PTAB

IPR2018-00777

Lippert Components, Inc. v. Days Corporation

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1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Automatically Leveling a Vehicle
  • Brief Description: The ’693 patent describes a system for automatically leveling a vehicle, such as a recreational vehicle (RV), when it is stationary on uneven terrain. The system uses a microprocessor-based controller connected to multiple extendable legs and a level sensor that detects the vehicle's pitch and roll to adjust the legs until the vehicle is level.

3. Grounds for Unpatentability

Ground 1: Claims 12-13 are anticipated by Uriarte

  • Prior Art Relied Upon: Uriarte (Patent 5,143,386).
  • Core Argument for this Ground: Petitioner asserted that claims 12 and 13 are anticipated under 35 U.S.C. § 102 because Uriarte discloses every limitation, either explicitly or inherently.
    • Prior Art Mapping: Petitioner argued Uriarte discloses a complete automatic vehicle leveling system with a controller (CPU 282), multiple jacks (legs 20), and a proportional level sensor (205). A central contention was that although Uriarte’s sensor measures vehicle tilt along diagonal axes, it inherently "senses" the vehicle's pitch and roll, and its output signal "represents" this orientation, thereby meeting the claim language under the doctrine of inherency. Petitioner further contended that Uriarte’s leveling logic, which includes both extending jacks to raise the vehicle and retracting other jacks in a "reverse logic" sequence to level it, satisfies the claim requirement for the controller to move legs both upwardly and downwardly. For claim 13, Petitioner argued that Uriarte’s CPU, which has procedures for saving level sensor values to establish a "level state," constitutes the claimed memory for storing and replacing reference level plane data.

Ground 2: Claims 12-13 are obvious over Uriarte in view of Fukumoto

  • Prior Art Relied Upon: Uriarte (Patent 5,143,386), Fukumoto (Patent 5,580,095).
  • Core Argument for this Ground: As an alternative to Ground 1, Petitioner argued that claims 12 and 13 are obvious under §103. If the Board were to find that Uriarte’s diagonal-axis sensor does not teach the claimed sensor limitation, Fukumoto supplies the missing teaching.
    • Prior Art Mapping: Uriarte was asserted to provide the base leveling system. Fukumoto was cited for its explicit teaching of an inclination detector that measures tilt directly along the vehicle's primary front-to-rear (pitch) and left-to-right (roll) axes.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated to modify Uriarte's sensor alignment to match that of Fukumoto. Petitioner framed this as a simple substitution of one known sensor orientation for another to achieve the same function of leveling a vehicle, which is a predictable design choice.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success because the modification only involves reorienting the sensor and making corresponding, well-understood adjustments to the processing mathematics. This would be a predictable variation yielding a predictable result.

Ground 3: Claims 12-13 are obvious over Fukumoto in view of Uriarte

  • Prior Art Relied Upon: Fukumoto (Patent 5,580,095), Uriarte (Patent 5,143,386).
  • Core Argument for this Ground: Reversing the primary reference, Petitioner argued that Fukumoto discloses nearly all claim limitations, but that Uriarte supplies specific controller functionalities that are allegedly absent in Fukumoto.
    • Prior Art Mapping: Fukumoto was argued to provide the base system, including leveling legs, a controller, and a sensor for pitch and roll. However, Petitioner contended that Fukumoto does not explicitly teach a controller that (1) uses a leveling sequence involving both leg extension and retraction, or (2) includes a memory to store and overwrite a user-defined reference level plane. Uriarte’s controller (CPU 282) was cited as explicitly teaching both this "reverse logic" leveling sequence and the functionality to save new reference level data into its memory.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Uriarte’s more advanced controller logic into Fukumoto’s existing hardware. The stated benefits included implementing a faster leveling procedure, reducing wear on components, and adding the flexibility for a user to set a custom "level" state.
    • Expectation of Success: Petitioner argued that implementing Uriarte's known logic into Fukumoto's system—either by reprogramming Fukumoto's controller or by substituting it with a controller like Uriarte's—would be a predictable design variation. The result would be the simple combination of known prior art elements to achieve their expected functions.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for several terms, with the interpretation of the sensor-related limitations being central to its invalidity arguments.
  • For the phrase "to sense pitch and roll of the vehicle relative to a reference level plane", Petitioner argued this term does not require the level sensor to be physically aligned with the vehicle's direct pitch and roll axes. Rather, it contended the limitation is met as long as the sensor detects vehicle tilt in a way that is indicative of changes in pitch and roll. This construction was critical to Petitioner's argument that the diagonal-axis sensor taught in the Uriarte reference inherently anticipates this limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) on all asserted grounds and the cancellation of claims 12 and 13 of Patent 6,619,693 as unpatentable.