PTAB

IPR2018-00871

Intex Recreation Corp v. Team Worldwide Corp

Key Events

Petition

petition

Title: Inflatable Product with Built-In Housing and Switch Pipe
Brief Description: The ’394 patent discloses an inflatable product, such as an airbed, featuring a built-in air pump assembly. The assembly is designed with a uni-directional pump and a movable "switching pipe" that allows a user to alternate between inflation and deflation modes without reversing the direction of the pump's motor.

Prior Art Relied Upon: Walker (Patent 4,890,344) and Chaffee (Patent 7,039,972).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Walker disclosed an external, uni-directional air pump assembly featuring an "air control apparatus" (casing 328) that contained a motor, impeller, and a movable gate (gate 338). This gate functioned as a switching air conduit to direct airflow for either inflation or deflation. While Walker taught the core pump mechanism, it did not teach building the pump into the inflatable body itself. Petitioner asserted that Chaffee supplied this missing element by disclosing a fluid controller with a housing (housing 90) that is explicitly built into and recessed within an inflatable bladder.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Walker's pump system with Chaffee's built-in housing design to achieve several predictable and well-known benefits. These motivations included enhanced user convenience (by eliminating a separate pump), improved spatial efficiency (creating a more compact product), increased durability (by protecting the pump), and better cost-effectiveness.
- Expectation of Success: A POSITA would have had a high expectation of success because combining a known pump mechanism with a known integration method was a simple substitution of familiar elements to predictably yield a functioning air mattress with an integrated pump.

Prior Art Relied Upon: Walker (Patent 4,890,344) and Goldsmith (Patent 2,493,067).
Core Argument for this Ground: This ground presented an alternative combination to Ground 1, using Goldsmith to teach the "built-in" feature.
- Prior Art Mapping: As in the first ground, Walker was used to supply the core uni-directional pump technology. Petitioner cited Goldsmith for its teaching of an air pump for a mattress where the housing (casing 42) is "mounted or attached to the mattress" air compartment wall using rivets. Petitioner contended this riveted, recessed mounting constituted a built-in design distinct from Chaffee's adhered or heat-sealed method.
- Motivation to Combine: The motivation was identical to that asserted in Ground 1. A POSITA would have been motivated to integrate Walker's pump into an inflatable body using the method taught by Goldsmith to realize the same known advantages of efficiency, compactness, durability, and marketability associated with built-in pump designs.

Prior Art Relied Upon: Walker (Patent 4,890,344) and Parienti (Patent 6,018,960).
Core Argument for this Ground: This ground provided a third distinct combination for the "built-in" limitation.
- Prior Art Mapping: Walker again provided the foundational pump assembly. Parienti was introduced to teach making an air pump device "interdependent with the mattress by means of gluing or any other means." Petitioner argued that a POSITA would understand this permanent attachment method to be a teaching of building the pump housing into the inflatable mattress.
- Motivation to Combine: The rationale for the combination mirrored that of the previous grounds. Applying Parienti's teaching of a glued, built-in pump to Walker's system was presented as an obvious design choice to achieve the well-documented benefits of an integrated pump-mattress system.
Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 4-6 and 19-21. This ground combined Walker with one of Chaffee, Goldsmith, or Parienti, and further added Basic Pneumatics (a 1997 manual). This alternative ground argued that if Walker's rectangular sliding gate were not considered a "pipe," Basic Pneumatics taught that modifying it into a well-known cylindrical, rotational valve was a simple substitution of known components to achieve a predictable result and a more compact design.

"pipe": Petitioner argued for a Broadest Reasonable Interpretation (BRI) of "a hollow body for conveying air or other gases." This construction was critical to the invalidity case, as the primary reference, Walker, discloses an "air conduit" (gate 338) that is a rectangular, sliding component, not a traditional cylindrical tube. Petitioner asserted that the district court’s narrower construction in related litigation, which required a "tubular or cylindrical object," was erroneous and that under the proper, broader BRI, Walker's gate meets the "pipe" limitation.
"inflatable body": Petitioner contended that the BRI for this term is "a structure that expands when filled with air or other gases." They argued against including a "substantially airtight" limitation, asserting this was erroneously imported by the district court. Petitioner pointed out that the ’394 patent’s own specification describes inflatable bodies with large openings to accommodate the pump assemblies, undermining the notion that they must be substantially airtight on their own.

Petitioner requested that the Board institute an inter partes review and cancel claims 1-12 and 16-23 of the ’394 patent as unpatentable under 35 U.S.C. §103.