PTAB

IPR2017-00433

Arctic Cat Inc v. Polaris Industries Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: SIDE-BY-SIDE VEHICLE
  • Brief Description: The ’501 patent describes a side-by-side vehicle featuring specific configurations for its powertrain and air intake systems. The core of the challenged claims relates to an air intake system for cooling the vehicle’s continuously variable transmission (CVT), with an inlet located in an exterior body panel between the front and rear wheels.

3. Key Claim Construction Positions

  • Petitioner proposed constructions for several terms under the broadest reasonable interpretation (BRI) standard.
  • "coupled to" / "coupling": Argued to mean "connected directly or indirectly." This broad construction is central to Petitioner's argument that components described in the prior art meet the claimed coupling limitations even if they are not in direct physical contact.
  • "rearward of" / "forward of": Argued to mean "at least partially rearward of" and "at least partially forward of." Petitioner asserted this construction is necessary because the patent uses the term "completely" when a fully rearward or forward position is intended, implying "rearward of" alone is less restrictive.

4. Grounds for Unpatentability

Ground 1: Claims 1, 6-9 are obvious over Sunsdahl in view of Suzuki and Brown.

  • Prior Art Relied Upon: Sunsdahl (Application # 2008/0023249), Suzuki (Application # 2006/0270503), and Brown (Patent 4,681,178).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sunsdahl disclosed nearly all elements of independent claim 1, including a side-by-side vehicle with a CVT and an associated cooling air intake system. However, Sunsdahl’s intake was positioned between the driver and passenger seats. Petitioner contended that both Suzuki and Brown disclosed the common practice of placing air inlets on the exterior side body panels of vehicles to cool powertrain components. Specifically, Brown was cited for teaching an air inlet in the "rear quarter panel."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to relocate Sunsdahl’s centrally-located CVT air inlet to a side body panel, as taught by Suzuki and Brown. The motivations were to achieve predictable benefits, including: (1) reducing the likelihood of the inlet being blocked by passengers or cargo, thereby improving cooling efficiency; (2) reducing noise and vibration in the operator area by moving the inlet outward; and (3) reducing the potential for water ingestion during forward movement.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a high expectation of success because the combination involved merely applying a known technique (side-mounted inlet) to a known vehicle type (Sunsdahl's ATV) to obtain predictable, improved results.

Ground 2: Claims 10-12, 14-22 are obvious over Sunsdahl, Suzuki, and Brown, further in view of Ranger.

  • Prior Art Relied Upon: Sunsdahl, Suzuki, Brown, and Ranger (2007 Polaris Ranger Service Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims with additional limitations related to a second air intake system (for engine combustion), the specific location of the airbox, and the configuration of the rear suspension. While Sunsdahl disclosed a second air intake, Petitioner relied on Ranger to teach specific configurations not explicitly shown in the primary combination. Ranger was used to show that positioning an airbox so that its cover is rearward of its base, and positioning rear dampening members laterally outward of the airbox, were well-known and conventional design choices.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the teachings of Ranger to optimize the vehicle layout. For example, arranging the airbox as taught by Ranger would make the filter more accessible for maintenance. It was argued to be an ordinary design choice among a finite number of predictable options.

Ground 3: Claim 2 is obvious over Sunsdahl, Suzuki, and Brown, further in view of Chonan.

  • Prior Art Relied Upon: Sunsdahl, Suzuki, Brown, and Chonan (Patent 7,427,248).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claim 2, which requires the CVT unit to have a housing with a base and a cover, where the air inlet passes through an opening in an interior wall of the base portion. Petitioner argued Chonan explicitly taught this configuration.
    • Motivation to Combine: A POSITA would have been motivated to modify the CVT housing of the primary combination with the design from Chonan to gain known benefits. This design simplifies servicing, as the CVT cover could be removed to access internal components without needing to disconnect the entire air intake duct from the housing.

Ground 4: Claims 3-5 are obvious over Sunsdahl, Suzuki, Brown, Chonan, and Nallinger.

  • Prior Art Relied Upon: Sunsdahl, Suzuki, Brown, Chonan, and Nallinger (Patent 2,033,731).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring a protective "cover" with openings (e.g., gills or a screen) over the air inlet and a filter assembly behind it. Petitioner asserted Nallinger taught the use of a cover with "gill openings" over an air intake to supply combustion air, along with a filter positioned behind the openings.
    • Motivation to Combine: The motivation to add Nallinger's cover was to achieve the obvious benefit of protecting the air intake system and filter from damage or clogging by mud, branches, and other debris, a common concern for off-road vehicles. This was presented as the application of a known solution to a known problem.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-12 and 14-22 of the ’501 patent as unpatentable.