PTAB

IPR2016-00364

Unified Patents Inc. v. American Vehicular Sciences LLC

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1. Case Identification

2. Patent Overview

  • Title: Vehicle Airbag System
  • Brief Description: The ’093 patent discloses a vehicle airbag system comprising a "single airbag" designed to extend across at least two longitudinally displaced seating positions, such as the front and rear seats. A key feature of the claimed invention is the use of a "single gas-providing system" with "only one inflator" to inflate the entire multi-position airbag upon deployment.

3. Grounds for Unpatentability

Ground I: Obviousness over Leising and Lau - Claims 1, 8, 10, 12, 17-19, 26, 27, and 36 are obvious over Leising in view of Lau.

  • Prior Art Relied Upon: Leising (Patent 3,897,961) and Lau (Patent 5,273,309).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Leising taught the core elements of the claimed invention, including a side airbag system with a single gas source, a single inflator, a conduit (tube 37) to deliver gas, and a "single airbag" with a plurality of compartments (formed by restraining webs). Leising’s airbag included integrally formed side curtain and torso portions. However, Petitioner acknowledged that Leising does not explicitly disclose its airbag extending to protect rear-seat occupants. To remedy this, Petitioner introduced Lau, which teaches an airbag assembly mounted on a center pillar to protect occupants in both front and rear seats using a single inflator. Petitioner asserted that Lau’s teaching of extending protection to the rear seat renders obvious the modification of Leising’s airbag to cover both front and rear seating positions. Further, Lau discloses concealing its airbag behind break-away doors, teaching the claimed "cover" element.
    • Motivation to Combine: A person of ordinary skill in the art (POSA) would combine Leising and Lau to address the common problem of providing effective side-impact protection for all vehicle occupants. The motivation to extend Leising’s side curtain to the rear seat was driven by the known desire to enhance the safety of back-seat occupants, an objective explicitly addressed by Lau.
    • Expectation of Success: A POSA would have a reasonable expectation of success in modifying Leising's system. The combination involved the predictable design choice of elongating Leising's side curtain airbag and its roof storage area, a straightforward modification to achieve the known benefit of rear-seat protection as taught by Lau.

Ground II: Obviousness over Karlow and Lau - Claims 1, 17-19, 26, 27, and 36 are obvious over Karlow in view of Lau.

  • Prior Art Relied Upon: Karlow (Patent 5,588,672) and Lau (Patent 5,273,309).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a parallel argument to Ground I, substituting Karlow as the primary reference. Petitioner argued that Karlow discloses an "inflatable head restraint" that constitutes a single airbag deployed during a side impact. Karlow's system uses a single gas generator (inflator) to inflate multiple "fingers" (the claimed compartments) via a manifold (the claimed conduit). The undeployed airbag is stored behind a "trim close-out panel" (the claimed cover). As with Leising, Karlow does not explicitly show protection extending to rear-seat occupants. Petitioner again relied on Lau to supply the teaching of extending side airbag protection to cover both front and rear seats.
    • Motivation to Combine: The motivation was identical to Ground I: improving vehicle safety by providing side-impact protection to rear-seat passengers. A POSA seeking to extend the protection of an airbag system like Karlow's would have been motivated to incorporate the multi-row protection concept taught by Lau.
    • Expectation of Success: A POSA would expect success in modifying Karlow's airbag to protect rear occupants by applying the teachings of Lau. Both references operate in the same technical field, and the proposed modification—extending the airbag and its mounting track along the side of the vehicle—was presented as a predictable combination of known elements to achieve an expected result.

4. Key Claim Construction Positions

  • Petitioner proposed the following constructions under the "broadest reasonable interpretation" standard, arguing they were consistent with the specification and ordinary meaning.
  • "single airbag": Petitioner argued this term should be interpreted to mean an airbag that encloses an internal area, including a combination of front and rear airbag portions that are in flow communication with each other. This construction is critical for asserting that prior art references teaching integrally formed or combined front and rear bags meet the limitation.
  • "conduit": Petitioner proposed this term should be interpreted to mean a channel for conveying a fluid or liquid. This broad construction allows various prior art structures, such as tubes (Leising) or manifolds (Karlow), to be mapped to this claim element.
  • "compartments": Petitioner proposed this term should be interpreted to mean individually defined spaces within the airbag. This construction supports mapping the term to features such as the areas between restraining webs in Leising or the "inflatable fingers" in Karlow.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 8, 10, 12, 17-19, 26, 27, and 36 of Patent 9,043,093 as unpatentable.