PTAB

IPR2017-01273

C&D Zodiac Inc v. B E Aerospace

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Aircraft Interior Lavatory
  • Brief Description: The ’476 patent describes an aircraft cabin enclosure, such as a lavatory, featuring a forward wall with a recess. This recess is contoured to substantially conform to the shape of the aft surface of an adjacent passenger seat, allowing the seat to be positioned further aft in the cabin to increase passenger density or space.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are obvious over Admitted Prior Art in view of Betts

  • Prior Art Relied Upon: Admitted Prior Art (APA) from the specification of the ’476 patent itself, and Betts (Patent 3,738,497).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the APA, as described in Figure 1 of the ’476 patent, discloses all elements of the challenged claims except for the recessed forward wall. The APA explicitly teaches a standard aircraft cabin with a passenger seat positioned immediately forward of a flat-walled lavatory. Betts, a patent from 1973, was argued to cure this deficiency by disclosing an aircraft coat closet with a contoured forward wall. This recess in Betts is specifically shaped to receive the aft surface of an adjacent passenger seatback, thereby creating more room for passengers. Petitioner contended that combining the standard lavatory of the APA with the known space-saving recessed wall from Betts rendered claims 1-6 obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of the APA and Betts for the clear and predictable purpose of increasing the efficient use of valuable cabin space. The primary goal of aircraft interior design has long been to maximize passenger capacity or comfort. Betts explicitly teaches its recessed wall design "provide[s] more room for passengers." Therefore, applying this known design solution from one type of aircraft enclosure (a closet) to another (a lavatory) to achieve the same well-understood benefit was presented as an obvious design choice.
    • Expectation of Success: A POSITA would have a high expectation of success. The combination involved applying a known mechanical feature (a recessed wall) to a known structure (a lavatory) to achieve a predictable result (increased space forward of the enclosure). No technological incompatibility or unpredictable outcome would prevent a designer from successfully implementing this combination.

Ground 2: Claims 1-6 are obvious over Admitted Prior Art in view of the KLM Crew Rest Document

  • Prior Art Relied Upon: Admitted Prior Art (APA) from the ’476 patent, and the KLM Crew Rest Document (a collection of design documents made publicly available through the file history of Patent 6,520,451).
  • Core Argument for this Ground:
    • Prior Art Mapping: As in the first ground, the APA was used to establish the baseline flat-walled lavatory configuration. The KLM Crew Rest Document was asserted to disclose a crew rest access area that was explicitly modeled on a "lavatory envelope." This structure featured a contoured forward wall with a recess designed to allow the adjacent row of passenger seats to be positioned further aft and still have room to recline. Petitioner argued that this document provides a direct analogue for the claimed invention, teaching the application of a recessed wall to a lavatory-like structure.
    • Motivation to Combine: The motivation was identical to that in Ground 1: the persistent drive in the airline industry to optimize cabin space. The KLM design directly addressed this need by contouring a wall to accommodate seating. A POSITA seeking to add seats or increase legroom would see the KLM design and recognize its applicability to other fixed enclosures, most notably the lavatory on which the KLM structure was already based. One of the KLM designers even testified that the contoured wall was the "logical way" to allow seats to be placed further aft.
    • Expectation of Success: Success would be highly expected and predictable. Because the KLM enclosure was already designed around a lavatory envelope, adapting its contoured wall feature to a standard lavatory would be a straightforward engineering task. The result—enabling a seat to be placed further aft—was the intended and predictable outcome of the modification.

4. Key Claim Construction Positions

  • Petitioner argued for a broad construction of the term "forward wall being substantially not flat and configured to receive a portion of the exterior aft surface of said seat back when the seat back is in an unreclined seat position."
  • This construction was proposed to be broad enough to encompass any forward wall with a recess or contour that allows a seat to be positioned further aft than if the wall were flat. Petitioner asserted this construction was necessary to cover the disclosures in prior art references like Betts and the KLM document, which show walls with recesses that achieve this space-saving function, thus making them relevant prior art for the obviousness analysis.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) of claims 1-6 of Patent 9,434,476 and requested the cancellation of all challenged claims as unpatentable under 35 U.S.C. §103.