Intex Recreation Corp. v. Team Worldwide Corp.

1. Case Identification

• Case #: IPR2019-00243
• Patent #: 8,863,771
• Filed: November 12, 2018
• Petitioner(s): Intex Recreation Corp.
• Patent Owner(s): Team Worldwide Corporation
• Challenged Claims: 1-4, 8, 12, 13, 17, 21, and 22

2. Patent Overview

• Title: Inflating Module for Use with an Inflatable Object
• Brief Description: The ’771 patent relates to an inflating module for use with inflatable objects like air mattresses. The module contains an air pump assembly and a pressure control system designed to automatically monitor air pressure and activate a supplemental air pump to maintain the pressure within a predetermined range.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claim 1 - Claim 1 is anticipated under 35 U.S.C. § 102 by Price.

• Prior Art Relied Upon: Price (Patent 6,721,980).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Price, which discloses an inflatable air mattress system for bedridden patients, teaches every element of claim 1. Price's controller functions as the claimed "inflating module," which includes an air pump assembly (air supply 23) and a supplemental air pressure providing device (high-pressure pump 31). Price’s pneumatic system and controller software constitute the "pressure controlling assembly," as they are configured to monitor pressure after initial inflation and automatically activate the supplemental pump when pressure drops below a predetermined minimum (Pmin), thereby maintaining pressure within a desired range.

Ground 2: Obviousness over Price and Lin - Claims 1-4, 8, and 17 are obvious over Price in view of Lin.

• Prior Art Relied Upon: Price (Patent 6,721,980) and Lin (Chinese Patent No. CN1260478C).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Price discloses the basic system of automatically maintaining air pressure as recited in the independent claims. Lin, which teaches an "air exchange device" for inflating and deflating air bags, discloses the specific "valve controlling assembly" recited in the dependent claims. Lin’s assembly includes a rotatable knob (handwheel 27), a shaft (air exchange core 6) with a cam (cam 63), and a valve that is selectively pushed by the cam to control airflow.
  • Motivation to Combine: A POSITA would combine Lin's valve control assembly with Price's system to add a feature that Price lacks: an integrated, powered deflation mechanism. While Price has an emergency dump valve, it requires separate manual operation. Lin provides a known, simple design to use the same pump for both inflation and deflation, controlled by a single knob, which would have been an obvious improvement to enhance the functionality and ease of use of Price's system.
  • Expectation of Success: The combination involved substituting a known type of valve controller into a known inflation system. This was a simple substitution of one known element for another to obtain the predictable result of improved manual control over both inflation and deflation.

Ground 3: Obviousness over Price and Lathrop - Claims 12 and 13 are obvious over Price in view of Lathrop.

• Prior Art Relied Upon: Price (Patent 6,721,980) and Lathrop (Patent 7,789,194).

• Core Argument for this Ground:

  • Prior Art Mapping: Price teaches the supplemental air pump system recited in the claims. Lathrop addresses the identical technical problem of noise generated by blowers, albeit in the context of a CPAP device. Lathrop discloses using a housing with air chambers containing absorbent material (e.g., open-cell foam) to minimize air movement noise. It further discloses using noise silencers, such as suspension mounts and thickened housing sections, that are securely attached to the housing to dampen mechanical vibration from the blower.
  • Motivation to Combine: A POSA would combine Lathrop’s noise-reduction technology with Price’s pump system to solve the well-known problem of excessive noise from pumps used in inflatable products. Since Price's pump automatically activates to maintain pressure, including potentially at night, noise reduction would be a critical and obvious improvement. Lathrop provides a direct, analogous solution to this exact problem.
  • Expectation of Success: Applying known sound-dampening materials and vibration-isolating structures from Lathrop to the pump in Price’s system would have predictably resulted in a quieter device. This application of a known technique to a similar problem to obtain a predictable result would have been routine for a POSA.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Price with both the first and second embodiments of Lin to ensure disclosure of a "spring abutted shaft" for claim 3, and combining Price, Lin, and Lathrop to argue the unpatentability of omnibus claims 21 and 22.

4. Key Claim Construction Positions

• "pressure controlling assembly": Petitioner argued this is a means-plus-function term under §112(f) because the claims recite the term purely in functional language (e.g., "configured to monitor," "to automatically activate," and "to control") without reciting sufficient corresponding structure. Petitioner contended that because the '771 patent specification fails to disclose adequate structure to perform these claimed functions, the term is indefinite and the claims are invalid.
• "integrally extending": Petitioner argued for a construction of "extending by fixed connection," rather than requiring a unitary, one-piece structure. This position was based on figures in the '771 patent that appear to show the knob and shaft as separate components connected by a screw, which would be necessary for assembly.
• "an air chamber... for receiving therein absorbent and a noise silencer securely attached to the housing": For claims 13 and 22, Petitioner argued that based on grammatical construction and claim differentiation from claim 12, the limitation "securely attached to the housing" applies only to the "noise silencer" and not the "absorbent." Furthermore, it argued "for receiving therein" applies only to the absorbent, meaning the noise silencer need not be inside the air chamber.

5. Relief Requested

• Petitioner requests institution of an inter partes review of claims 1-4, 8, 12, 13, 17, 21, and 22 of the '771 patent and that those claims be cancelled as unpatentable.