PTAB

IPR2015-01839

Douglas Dynamics LLC v. Meyer Products LLC

Key Events

Petition

petition

Title: Multiplex Light Harness
Brief Description: The ’829 patent discloses an auxiliary multiplex vehicle light harness that connects auxiliary lights to a vehicle's standard headlight system. The harness includes a processing module with a microprocessor to control the power supplied to both the vehicle's headlights and the auxiliary lights.

Prior Art Relied Upon: Knepel (Patent 5,420,480) and Moller (Patent 4,942,571).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Knepel, which discloses an "Automatic Headlamp Switching System" for vehicles with snowplows, teaches every limitation of independent claim 1 except for a "processing module including a microprocessor." Knepel's system uses electromechanical relays to switch between vehicle headlights and auxiliary plow lights. Petitioner contended that Moller, which describes an "On-Board Network For Motor Vehicles," explicitly teaches using microcontrollers and microprocessors to replace conventional relay circuits for controlling electrical devices, including lights.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because Moller expressly motivates replacing older, conventional relay circuits (as found in Knepel) with more advanced microprocessor-based controls. Petitioner asserted this was a well-known technological trend to improve functionality and flexibility in automotive electronics.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in making this substitution, as Moller teaches that simple microcontrollers are suitable for such controller devices, and the replacement of relays with programmable controllers was a common practice in the automotive industry.

Prior Art Relied Upon: Knepel (Patent 5,420,480), Moller (Patent 4,942,571), and Plyler (Patent 4,311,355).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds upon the combination of Knepel and Moller from Ground 1 to establish the core microprocessor-controlled lighting circuit. Petitioner argued that the dependent claims challenged in this ground add limitations related to specific connector features, such as sealing arrangements, which are not detailed in Knepel or Moller. Plyler, titled "Weatherproof Electrical Connector," discloses these specific features, including male and female connectors with flexible seals, locking arrangements, and housings designed for use in vehicles.
- Motivation to Combine: A POSITA would be motivated to incorporate the weatherproof connectors of Plyler into the lighting system of Knepel/Moller. Since the system is for external vehicle use (e.g., snowplows), protecting electrical connections from moisture and weather is a fundamental design consideration. Plyler directly addresses this known problem by providing robust, sealed connectors suitable for the automotive environment.

Prior Art Relied Upon: Rhodes (Patent 5,770,999).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rhodes, which discloses a "Vehicle Light Control System" for emergency vehicles, anticipates every element of the challenged claims. Rhodes describes a light circuit in a wiring harness that connects auxiliary "sneak lights" to a vehicle's headlight system. This system includes a processing module (blackout switch panel circuit 100) containing a microprocessor (M150) that controls power to both the standard headlights and the auxiliary lights. Petitioner mapped Rhodes's disclosure to each limitation of claim 1, including the headlight connector, power connector, auxiliary light connector, and the microprocessor-based processing module that controls light functions in on/off modes based on control signals from a switch.
Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 8, 32, and 33 over Knepel, Moller, Plyler, and UniMount 1997 (a commercial embodiment of Knepel); claims 4, 28, 36, and 43 over Rhodes in view of Moller; and claims 5, 29, 31, and 48-54 over Rhodes in view of Plyler.

"said processing module including a microprocessor": Petitioner argued that this phrase should be construed as "a control device such as a microcontroller that includes an integrated circuit for processing information." This construction was central to Petitioner's argument that the patent's sole distinguishing feature over prior art during prosecution—the microprocessor—was merely the implementation of a well-known, off-the-shelf component to replace older relay technology. Petitioner supported this construction by citing the prosecution history, where the applicant distinguished the invention from prior art that used simple solid-state switches, and by referencing technical manuals (e.g., Gould) showing that microprocessor-based controllers were known "brains" of a system designed to replace relays.

Petitioner requested institution of an inter partes review and cancellation of claims 1-2, 4-8, 28-33, 36, 38-39, 43-44, and 48-54 of the ’829 patent as unpatentable.