PTAB

IPR2016-00752

HP Inc v. Memjet Technology Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Inkjet Pagewidth Printer for High Volume Pagewidth Printing
  • Brief Description: The ’914 patent describes a high-volume pagewidth inkjet printer. The invention utilizes multiple, consecutively arranged printhead modules that span the width of a printing zone, a design intended to overcome the speed limitations and disadvantages of conventional printers that use traversing printheads.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 and 6 are anticipated under 35 U.S.C. §102 or obvious under 35 U.S.C. §103 over Silverbrook.

  • Prior Art Relied Upon: Silverbrook (WO 00/54973), which incorporates by reference PQ4559 (Australian Provisional Patent Application) and PQ5959 (Australian Provisional Patent Application).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Silverbrook, which discloses a pagewidth inkjet printer, teaches every limitation of the challenged claims. For independent claim 1, Silverbrook allegedly discloses a "support structure" (main printer housing supported on spaced legs), a "platen assembly" (full-width metal platen), and a complete "print assembly." This print assembly was argued to include a chassis, a plurality of printhead modules arranged end-to-end, each with a carrier, printhead chip, and flexible printed circuit board, and a media feed mechanism. Petitioner further contended that Silverbrook disclosed the dependent claim limitations, including the spaced feet and legs (claim 2), a media roll and take-up spool (claim 3), an ink distribution arrangement and reservoir (claim 4), and detachable printhead modules that permit replacement (claim 6).

Ground 2: Claim 7 is obvious over Silverbrook in view of Matsufuji.

  • Prior Art Relied Upon: Silverbrook (WO 00/54973), Matsufuji (Patent 4,477,823).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Silverbrook teaches all limitations of base claim 1, leaving only the additional limitations of claim 7 to be addressed. Claim 7 adds a "plurality of capping devices, associated with respective printhead modules, each capping device being mounted on the chassis and being displaceable" to cap the printhead chip. Petitioner argued Matsufuji teaches this exact feature, disclosing a capping assembly with a plurality of individual caps that are oscillated by a motor to engage and disengage the printhead modules.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references to improve the reliability of Silverbrook's printer. Both references are in the field of pagewidth inkjet printers and address reliability. Adding a known capping mechanism from Matsufuji to prevent ink nozzles from drying out in the Silverbrook printer was presented as a simple and predictable solution to a common problem.
    • Expectation of Success: The combination was alleged to be a straightforward integration of known components for their intended purposes, yielding predictable results.

Ground 3: Claims 1, 2, 4-6 are obvious over Yoshimura in view of Toganoh.

  • Prior Art Relied Upon: Yoshimura (Patent 4,692,778), Toganoh (Patent 4,559,543).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Yoshimura discloses the general structure of a pagewidth printer, including the support structure, a platen assembly for supporting a recording medium, and a paper feed mechanism, thus teaching the framework of claim 1. Toganoh was alleged to teach the specific modular printhead assembly required by the claim, disclosing a "plural number of ink jet device units" that can be arranged consecutively on a base plate. These units were argued to constitute the claimed "printhead modules," each comprising a carrier (head unit base plate), a printhead chip (ink jet head portion), and a flexible printed circuit board.
    • Motivation to Combine: A POSITA would combine Yoshimura and Toganoh as both references relate to pagewidth printers, were assigned to the same entity (Canon), and explicitly discuss the benefits of modularity. Petitioner argued it would have been obvious to incorporate Toganoh's improved, modular printhead design into the printer system of Yoshimura to enhance serviceability and facilitate the replacement of defective components.
    • Expectation of Success: Combining these complementary technologies—a printer framework and a modular printhead—was described as an application of known design principles that would predictably result in an improved, modular printer.

  • Additional Grounds: Petitioner asserted that claim 7 is obvious over the combination of Yoshimura, Toganoh, and Matsufuji, arguing that Matsufuji’s capping assembly could be readily integrated into the printer formed by combining Yoshimura and Toganoh.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention of the petition was that the ’914 patent was not entitled to its earliest claimed priority date of July 10, 1998, which stems from the ’767 application. Petitioner argued the ’767 application, which is directed to a specific ink jet nozzle structure, fails to provide adequate written description support for the broader system-level elements of claim 1 of the ’914 patent, such as the "print assembly," "platen assembly," and "chassis." Petitioner asserted the correct, earliest priority date is April 12, 2002. This argument was critical, as it rendered references published between 1998 and 2002, such as Silverbrook (published September 21, 2000), available as prior art against the challenged claims.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-7 of Patent 6,880,914 as unpatentable.