PTAB

IPR2016-00873

HP Inc v. Memjet Technology Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Modular Printhead Assembly
  • Brief Description: The ’492 patent discloses a modular printhead assembly for a pagewidth inkjet printer. The invention is directed at using a plurality of replaceable printhead modules mounted on a metal alloy carrier, which allows for the construction of printheads of arbitrary width and enables the simple replacement of individual defective modules without scrapping the entire assembly.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cowger, Silverbrook 2172, and Matsufuji - Claims 6-8 are obvious over Cowger in view of Silverbrook 2172 and Matsufuji.

  • Prior Art Relied Upon: Cowger (Patent 5,565,900), Silverbrook 2172 (WO 01/02172), and Matsufuji (Patent 4,477,823).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cowger disclosed the fundamental elements of a modular, pagewidth printhead assembly as claimed in the ’492 patent, including a support carrier, a fluid transporter received in the carrier, and multiple printing modules mounted on the transporter. However, Petitioner contended Cowger did not explicitly teach making the carrier from a metal alloy or include a capping arrangement with a moving mechanism. Silverbrook 2172, which discloses an aluminum alloy support structure for printhead segments, was argued to supply the missing metal alloy carrier element. Matsufuji was argued to supply the remaining limitations, as it explicitly taught a capping arrangement with multiple caps and a moving arrangement (including supports and a camshaft) to engage and disengage the caps from the printheads.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine these references because they all address modular, pagewidth inkjet printers. A POSITA would have been motivated to use a metal alloy carrier, as taught by Silverbrook 2172, in Cowger’s design to improve rigidity, stiffness, and thermal distribution for a long pagewidth assembly. Furthermore, a POSITA would incorporate Matsufuji’s capping mechanism to solve the well-known problem of printhead nozzles drying out, clogging, or collecting dust, a common issue in the art.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these known elements, as it involved applying conventional capping technology to a known modular printer design and selecting a suitable material for its known properties.

Ground 2: Obviousness over Silverbrook 142, Silverbrook 2172, and Matsufuji - Claims 6-8 are obvious over Silverbrook 142 in view of Silverbrook 2172 and Matsufuji.

  • Prior Art Relied Upon: Silverbrook 142 (Patent 6,428,142), Silverbrook 2172 (WO 01/02172), and Matsufuji (Patent 4,477,823).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative primary reference. Petitioner argued Silverbrook 142 disclosed a modular printhead assembly with a "chassis" made of "punched, sheet metal" that functions as the claimed carrier, an ink reservoir that functions as the fluid transporter, and multiple replaceable printhead modules. To the extent the "metal" chassis was not considered a "metal alloy," Petitioner argued it would have been obvious to substitute the aluminum alloy carrier from Silverbrook 2172. Similar to Ground 1, Petitioner asserted that Silverbrook 142 lacked a capping or moving arrangement, and that these missing elements were supplied by Matsufuji, which taught a complete capping system with a camshaft-driven moving mechanism.
    • Motivation to Combine: The motivations were analogous to Ground 1. All references were in the same technical field. A POSITA would be motivated to improve the structural integrity of the Silverbrook 142 chassis by using a more rigid metal alloy as taught by Silverbrook 2172. A POSITA would also be motivated to add Matsufuji’s capping system to the Silverbrook 142 assembly to provide necessary protection for the printhead nozzles, a standard practice for improving printer reliability and longevity.
    • Expectation of Success: Petitioner contended there was a high expectation of success, as the combination merely integrated a known capping solution and an optimal material choice into an existing modular printer architecture.

4. Key Claim Construction Positions

  • "carrier": Petitioner proposed that the broadest reasonable interpretation of "carrier" is "support structure." This construction was argued to be consistent with the specification, which uses the terms interchangeably (e.g., describing a "metal channel" as a "support structure" that holds modules in place). This broader construction was important for mapping the term onto structures in the prior art like Cowger's "rigid body" and Silverbrook 142's "chassis".
  • "that can each transport a respective type of fluid": Petitioner argued this phrase, which modifies the "plurality of channels," should be given no patentable weight because it merely described an intended use of the apparatus rather than a structural limitation. Alternatively, if the Board found the phrase to be limiting, Petitioner proposed it should be construed broadly to mean "that can each transport any type of fluid," arguing the patent's own definition of "ink" includes any fluid and does not require different types or colors.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 6-8 of the ’492 patent as unpatentable under 35 U.S.C. §103.