PTAB

IPR2019-00245

Intex Recreation Corp. v. Team Worldwide Corporation

Title: Inflating Module for Use with an Inflatable Object
Brief Description: The ’979 patent relates to an inflating module for use with an inflatable object, such as an air mattress. The invention describes a system that uses a pump for primary inflation and includes a separate "supplemental air pressure providing device" configured to automatically monitor and maintain the object's air pressure within a predetermined range after initial inflation. The patent also discloses noise-reducing features, including an "absorbent" material in an air chamber and a "noise silencer" between an inner and outer housing.

Prior Art Relied Upon: Price (Patent 6,721,980)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Price, which discloses an air mattress system for bedridden patients, teaches every limitation of claim 1. Price’s system includes an inflating module (controller 18) adapted to an inflatable body (air mattress 12). This module uses a primary pump (blower 33) for initial inflation and features a pressure controlling assembly (pneumatic system 27 and software) that monitors pressure post-inflation. The assembly automatically activates a supplemental air pressure device (pump 31) to maintain pressure within a predetermined range if it drops below a set threshold.

Prior Art Relied Upon: Price (Patent 6,721,980) and Lathrop (Patent 7,789,194)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Price teaches the base system of claim 1, and Lathrop provides the missing elements for dependent claims 2-4. Lathrop, which addresses noise in medical ventilation systems (analogous art), discloses a silencer for a blower device. This silencer comprises an outer housing with an integrally formed inner housing (claim 3), contains an air blower, and uses absorbent material ("dissipative elements") in air chambers to minimize noise (claim 2). Lathrop also teaches positioning noise silencers ("thick sections") between the outer and inner housings (claim 4).
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated to address the known problem of pump noise, particularly for a device like Price's that automatically activates and could disturb a sleeping user. A POSITA would have looked to analogous arts, such as Lathrop's CPAP silencers, to incorporate known noise-reduction structures—like dual housings, absorbents, and silencers—into Price's supplemental pump.
- Expectation of Success: Combining known noise attenuation features from Lathrop with the pump system of Price was argued to be a straightforward application of known solutions to a known problem, with predictable results.

Prior Art Relied Upon: Price (Patent 6,721,980) and Shan-Chieh (Patent 5,716,199)
Core Argument for this Ground:
- Prior Art Mapping: While relying on Price for the base invention of claim 1, Petitioner argued that Shan-Chieh teaches the housing limitations of claims 3 and 4. Shan-Chieh discloses an air pump for an air mattress that has an outer housing and an inner housing (casing) integrally formed inside (claim 3). Furthermore, Shan-Chieh teaches the use of noise silencers in the form of "side cushioning pads" and "cushioning members" positioned between its outer and inner housings to reduce vibrational shock and noise (claim 4).
- Motivation to Combine: A POSITA seeking to quiet the supplemental pump in Price's system would be motivated to incorporate the housing and silencing designs from Shan-Chieh, which is directed to the same field of air pumps for mattresses. This combination was presented as a simple substitution of known elements to achieve the predictable result of noise reduction.

Prior Art Relied Upon: Price (Patent 6,721,980) and Wilkinson (Patent 7,434,283)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner alleged that Wilkinson provides the final limitation of claim 5. Wilkinson discloses a cushioning device where air is pumped through ports that function as nozzles. Critically, Wilkinson teaches connecting an absorbent "sound control batten" directly to these ports for the express purpose of reducing noise during air intake and exhaust.
- Motivation to Combine: A POSITA would recognize that the supplemental pump in Price's system would require an outlet or nozzle for air delivery. To address noise generated by airflow through this nozzle, particularly in a hospital setting as described in Price, the POSITA would be motivated to incorporate Wilkinson's teaching of using a sound-dampening batten directly at the nozzle.
- Expectation of Success: Applying a known sound-dampening element (Wilkinson's batten) to a known component (the nozzle of Price's pump) would have been an obvious design choice with a high expectation of success in reducing noise.

"pressure controlling assembly" (claims 1-5): Petitioner argued this term is governed by 35 U.S.C. §112, ¶ 6 (pre-AIA) as a means-plus-function term. Petitioner contended the term is indefinite because the ’979 patent specification fails to disclose any corresponding structure for performing the claimed functions of monitoring pressure, automatically activating a device, and controlling supplemental air. The specification only describes the assembly in purely functional terms.
"the inflating module used in conjunction with a pump that provides primary air pressure" (preamble, claim 1): Petitioner argued this preamble phrase is limiting because the claim body depends on it for antecedent basis. Petitioner further contended the phrase is indefinite because it improperly recites a method of use ("used in conjunction with") within an apparatus claim, making the point of infringement unclear. The meaning of "primary air pressure" is also argued to be unclear, as the specification provides no definition.
"absorbent" (claims 2, 5): Based on the specification, Petitioner proposed this term be construed as "any material, such as cotton, that minimizes noise caused by flow of air from the operation of a blower and/or pump, or that reduces noise inside an inlet or a nozzle."

Petitioner requested that the Board institute an inter partes review and cancel claims 1-5 of the ’979 patent as unpatentable.