PTAB

IPR2018-00874

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 airbed, featuring a built-in, uni-directional air pump assembly. The assembly uses a movable air conduit, such as a switching pipe or valve, to selectively direct airflow for inflation or deflation without reversing the direction of the pump's motor.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Chaffee (Patent 7,039,972) and Wu (Patent 6,698,046).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Chaffee disclosed most claim elements, including an inflatable product (an air mattress) with a built-in, motorized pump assembly contained within a housing that is recessed into the inflatable body. However, Chaffee taught a reversible pump assembly where the motor's direction is reversed to switch between inflation and deflation. Petitioner argued that Wu taught the missing element: a uni-directional pump assembly that uses a movable, rotary valve (an "air conduit") to switch between inflation and deflation, a feature central to the challenged claims of the ’394 patent.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would have been motivated to replace Chaffee's reversible pump with Wu's more advanced uni-directional pump assembly. The stated motivations were to achieve predictable and well-known benefits, including improved spatial efficiency (allowing for a smaller, lighter motor), increased energy efficiency, and reduced manufacturing cost. These were all recognized advantages of uni-directional pumps over reversible pumps at the time, making the combination a common-sense design improvement.
    • Expectation of Success: A POSA would have had a high expectation of success in making this substitution. The petition argued this was a simple replacement of one known pump type for another within the same field of art (inflatable mattress pumps) to achieve predictable results, a classic motivation for finding obviousness.

Ground 2: Claims 1-12 and 16-23 are obvious over Chaffee in view of Scott and Pisante.

  • Prior Art Relied Upon: Chaffee (Patent 7,039,972), Scott (Patent 4,938,528), and Pisante (Patent No. FR 2 583 825).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative path to obviousness. As in Ground 1, Chaffee provided the base invention of an inflatable product with a built-in reversible pump. Scott was cited for teaching the concept of a uni-directional pump using a "two-position, four-way valve" to control inflation and deflation. However, Scott only disclosed this valve schematically without a specific physical structure. To fill this gap, Petitioner introduced Pisante, which disclosed a physical, rotatable "pipe switching device" (a directional control valve) for a blower/vacuum assembly that performed a similar function.
    • Motivation to Combine: The motivation to combine Chaffee and Scott was identical to that in Ground 1—to gain the known advantages of a uni-directional pump. A POSA, seeking to implement Scott's conceptual schematic valve, would have been motivated to look for known physical valve structures to realize the design. Petitioner argued that Pisante provided a suitable, known example of such a rotary directional control valve, making it an obvious component choice to complete the design.
    • Expectation of Success: A POSA would have reasonably expected success in this combination. The process involved substituting one known pump type for another (Chaffee/Scott) and then implementing a conceptual valve (Scott) with a known, off-the-shelf physical structure (Pisante). The petition framed this as a routine engineering design choice, not an inventive leap.

4. Key Claim Construction Positions

  • "inflatable body": Petitioner proposed the construction "a structure that expands when filled with air or other gases." This was argued to be critical because the Petitioner contended a district court's prior construction, which required the body to be "substantially airtight," was erroneous. Petitioner argued the patent's own disclosure shows the inflatable body having a large hole to accommodate the pump assembly, meaning it is not airtight on its own and relies on the pump assembly to seal the opening.
  • "pipe": Petitioner argued for a broad construction of "a hollow body for conveying air or other gases," without limitation to a specific shape like "tubular or cylindrical." This construction supports their argument that the movable air conduits in the prior art, such as Wu's rotary valve, meet the "pipe" limitation as it is a passage for conveying air.
  • "fan": Petitioner proposed the construction "a device that alters air pressure through rotation." This construction was used to map the rotary impellers in the prior art (e.g., in Chaffee and Wu) to the claimed "fan and motor assembly."

5. Key Technical Contentions (Beyond Claim Construction)

  • Interchangeability of Pump Designs: A central technical contention underpinning both grounds of invalidity was that, as of the patent's priority date, a POSA would have considered reversible pump assemblies and uni-directional pump assemblies to be well-known, interchangeable alternatives for achieving powered inflation and deflation in inflatable products. The petition argued that the choice between them was a simple design trade-off based on known factors like cost, efficiency, and size, rather than an inventive step. This interchangeability was key to the argument that substituting one for the other would have been obvious to a skilled artisan.

6. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 1-12 and 16-23 of Patent 7,246,394 as unpatentable under 35 U.S.C. §103.