PTAB

IPR2018-00870

Intex Recreation Corp v. Team Worldwide Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Inflatable Product With Built-In Housing And Switch Pipe
  • Brief Description: The ’394 patent describes an inflatable product, such as an air mattress, featuring a built-in, uni-directional air pump assembly. The assembly uses a movable air conduit, such as a rotatable pipe, to switch between inflation and deflation modes without reversing the pump's motor direction.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wu and Chaffee - Claims 1-12 and 16-23 are obvious over Wu in view of Chaffee.

  • 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 meets most of the challenged claim limitations, including a motorized fan and a movable, rotatable air conduit (a rotary valve) for switching between inflation and deflation. However, Wu’s pump components were not disclosed as being contained within a housing that is built into the inflatable body. Chaffee allegedly supplied this missing element by teaching an inflatable device with a recessed fluid controller, where the pump is contained within a housing that is built into the inflatable body (e.g., via adhesive or heat seal).
    • Motivation to Combine: A POSITA would combine Wu’s pump system with Chaffee’s built-in housing design to achieve well-known and predictable benefits. These benefits included improved spatial efficiency, increased durability by protecting the pump components, enhanced user convenience by eliminating a separate external pump, and reduced manufacturing and logistics costs.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination, as it involved integrating a known pump system into a known built-in housing configuration, both of which were established in the field of inflatable products.

Ground 2: Obviousness over Wu and Goldsmith - Claims 1-12 and 16-23 are obvious over Wu in view of Goldsmith.

  • 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 a similar argument to Ground 1, with Wu again providing the core uni-directional pump assembly. Goldsmith was asserted to teach the missing limitations of a pump contained within a housing that is built into an inflatable body. Petitioner contended that Goldsmith disclosed an "air distributing chamber" (housing) containing a fan and motor that is "mounted or attached to the mattress" via rivets or other suitable means, teaching the integration of the pump mechanism within the inflatable product.
    • Motivation to Combine: The motivations mirrored those in Ground 1. A POSITA would have been motivated to place Wu's pump components inside a housing as taught by Goldsmith to improve spatial efficiency, enhance durability, decrease manufacturing costs, and solve the problem of how to structurally interface the separate pump components with the air mattress.
    • Expectation of Success: The combination was presented as a predictable application of known design principles—placing a pump system inside a protective, integrated housing—to achieve expected improvements in an inflatable product.

Ground 3: Obviousness over Wu and Parienti - Claims 1-12 and 16-23 are obvious over Wu in view of Parienti.

  • Prior Art Relied Upon: Wu (Patent 6,698,046) and Parienti (Patent 6,018,960).

  • Core Argument for this Ground:

    • Prior Art Mapping: Following the same pattern, this ground relied on Wu for the uni-directional pump assembly and on Parienti for the teaching of a built-in housing. Petitioner asserted that Parienti disclosed a pump device for an inflatable mattress that is made "interdependent with the mattress by means of gluing or any other means." Parienti's pump device included a housing containing the internal pump components (motor and turbine), thereby teaching a pump integrated into the inflatable body.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Wu's pump system into a built-in housing like that shown in Parienti for the same established reasons: achieving a more compact, durable, convenient, and cost-effective product by combining known elements for their known purposes.
    • Expectation of Success: Petitioner argued that implementing the known interface design from Parienti (a glued-in housing) with the pump components of Wu's system would have been well within a POSITA's technical grasp and would have predictably yielded an air mattress with a built-in pump.

  • Additional Grounds: Petitioner asserted an alternative obviousness challenge (Ground 4) based on Wu in combination with Goldsmith and in further combination with Chaffee. This ground was presented as an alternative in the event the Board construed "inflatable body" to require a substantially airtight structure that Wu and Goldsmith alone were argued not to disclose, with Chaffee providing the teaching of such a body.

4. Key Claim Construction Positions

  • "inflatable body": Petitioner argued for the construction "a structure that expands when filled with air or other gases." This position was critical because Petitioner contended the term does not require the structure to be "substantially airtight," contrary to a construction from a related district court case. Petitioner argued the patent’s own disclosure of a built-in pump necessitates a hole or opening in the body, precluding it from being substantially airtight.
  • "fan": Petitioner proposed the construction "a device that alters air pressure through rotation," based on intrinsic evidence describing the fan as an "air pressure rotator."
  • "pipe": Petitioner proposed the construction "a hollow body for conveying air or other gases," arguing the claims do not restrict the size or shape beyond this function.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-12 and 16-23 of the ’394 patent as unpatentable.