PTAB

IPR2017-01510

HenDRickSon USA LLC v. Trans Technologies Co

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Maintaining Air Pressure in Tires
  • Brief Description: The ’465 patent relates to an automatic tire inflation system for vehicles, particularly tractor-trailers. The invention describes a system that uses a rotary air chamber secured to a hub cap to both inject air into tires via check valves when pressure drops below a first preset value and release air via relief valves when pressure rises above a second preset value.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bland and Parker - Claims 1, 8-10, and 12-17 are obvious over Bland in view of Parker under 35 U.S.C. §103.

  • Prior Art Relied Upon: Bland (Patent 4,387,931) and Parker (Patent 2,317,636).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bland, a trailer tire inflation system, disclosed all elements of independent claim 1 except for the relief valves. Bland taught a system with a rotary air chamber (“adapter 14”) secured to a hub cap, check valves (ball bearings 104, 106) for inflation, an air shaft (“sleeve 81”), and an air line through the axle. Petitioner contended that Parker, a 1941 patent for a “Dual Tire Inflater,” supplied the missing relief valve element. Parker explicitly taught a system with both check valves for inflation and conventional relief valves to “relieve the tires of air in case of over-inflation.”
    • Motivation to Combine: Petitioner asserted that the benefits of systems that both inflate and deflate tires were pervasive in the art to maintain proper pressure for safety, mileage, and tire wear. Parker disclosed that its relief valves were of “any well known construction” and that its system could be used in various automotive vehicles, including trailers. A POSITA would combine Parker’s well-known deflation solution with Bland’s trailer inflation system to achieve the predictable benefit of preventing over-inflation.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success, as the combination involved integrating standard, well-understood mechanical components. It contended that Parker’s relief valves could be directly inserted into Bland’s system with simple tools.

Ground 2: Obviousness over Stech and Loewe - Claims 1, 8-10, and 12-17 are obvious over Stech in view of Loewe under §103.

  • Prior Art Relied Upon: Stech (Patent 5,287,906) and Loewe (Patent 5,325,902).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Stech taught an air control system with all limitations of claim 1 except for the relief valves. Stech’s system included a rotary air chamber (a rotatable “tee 54” connection), conventional check valves, an air shaft (“rotatable connection 40”), and an air line through the axle. Petitioner argued that Loewe supplied the missing teaching of relief valves, disclosing an automatic tire pressure monitoring and inflation system that used a “relief valve 82” on each tire to prevent over-inflation.
    • Motivation to Combine: Petitioner contended that Loewe provided an explicit motivation, stating that systems for automatically inflating and deflating tires were "well known" and that various relief valves were suitable for preventing over-inflation. Loewe also stated its system could be mounted on a wheel or hubcap. A POSITA would be motivated to add Loewe's conventional relief valve to an inflation system like Stech's to gain the well-known benefits of maintaining correct pressure, such as improved fuel economy and safety.
    • Expectation of Success: Petitioner argued for a high expectation of success, as the combination was a straightforward addition of a known element (a relief valve) to an existing system to achieve a predictable result (preventing over-inflation).

Ground 3: Obviousness over White and Schultz - Claims 1, 8-10, and 12-17 are obvious over White in view of Schultz under §103.

  • Prior Art Relied Upon: White (Patent 7,273,082) and Schultz (Patent 4,678,017).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that White, a more contemporary reference, disclosed all limitations of claim 1 except for the relief valves. White taught a rotary air chamber (“air tube assembly 36”) secured to a hub cap and check valves to inject air when pressure dropped below a target value. Petitioner asserted that Schultz, which taught a wheel end valve for a central tire inflation system, supplied the missing relief valve functionality.
    • Motivation to Combine: Petitioner argued Schultz provided strong motivation by teaching several advantages of releasing tire pressure, including improved riding comfort on rough roads and better traction on soft terrain. Schultz described a “deflate mode of operation” that would motivate a POSITA to incorporate its functionality into a modern inflation system like White's to gain these enhanced performance capabilities.
    • Expectation of Success: Petitioner asserted a high expectation of success because Schultz taught locating its valve assembly on a protected location like the tire rim or hub, making its integration with White's hub-mounted rotary air chamber a predictable and logical design choice.

4. Key Claim Construction Positions

Petitioner proposed constructions for several key terms, arguing they were critical to the invalidity analysis.

  • "rotary air chamber": Proposed as a structure that forms an enclosed space for air that rotates with the wheel.
  • "relief valve": Proposed as a pressure-responsive valve that opens to relieve pressure beyond a specified limit and recloses upon return to normal conditions.
  • "means for injecting air..." (claim 12.2): Argued this is a means-plus-function term requiring the structure of (1) a non-rotating air pressure regulator, (2) a rotary air chamber, and (3) a check valve responsive to the regulator’s pressure setting.
  • "means for releasing air..." (claim 12.3): Argued this is a means-plus-function term requiring the structure of (1) a rotary air chamber and (2) a relief valve that relieves pressure in response to tire pressure rising above a second adjustable preset value.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 8-10, and 12-17 of the ’465 patent as unpatentable.