PTAB

IPR2016-01074

Johnson Safety Inc v. Voxx Intl Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Display Device Having a Wireless Transmitter
  • Brief Description: The ’355 patent relates to a display device mounted to the rear of a vehicle seat or headrest. The device features an assembly housing with a face portion larger than a rear portion, allowing it to be installed substantially flush in a hole in the seat, and includes a wireless transmitter for supplying audio to passengers.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lavelle-365, Jost, and Chang - Claims 1, 2, 4, 10-12, 14, 18, 20, 26, 30, 32, 38, 39, and 42 are obvious over Lavelle-365 in view of Jost and Chang.

  • Prior Art Relied Upon: Lavelle-365 (Patent 6,899,365), Jost (Patent 6,883,870), and Chang (Patent 6,871,356).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lavelle-365 discloses a foundational in-seat entertainment system with a display housing mounted in a seat, an internal support structure, and wireless audio transmission. To meet all limitations, Petitioner combined it with Jost and Chang. Jost was cited to teach the specific claimed housing geometry, disclosing a monitor with an "oversized peripheral flange" (the face portion) larger than its inserted casing (the rear portion), which rests against the rim of an opening in a headrest. This maps to the claims requiring a larger face portion that rests outside a hole. Chang was cited to satisfy limitations requiring at least two media sources and, for certain claims, at least two wireless transmitters, disclosing a system that can connect to multiple external video sources and transmit audio to both a loudspeaker and a plurality of wireless headphones simultaneously.
    • Motivation to Combine: A POSITA would combine Lavelle-365 with Jost’s flange design for the known benefits of improving aesthetics and masking imperfections created when cutting a hole in the seat fabric. The integration of Chang’s multi-source, multi-listener capabilities was motivated by the well-understood market demand for providing passengers with individual entertainment choices, a common objective in the analogous art of vehicle entertainment systems.
    • Expectation of Success: Combining these known elements from analogous art—all directed to in-vehicle entertainment systems—would predictably result in the claimed invention without requiring undue experimentation.

Ground 2: Obviousness over LCM500NP and Lavelle-365 - Claims 1, 2, 4, 10-12, 14, 18, 20, 26, 30, 32, 38, 39, and 42 are obvious over LCM500NP in view of Lavelle-365.

  • Prior Art Relied Upon: LCM500NP (Audiovox Installation Manual, 2001) and Lavelle-365 (Patent 6,899,365).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the LCM500NP manual, for a commercially available Audiovox headrest monitor, discloses the core structural and functional limitations of the claims. The manual instructs users to cut a hole in a headrest and insert a clamshell housing, which has a face portion with a distinct lip larger than the rear portion that rests on the headrest's outer surface. It also teaches securing the housing to the headrest posts (an internal support structure) with tie straps or screws. The system's interconnection box explicitly provides for two video sources, and the monitor has built-in locations for two optional IR transmitters to support two-channel wireless headphones. For claims requiring a single transmitter to handle multiple media sources (claim 14), Lavelle-365 was added to supply this missing element.
    • Motivation to Combine: While LCM500NP teaches using two separate transmitters, a POSITA would have found it obvious to substitute a single multi-channel transmitter as taught by Lavelle-365. This modification would achieve the same result—transmitting audio from different sources to different listeners—in a potentially more integrated and cost-effective manner. It represented a simple substitution of one known element for another to obtain a predictable result.
    • Expectation of Success: A POSITA would have reasonably expected that replacing two separate single-channel transmitters with one dual-channel transmitter, a common component in the art, would function as intended to manage audio from multiple sources.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for several key terms that it argued were critical for its obviousness grounds:
    • "internal support structure": Proposed construction is "a support structure (disposed in whole or in part) within a seat." This aligns with the specification’s examples of vertical or horizontal support members.
    • "the face portion rests outside of the hole on an outside surface of the seat": Construed to mean "the sides and recessed portion of a hole are not part of the outside surface of the seat," clarifying that the display's lip rests on the primary, external seat surface.
    • "substantially flush with the outside surface of the seat": Petitioner argued this term, used in dependent claims, must be narrowly construed as "the face portion rests on the outside surface of the seat." Petitioner contended that because the independent claims already require the face portion to rest on and protrude from the seat surface, this is the only one of the patent's four broader definitions of "substantially flush" that does not improperly broaden the scope of the independent claim.

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner contended that the ’355 patent is not entitled to the October 27, 2000 filing date of its parent application, and thus its effective filing date is its actual filing date of August 26, 2004. The argument centered on the assertion that all independent claims of the ’355 patent recite new matter not disclosed in the parent application. Key new matter elements allegedly include the specific limitations for a "face portion" and "rear portion" with differing areas, the mounting of the rear portion "in a hole," and securing the device to an "internal support structure." This priority date argument was foundational to the petition, as it established that the asserted references were valid prior art.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 4, 10-12, 14, 18, 20, 26, 30, 32, 38, 39, and 42 of the ’355 patent as unpatentable under 35 U.S.C. §103.