PTAB

IPR2018-00870

Intex Recreation Corp. v. Team Worldwide Corporation

Title: Inflatable Product With Built-In Housing and Switch Pipe
Brief Description: The ’394 patent relates to an inflatable product, such as an air mattress, featuring a built-in pump assembly. The assembly includes a uni-directional pump and a movable air conduit (a "switching pipe") that can be repositioned to switch between inflation and deflation modes without reversing the pump's motor.

Prior Art Relied Upon: Wu (Patent 6,698,046) and Chaffee (Patent 7,039,972).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Wu disclosed a uni-directional pump assembly for an air mattress that used a rotary valve (an "air conduit") to switch between inflation and deflation, satisfying most limitations of the challenged claims. However, Wu did not explicitly disclose containing its pump assembly within a housing or building that housing into the inflatable body. Chaffee, in contrast, taught an inflatable device with a recessed fluid controller built into the inflatable body within a housing that "surrounds the inner workings of the pump."
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Wu’s pump assembly with Chaffee’s built-in housing to achieve well-known and predictable benefits. These motivations included improved spatial efficiency, increased durability by protecting the pump components, enhanced user convenience by eliminating a separate pump, and reduced manufacturing and logistics costs. Petitioner contended this was a simple substitution of known elements to achieve a predictable result.
- Expectation of Success: A POSA would have a high expectation of success, as incorporating a pump into an inflatable product was a well-known design choice with predictable advantages.

Prior Art Relied Upon: Wu (Patent 6,698,046) and Goldsmith (Patent 2,493,067).
Core Argument for this Ground:
- Prior Art Mapping: This ground presented an argument parallel to Ground 1, with Wu again providing the core uni-directional pump assembly. Goldsmith was offered as an alternative prior art reference teaching the "built-in housing" limitation. Goldsmith disclosed a distribution casing (housing) containing a blower, which was "mounted or attached" to the wall of an inflatable mattress, including by rivets. Petitioner argued Goldsmith's housing was distinct from Chaffee's, which taught adhesion or heat sealing.
- Motivation to Combine: The motivations to combine were identical to those asserted in Ground 1, including improving durability, spatial efficiency, and user convenience. Goldsmith's purpose was to overcome problems that arise when a pump is separate from the inflatable body, providing a direct reason for a POSA to integrate Wu's pump into a housing and build it into the mattress.
- Expectation of Success: The combination was presented as a straightforward application of known engineering principles.

Prior Art Relied Upon: Wu (Patent 6,698,046) and Parienti (Patent 6,018,960).
Core Argument for this Ground:
- Prior Art Mapping: Similar to the previous grounds, this challenge used Wu for the core pump technology. Parienti was introduced as another alternative teaching for a built-in pump. Parienti disclosed a pump device made "interdependent with the mattress by means of gluing or any other means." The pump device itself included a housing containing the motor and turbine. This provided a third distinct teaching (gluing) for building a pump into an inflatable body.
- Motivation to Combine: Petitioner asserted the same motivations as in the other grounds, arguing a POSA would be driven by the known benefits of an integrated, compact, and durable design to combine the teachings of Wu and Parienti.
- Expectation of Success: A POSA would have recognized the combination as an obvious design modification using familiar elements to achieve a predictable result.
Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) based on the combination of Wu, Goldsmith, and Chaffee. This ground was presented as an alternative in the event the Board found that Wu alone did not disclose a "substantially airtight" inflatable body, with Chaffee providing the teaching for such a body.

"inflatable body": Petitioner argued for the broad construction "a structure that expands when filled with air or other gases." This position was taken to counter a district court construction in a related litigation that required the body to be "substantially airtight." Petitioner contended that the ’394 patent’s own figures show that the inflatable body must have an opening to accommodate the built-in pump, and that prior art cited during prosecution disclosed inflatable mattresses with micro-vents, both of which would contradict a "substantially airtight" requirement.
"fan": Petitioner proposed the construction "a device that alters air pressure through rotation." This was based on intrinsic evidence, including a parenthetical in the specification describing the fan as an "air pressure rotator," and supported by extrinsic dictionary definitions.
"pipe": Petitioner argued for the construction "a hollow body for conveying air or other gases." Petitioner asserted that the claims do not restrict the size or shape of the pipe and that its proposed construction was consistent with both the specification and extrinsic evidence.

Petitioner requested institution of an inter partes review and cancellation of claims 1-12 and 16-23 of Patent 7,246,394 as unpatentable.