PTAB

IPR2018-00714

Amazon.com Inc v. JumpSport Inc

Key Events

Petition

petition

Title: TRAMPOLINE OR THE LIKE WITH ENCLOSURE
Brief Description: The ’845 patent relates to a safety enclosure system for a trampoline. The invention comprises a frame, a rebounding mat, and a flexible wall structure supported by vertical poles to create a chamber above the mat, preventing users from falling off the trampoline.

Prior Art Relied Upon: Wu (Chinese Patent No. 2,195,352Y) and Heege (German Application No. DE 2052258 A1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Wu disclosed the fundamental elements of claim 1: a trampoline with a frame, a rebounding mat, and a safety enclosure supported by multiple independent poles. However, Wu’s design left hazardous gaps between the bottom of the safety net and the rebounding mat. Heege, which also taught a trampoline safety structure, disclosed directly coupling its "safety edge" to the "trampoline cloth" (the rebounding mat). The combination of Wu's pole-supported enclosure with Heege's direct mat attachment met the limitations of claim 1. Claim 17’s limitation of an "inelastic securing member" was argued to be an obvious design choice for this connection.
- Motivation to Combine: A POSITA would combine Heege's direct attachment method with Wu's enclosure to improve safety by eliminating the dangerous gaps present in Wu's design. Petitioner asserted that a POSITA would recognize this gap as a hazard, particularly for head and neck entrapment, a concern addressed by contemporaneous safety standards like ASTM F1148-95.
- Expectation of Success: The combination involved simple and predictable mechanical principles, providing a high expectation of success in creating a safer trampoline enclosure.

Prior Art Relied Upon: Wu, Heege, and Katzman (Patent 3,654,640).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed the additional limitations of claim 5, which required each enclosure pole to be secured to both a horizontally extending portion of the frame and one of the trampoline’s legs. The base combination of Wu and Heege provided the trampoline with the safety enclosure. Katzman, which the ’845 patent acknowledged as analogous art by relating trampolines to above-ground pools, disclosed a pool fence where vertical posts were secured to both the horizontal frame and the vertical leg supports.
- Motivation to Combine: A POSITA would modify the pole attachment of Wu by incorporating the sturdier mounting method taught by Katzman. In Wu, poles attached only to the legs, which could allow the legs to be pulled out from under the frame upon impact with the net, potentially causing a collapse. Attaching the poles to the frame as taught by Katzman would distribute impact forces more effectively, creating a more robust and safer structure.
- Expectation of Success: Applying a known, sturdier mounting technique from analogous pool-fencing art to a trampoline enclosure was a straightforward mechanical modification with predictable results.

Prior Art Relied Upon: Wu, Heege, and Owens (Patent 5,356,354).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed limitations related to specific safety features: an "end cap at the top of each pole" (claim 7) and "resilient sheaths around the poles" (claim 12). While Wu and Heege provided the base trampoline enclosure, Owens, which taught modular play equipment, disclosed using foam end caps and impact-attenuating foam sheaths on its structural posts to protect children from injury.
- Motivation to Combine: A POSITA would add the end caps and resilient sheaths from Owens to the poles of the Wu trampoline to enhance user safety. The motivation stemmed from the common goal of preventing injury from impacts with hard surfaces on playground equipment. Petitioner cited safety standards like ASTM F1148-95, which recommended capping open tubing ends, and ASTM F381-95, which recommended using "shock-attenuating protective devices" on applicable parts of a trampoline, including support poles.
- Expectation of Success: Adding common safety features like foam padding and caps to poles was a simple, well-understood practice in the field of recreational equipment, ensuring a reasonable expectation of success.

Prior Art Relied Upon: Wu, Heege, Katzman, and Rich (Patent 5,788,606).
Core Argument for this Ground:
- Prior Art Mapping: This ground challenged claim 8, which required using fasteners including at least one U-bolt to couple the poles to the legs and frame. The combination of Wu, Heege, and Katzman established the desirability of securing the poles to both the frame and legs. Rich, another trampoline patent, explicitly disclosed using U-bolts to connect support members to the trampoline frame.
- Motivation to Combine: A POSITA would use U-bolts, as taught by Rich, as the fastener for the pole connections established by the primary combination. U-bolts were argued to be a common, inexpensive, and readily available fastener for securing tubular components together. Their use would facilitate mass production and provide a simple, secure, and adjustable means of attachment.
- Expectation of Success: Using a standard fastener like a U-bolt for its intended purpose was a simple and highly predictable application of conventional technology.

Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 5, 7, 8, 12, 13, 15, and 17 of the ’845 patent as unpatentable.