PTAB

IPR2019-00243

Intex Recreation Corp v. Team Worldwide Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Inflating Module for Use with an Inflatable Object
  • Brief Description: The ’771 patent discloses an inflating module for an inflatable object, such as an air mattress. The module includes a pressure controlling assembly configured to monitor air pressure and automatically activate a supplemental air pressure device to maintain pressure within a predetermined range.

3. Grounds for Unpatentability

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

  • 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 for bedridden patients, teaches every limitation of claim 1. Price’s controller (18) is an "inflating module" with an air supply (23) as the "air pump assembly." Critically, Price's combination of a pneumatic system (27) and controller software constitutes a "pressure controlling assembly." This assembly is configured to monitor air pressure in the mattress zones after initial inflation and automatically activate a supplemental, low-volume pump (31) if the pressure drops below a predetermined minimum, thereby maintaining the pressure within a set range. This maps directly to all functional requirements of the claimed pressure controlling assembly.

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 contended that Price teaches the base inflating module with automatic supplemental air pressure, as established in Ground 1. Lin, which discloses an air exchange device for inflating and deflating air bags, supplies the specific mechanical limitations of the dependent claims. Lin teaches a "valve controlling assembly" comprising a rotatable knob (handwheel 27), a shaft (air exchange core 6) with a cam (63) on its periphery, and a valve (13) that is selectively pushed by the cam's movement to control airflow. This combination discloses the limitations recited in claims 2, 3, 4, and 8.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Lin’s valve control mechanism with Price’s inflating module to improve its functionality. Price relies on a separate, manual emergency dump valve for rapid deflation, whereas Lin provides a single, pump-driven mechanism for both inflation and rapid deflation. A POSITA would integrate Lin’s design to create a more convenient, all-in-one controller that ensures more complete and efficient deflation, remedying the shortcomings of Price’s system.
    • Expectation of Success: Incorporating Lin's well-understood mechanical valve control into Price's electronic system was a simple substitution of known elements to achieve a predictable improvement in functionality.

Ground 3: Obviousness over Price and Lathrop - Claims 12-13 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: Petitioner argued Price’s supplemental pump (31) is a "supplemental air pressure providing device." Lathrop, which addresses noise reduction in CPAP blower devices, teaches the remaining limitations of claims 12 and 13. Lathrop discloses a housing containing an air blower, with internal air chambers for receiving "absorbent" material (dissipative foam elements 92) to minimize airflow noise. Lathrop further discloses "noise silencers" (suspension mounts 22 and thick sections 68) that are securely attached to the housing to attenuate structure-borne vibration from the blower.
    • Motivation to Combine: A POSITA would be motivated to address the well-known problem of noise generated by pumps used in inflatable mattresses, particularly for nighttime use. The problem addressed by Lathrop (noise in CPAP machines) is directly analogous. A POSITA would therefore look to Lathrop’s established solutions and incorporate its absorbent materials and vibration-dampening silencers into the housing of Price’s supplemental pump to make the overall product quieter and more acceptable to consumers.
    • Expectation of Success: Applying known noise and vibration reduction techniques from an analogous field to a noisy pump was a routine design choice with a high expectation of success.

  • Additional Grounds: Petitioner asserted that claim 3 is obvious over Price and both the first and second embodiments of Lin. Petitioner also asserted that claims 21 and 22, which combine elements from the grounds above, are obvious over the combination of Price, Lin, and Lathrop.

4. Key Claim Construction Positions

  • "pressure controlling assembly": Petitioner argued this term, recited in all challenged claims, is a means-plus-function term under §112, ¶ 6. The claims recite the term solely by its function (monitoring, activating, controlling) without reciting sufficient structure to perform those functions. Petitioner further argued the term is indefinite because the specification fails to disclose any corresponding structure, referring to the assembly only in functional terms.
  • "integrally extending": For the phrase "a shaft integrally extending from the knob" (claims 2, 21), Petitioner argued the broadest reasonable interpretation is "extending by fixed connection." This construction does not require the knob and shaft to be a single unitary piece. This position was supported by figures in the ’771 patent itself, which appear to show the shaft connected to the knob with a screw, a configuration that would be necessary for assembly.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-4, 8, 12, 13, 17, 21, and 22 of the ’771 patent as unpatentable.