PTAB

IPR2016-00364

Unified Patents Inc v. American Vehicular Sciences LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Airbag System
  • Brief Description: The ’093 patent relates to a vehicle safety system featuring a single, continuous airbag designed to extend along a lateral side of the vehicle to protect occupants in at least two different seating positions (e.g., front and rear seats). The invention is characterized by its use of a single gas-providing system with only one inflator to deploy the entire multi-occupant airbag.

3. Grounds for Unpatentability

Ground I: Obviousness over Leising in view of 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 discloses the core features of the claimed invention but fails to explicitly teach extending the airbag to protect rear-seat occupants. Leising teaches a side airbag system with curtain and torso portions that are integrally formed into a single airbag, inflated by a single gas source (inflator), and contain multiple compartments formed by restraining webs. However, Leising’s figures depict protection primarily for front-seat occupants. Petitioner contended that Lau remedies this deficiency by disclosing a side airbag assembly mounted on a center pillar to protect occupants in both front and rear seats, also using a single inflator. Petitioner asserted that Lau further teaches concealing the airbag behind "break away doors," satisfying the "cover" limitation of claim 1. By combining these references, Petitioner argued all limitations of independent claims 1, 26, and 36 are met. For example, Leising’s single-inflator, multi-compartment side airbag would be elongated to cover the rear seating positions as taught by Lau.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Leising and Lau because both references are in the same field of vehicle airbag safety and address the same problem of providing effective side impact protection. The primary motivation was to enhance vehicle safety by extending the known protection of Leising’s side curtain airbag to rear-seat occupants, a solution explicitly taught by Lau.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a high expectation of success because combining the teachings was straightforward. Modifying Leising’s airbag by elongating it as suggested by Lau was a predictable design choice that would have produced the expected result of providing side impact protection to both front and rear-seat occupants using a single, efficient system.

Ground II: Obviousness over Karlow in view of 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 similar argument to Ground I, substituting Karlow as the primary reference. Petitioner argued that Karlow discloses an "inflatable head restraint"—a single airbag for side impact protection that uses a single gas generator (inflator). The Karlow airbag consists of multiple inflatable "fingers" and a manifold, which collectively function as the claimed "plurality of compartments." Karlow also discloses stowing the airbag behind a "trim close-out panel," which satisfies the "cover" limitation. As with Leising, Karlow does not explicitly show protection extending to the rear seat. Petitioner again relied on Lau to provide the teaching of a single-inflator side airbag system that protects both front and rear occupants. The combination of Karlow's single-inflator, multi-compartment airbag with Lau's teaching of extending protection to the rear seat allegedly renders the challenged claims obvious.
    • Motivation to Combine: The motivation was identical to that in Ground I. A POSITA seeking to improve occupant safety would have been motivated to extend the protection of Karlow's side airbag to rear-seat passengers. Lau provided a known, simple, and effective method for achieving this goal within the same field of technology.
    • Expectation of Success: Petitioner contended that success in this combination would have been highly predictable. The modification involved elongating Karlow's airbag system and its mounting track, a simple mechanical adjustment, to achieve the expected and desired result of protecting rear-seat occupants from side impacts, as taught by Lau.

4. Key Claim Construction Positions

  • "single airbag": Petitioner proposed this term be interpreted to mean "an airbag that encloses an internal area, including a combination of front and rear airbags that are in flow communication with each other." This construction was asserted to be consistent with the specification and necessary to read the prior art's integrally formed but distinct airbag portions onto the claims.
  • "conduit": Petitioner proposed this term be interpreted to mean "a channel for conveying a fluid or liquid." This broad, ordinary meaning was used to argue that tubes and manifolds in the prior art satisfied this limitation.
  • "compartments": Petitioner proposed this term be interpreted to mean "individually defined spaces within the airbag." This construction allowed Petitioner to map the limitation onto prior art airbags that used restraining webs (Leising) or inflatable "fingers" (Karlow) to create distinct inflatable zones.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 8, 10, 12, 17-19, 26, 27, and 36 of the ’093 patent as unpatentable.