by monitoring a status signal from the trailer's brake magnets and displaying this status on an LED. Robinson also discloses displaying the magnitude of the braking force via an LED display, which Petitioner argued makes it obvious to display the "output voltage" as claimed.
    • Motivation to Combine: A POSITA would combine McGrath and Robinson because both references are in the same field of electronic trailer brake controllers and address the common goal of providing accurate braking control and status feedback to the driver. Combining Robinson's known method for brake load detection and display with McGrath's self-calibrating controller would have been a predictable and logical improvement.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involves integrating known electronic sensing and display functions into a conventional brake controller architecture.

Ground 3: Obviousness over Robinson in view of Guzorek - Claims 4, 17, and 30 are obvious over Robinson in view of Guzorek

  • Prior Art Relied Upon: Robinson (Patent 6,837,551) and Guzorek (Patent 6,179,390)

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Robinson discloses the primary brake controller system, including a processor, a multi-axis accelerometer, and the capability to automatically determine a baseline acceleration (the "operating point") without needing to be leveled. The combination with Guzorek addresses the specific limitation of using a "dual seven-segment display." Guzorek explicitly teaches an electronic brake controller that uses a two-digit, seven-segment LED display to present various status and diagnostic information to the driver.
    • Motivation to Combine: A POSITA would combine these references as a matter of simple design choice. Both Robinson and Guzorek teach electronic brake controllers with displays. A designer seeking to implement the controller taught by Robinson would have looked to known display types in the art, such as the common dual seven-segment display taught by Guzorek, to convey information to the user. Substituting one known display type for another would have been an obvious and routine modification.
    • Expectation of Success: The integration would have been straightforward, as connecting a standard display component to a microprocessor-based controller was well within the ordinary skill in the art.

  • Additional Grounds: Petitioner asserted additional grounds, including that claims 1, 2, 5, 14, 15, 18, 27, 28, and 31 are anticipated by Robinson, and that claims 9, 22, and 35 are obvious over Robinson in view of Austin (Patent 5,333,948).

4. Key Claim Construction Positions

  • "operating point": Petitioner argued this term should be construed as "a value representing accelerometer output just prior to braking." This construction is based on the patent's own definition in the specification, which states the operating point is a reference level set by the accelerometer's output immediately prior to braking.
  • "mounted within a range of operating positions": Petitioner contended this phrase requires that the brake control unit can be mounted in multiple positions and remains operable. This construction is central to the argument that the prior art's auto-calibration or "zeroing" features, which allow for varied mounting orientations, meet this limitation.
  • "status and diagnostic information": Petitioner proposed this term refers to information on settings, braking parameters, and functional aspects of the controller. This includes brake output level (status) and warnings like shorted output or open ground (diagnostic), as described in the specification.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 2, 4, 5, 7, 9, 11, 14, 15, 17, 18, 20, 22, 24, 27, 28, 30, 31, 33, 35, and 37 of the ’993 patent as unpatentable.