PTAB

IPR2019-00162

E One Inc v. Oshkosh Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Quint Configuration Fire Apparatus
  • Brief Description: The ’915 patent describes a "quint" fire apparatus having five key features (aerial ladder, water tank, ground ladders, pump, hose storage) built on a chassis with a single rear axle. The invention purports to achieve an increased ladder extension (at least 95 feet vertical, 90 feet horizontal) and a high tip load capacity (at least 750 pounds) without requiring a tandem rear axle, which was traditionally used to support the weight needed for such performance.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shapiro, Dana, and AAPA - Claims 1-7, 11-17, and 20 are obvious over Shapiro in view of Dana and Applicant’s Admitted Prior Art (AAPA).

  • Prior Art Relied Upon: Shapiro (a 2002 publication, “Aerial Fire Trucks”), Dana (2007-2012 axle application guidelines), and AAPA (from the ’915 patent specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shapiro disclosed the foundational elements of the invention, namely single-rear-axle quint fire trucks with long ladders (100-foot and 110-foot models). The AAPA, taken from the patent’s own background, established that the "traditional" method for increasing ladder reach and tip load was to increase the weight of various components on the chassis to act as a counterbalance. The limiting factor for this traditional approach on a single-axle vehicle was the Gross Axle Weight Rating (GAWR) of the axle itself. Dana disclosed commercially available, off-the-shelf single axles with higher GAWRs (e.g., 35,000 lbs) than what was previously standard.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references due to a well-publicized 2011 proposal by the International Association of Fire Chiefs (IAFC) and Fire Apparatus Manufacturers Association (FAMA) to increase the legal GAWR limits for emergency vehicles. Petitioner asserted this proposal created a strong market incentive for manufacturers to design single-axle quints with enhanced capabilities by using the readily available high-capacity axles from Dana to support the additional weight required for longer ladder reach and higher tip loads, following the traditional methodology described in the AAPA.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as the combination involved applying a "traditional" and well-understood principle (adding weight for counterbalance) to a known vehicle type (single-axle quint) using known, suitable components (high-capacity axles) to achieve a predictable improvement in performance.

Ground 2: Obviousness over KME Manual, Shapiro, and Dana - Claims 1-7, 11-17, and 20 are obvious over KME Manual in view of Shapiro and Dana.

  • Prior Art Relied Upon: KME Manual (a 2012 vehicle manual for a 100-foot Tractor-Drawn Aerial quint), Shapiro, and Dana.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended the KME Manual disclosed a 100-foot tractor-drawn aerial (TDA) quint that met nearly every limitation of the challenged claims. The KME apparatus included a chassis, body, pump, tank, and a four-section ladder. Petitioner provided evidence from the manual showing the ladder could achieve a horizontal reach of over 95 feet. For the 750-pound tip load limitation, Petitioner argued the KME apparatus, with a rated capacity of 500 pounds, inherently met this requirement. This is because National Fire Protection Association (NFPA) standards, which the KME apparatus was designed to meet, mandate a 1.5x safety factor, resulting in a required static load capacity of 750 pounds (1.5 x 500 lbs). The manual’s load test diagrams also showed the vehicle’s components were positioned to counterbalance the ladder at full extension.
    • Motivation to Combine (for §103 grounds): The combination with Shapiro and Dana was argued to address any remaining minor limitations, particularly the specific axle configurations recited in certain claims (e.g., "single solid axle"). Petitioner argued that a POSITA would find it obvious to equip the KME apparatus with the common, off-the-shelf axle types disclosed in Dana, as these were standard design choices in the field, as evidenced by the historical overview in Shapiro.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in using standard axle configurations on the KME apparatus, as it represented a routine and predictable design choice with no technical hurdles.

4. Key Claim Construction Positions

  • "single [front/rear] axle coupled to a [front/rear] end of the chassis": Petitioner argued this term should not be construed to limit the apparatus to only two total axles. This position was based on the open-ended claim preamble "comprising," which allows for additional, unrecited elements. More significantly, Petitioner pointed to the ’915 patent’s own disclosure of a "rear tiller fire apparatus" as an alternative embodiment. Such tiller trucks are understood in the art to necessarily have more than two axles (e.g., a front axle, a trailer axle, and a tiller axle), meaning the Patent Owner's proposed narrower construction would improperly exclude a disclosed embodiment.
  • "tip load of at least 750 pounds": Petitioner contended this term should be construed as "rated capacity" consistent with NFPA standards. However, Petitioner argued the claims were unpatentable even under the Patent Owner’s broader construction of "maximum sustainable load." Under that construction, Petitioner asserted that prior art like the KME Manual inherently disclosed the limitation because its 500-pound rated load, when combined with the mandated 1.5x NFPA safety factor, results in a sustainable static load of 750 pounds.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7, 11-17, and 20 of the ’915 patent as unpatentable.