PTAB

IPR2018-00873

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 discloses an inflatable product, such as an air mattress, with an integrated, built-in air pump assembly. The invention centers on a uni-directional pump that uses a movable air conduit, such as a switching pipe, to alternate between inflation and deflation modes without reversing the pump's motor.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Parienti (Patent 6,018,960) and Renz (European Patent Publication No. 0 275 896).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Parienti disclosed the foundational invention: an inflatable mattress with a built-in pump assembly. However, Parienti’s pump was a reversible-motor type. Petitioner argued that Renz, which discloses a uni-directional ventilation device, taught the missing elements. Renz used a rotatable "tube-shaped" fan housing as a movable air conduit to switch the direction of airflow between intake and exhaust. Petitioner contended that replacing Parienti’s reversible pump with Renz’s uni-directional fan, motor, and rotatable fan housing would result in the invention claimed in the ’394 patent. The rotatable fan housing in Renz was argued to be the claimed "movable air conduit" or "pipe."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Parienti and Renz to create a more efficient and cost-effective product. Petitioner argued that uni-directional pumps, like Renz’s, were known to be superior to reversible pumps, like Parienti's, in several key aspects: improved spatial efficiency (allowing for a smaller motor), increased energy efficiency, lower manufacturing cost, and reduced overall weight. These known advantages would have provided a strong motivation for a POSA to substitute the less-efficient reversible pump in Parienti with the more efficient uni-directional system taught by Renz.
    • Expectation of Success: Petitioner argued that substituting one known type of power inflate/deflate system (reversible pump) for another (uni-directional pump) was a simple substitution of known elements to achieve the predictable result of a functional power-inflatable and -deflatable product. Therefore, a POSA would have had a high expectation of success.

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

  • Prior Art Relied Upon: Parienti (Patent 6,018,960) and Wu (Patent 6,698,046).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative combination for the same claims. As in Ground 1, Parienti supplied the base inflatable mattress with a built-in, reversible pump. Petitioner argued that Wu, which discloses a system for inflating and deflating an air mattress, taught a different type of uni-directional pump assembly that also met the claim limitations. Wu’s system used a uni-directional blower in combination with a rotary valve containing a movable "gate member" to switch airflow between inflation and deflation modes. Petitioner asserted that Wu’s movable gate member constituted the claimed "movable air conduit" and that substituting Parienti's pump with Wu's blower and rotary valve system rendered the claims obvious.
    • Motivation to Combine: The motivation to combine Parienti with Wu was identical to the motivation for combining with Renz in Ground 1. Petitioner argued a POSA would have been motivated to replace Parienti’s inefficient reversible pump with Wu’s more advanced uni-directional system to gain the well-known benefits of improved spatial efficiency, better energy efficiency, lower cost, and reduced weight. The petition explicitly stated that the reasons provided in Ground 1 were equally applicable to this combination.
    • Expectation of Success: Success was expected because the combination involved substituting one known power inflation/deflation mechanism for another to achieve the same, predictable function. The interchangeability of such systems was asserted to be well within the knowledge of a POSA.

4. Key Claim Construction Positions

  • "fan": Petitioner proposed the construction "a device that alters air pressure through rotation." This was based on the specification’s parenthetical description of the fan as an "air pressure rotator," which Petitioner argued confirmed the term's proper meaning.
  • "inflatable body": Petitioner proposed "a structure that expands when filled with air or other gases." A key point of contention was that this construction should not include a "substantially airtight" limitation. Petitioner argued that the patent's own figures show a large hole in the inflatable body where the pump assembly is installed, making a strictly airtight requirement inconsistent with the disclosure.
  • "pipe": Petitioner proposed the broad construction "a hollow body for conveying air or other gases." It was argued that the claims and specification support a general interpretation without restrictions on size or shape, consistent with the varied configurations shown in the patent.

5. Relief Requested

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