PTAB

IPR2017-01510

HENDRICKSON USA L.L.C. v. Trans Technologies Company

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1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Maintaining Air Pressure in Tires
  • Brief Description: The ’465 patent discloses an automatic tire inflation system for vehicles, particularly tractor-trailers. The system uses a rotary air chamber secured to a wheel's hub cap, which contains check valves to inject air when pressure drops below a preset value and relief valves to release air when pressure rises above a second preset value, thereby continuously maintaining proper tire pressure.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bland and Parker - Claims 1, 8-10, and 12-17 are obvious over Bland in combination with Parker.

  • 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 teaches a foundational trailer tire inflation system containing nearly all elements of independent claim 1, including a rotary air chamber (adapter 14) secured to a hub cap, check valves (ball bearings), an air pressure regulator, and an air line passing through the axle. However, Bland lacks the claimed relief valves for deflating the tires. Petitioner asserted that Parker, a patent from 1941, explicitly teaches the missing element: conventional relief valves located within a rotary air chamber specifically to "relieve the tires of air in case of over-inflation."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve the well-known benefits of maintaining proper tire pressure by both inflating and deflating, which improves safety, mileage, and tire wear. Petitioner contended that since Parker described its relief valves as being of "any well known construction," their application to a more modern system like Bland's would have been a predictable and simple solution to prevent tire over-inflation.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination involved integrating a standard, well-understood component (Parker's relief valve) into a known system (Bland's inflation apparatus) to achieve a predictable result. The modification was presented as a straightforward mechanical integration.

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

  • Prior Art Relied Upon: Stech (Patent 5,287,906) and Loewe (Patent 5,325,902).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stech discloses an air control system that meets the core limitations of claim 1, including a rotary air chamber (rotatable tee connection), conventional check valves, and an air line passing through the axle. Similar to the argument in Ground 1, Petitioner asserted Stech teaches inflation but lacks the claimed relief valve functionality for deflation. Loewe was presented to supply this missing element, as it explicitly teaches using conventional, adjustable relief valves in tire inflation systems to prevent over-inflation.
    • Motivation to Combine: The motivation was argued to be explicit in Loewe, which states that systems for automatically inflating and deflating tires are "well known" and that using relief valves is a suitable method for preventing over-inflation to achieve benefits like improved fuel economy, tire wear, and safety. A POSITA would be motivated to add Loewe's well-understood deflation feature to Stech's inflation system to create a more complete and effective pressure maintenance system.
    • Expectation of Success: Success would be highly expected because it involved adding a conventional component (Loewe's relief valve) to a known system to perform its ordinary, predictable function. Petitioner suggested a desirable location for this addition would be Stech's existing test valve stem.

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

  • Prior Art Relied Upon: White (Patent 7,273,082) and Schultz (Patent 4,678,017).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that White, a more contemporaneous reference invented by one of the Petitioners, discloses a modern tire inflation system with a rotary air chamber ("air tube assembly 36"), check valves, and an air line through the axle, but lacks the claimed relief valves. Schultz was introduced to teach the deflation function, describing relief valves used to decrease tire pressure to improve riding comfort and traction on soft or rough terrain.
    • Motivation to Combine: Schultz expressly teaches that it is "often desirable to decrease the tire pressure" for performance benefits and that this concept is "well known" for improving traction. A POSITA would combine Schultz's deflation capability with a modern inflation system like White's to provide a more versatile system that can adjust tire pressure for varying road conditions—a recognized need in the art.
    • Expectation of Success: Petitioner argued a POSITA would have had a clear expectation of success in combining the functionalities. Schultz teaches locating its valve assembly on a tire rim or hub, making its integration with White's hub-based system technically straightforward and predictable in its outcome.

4. Key Claim Construction Positions

  • Petitioner argued that several claim terms should be construed as means-plus-function limitations under §112, even without the explicit use of the word "means," and that these constructions were critical to the invalidity arguments.
  • "each check valve configured to inject air..." (claim 1): Petitioner asserted this is a functional limitation requiring construction as a means-plus-function element. The corresponding structure disclosed in the ’465 patent was argued to necessarily include not just a check valve, but also the air pressure regulator that sets the preset value and the rotary air chamber, as a valve alone cannot perform the entire claimed function.
  • "means for releasing air..." (claim 12): Petitioner contended the corresponding structure for this function must include a rotary air chamber attached to a hub cap and a conventional relief valve that recloses after relieving pressure, as this is the complete structure disclosed in the specification for performing the stated function.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 8-10, and 12-17 of Patent 7,669,465 as unpatentable.