PTAB

IPR2017-01403

Miniature Precision Components Inc v. Eagle Industries Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Noise Abatement Engine Cover
  • Brief Description: The ’592 patent discloses a one-piece vehicle engine cover designed for improved aesthetics and noise abatement. The cover features a core of medium-density polyurethane and a textured, in-mold coated outer surface that is visible when installed in an engine compartment.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are anticipated by, or in the alternative obvious over, Polytec.

  • Prior Art Relied Upon: Polytec (International Publication No. WO 2008/055806).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Polytec, which was not considered during prosecution, teaches every element of claims 1-12. Polytec discloses a one-piece, sound-absorbing engine cover with a polyurethane foam core having a density of 90-180 kg/m³, which falls within the claimed "medium density" range of 80-208 kg/m³. Petitioner asserted that Polytec's "optically enhanced" outer surface, achieved via an in-mold coating (IMC), PU spray skin, or cast skin, meets the limitation of a "textured outer surface with an embedded protective coating." The coatings taught by Polytec are inherently denser than the foam core and are intended to be visible, satisfying further limitations of independent claims 1 and 9. For dependent claims, Petitioner contended that Polytec's teachings of in-molded apertures, protrusions for support, and an uncoated inner surface anticipate the claimed features.
    • Motivation to Combine (for obviousness alternative): For the alternative obviousness ground, Petitioner argued that a person of ordinary skill in the art (POSITA) would find it obvious to apply Polytec's teachings to create the claimed engine cover. For instance, if Polytec did not explicitly teach an uncoated inner surface, it would be an obvious design choice to save costs and maintain sound absorption properties by leaving a non-visible surface raw.
    • Expectation of Success (for obviousness alternative): A POSITA would have a high expectation of success as implementing the claimed features would involve applying known automotive manufacturing principles to the engine cover disclosed in Polytec.

Ground 2: Claims 13-19 are obvious over Polytec in view of Burr.

  • Prior Art Relied Upon: Polytec (WO 2008/055806) and Burr (Patent 3,487,134).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets the method claims. Petitioner asserted that while Polytec teaches a method for making the claimed engine cover, Burr supplies specific, well-known reaction injection molding (RIM) process details. Independent claim 13 recites a method including applying mold release to a tool with a "grained side" and then applying a coating. Petitioner argued Burr explicitly teaches using a mold release on an etched or embossed (i.e., grained) mold surface to impart a desired texture onto a foamed article. Polytec teaches using an IMC for an "optically enhanced" surface, and Burr teaches spray-applying a coating to the mold. The remaining method steps—dispensing high-temperature, medium-density foam, allowing it to expand and cure, and extracting the part—were argued to be inherent to the RIM process disclosed in Polytec or explicitly taught by Burr as standard practice.
    • Motivation to Combine: A POSITA would combine Polytec and Burr because both are in the field of manufacturing foamed automotive parts. A POSITA seeking to produce the aesthetically-pleasing engine cover of Polytec would look to conventional and well-established RIM techniques, such as those detailed in Burr, to implement the manufacturing process. Using Burr’s teachings on grained tools and mold release would be a logical way to achieve the "optically enhanced" and "textured" surface described by Polytec, leading to predictable improvements in appearance and manufacturing efficiency.
    • Expectation of Success: A POSITA would have a high expectation of success in combining the references because it involves applying standard, predictable RIM process steps (Burr) to manufacture a specific type of product (Polytec). The combination would yield the expected result of a textured, coated foam part without undue experimentation.

4. Key Claim Construction Positions

  • "medium density polyurethane": Petitioner proposed this term be construed as "a polyurethane foam having a density in the range of 5-13 PCF (80-208 kg/m³)," based on the patent's specification. This construction was critical to show that the density range disclosed in Polytec (90-180 kg/m³) falls squarely within the claimed range.
  • "textured": Petitioner proposed a broad construction of "visual or tactile surface characteristics," arguing that the patent owner defined it during prosecution as any surface with "show-quality aesthetics." This construction allowed Petitioner to argue that Polytec’s "optically enhanced" surface, achieved with a high-quality coating, met the limitation.
  • "high temperature polyurethane": Petitioner argued this term means "polyurethane sufficient to withstand temperatures in an engine compartment." This functional definition was used to assert that Polytec’s engine cover, intended for use in an engine compartment, is necessarily made of such a material.
  • "embedded" protective coating: Petitioner proposed this term means "incorporated and firmly fixed," consistent with its plain meaning and the in-mold coating process described in the specification.