PTAB

IPR2019-00497

American National Mfg Inc v. Sleep Number Corp

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1. Case Identification

2. Patent Overview

  • Title: System and Method for Adjusting Pressure in an Inflatable Object
  • Brief Description: The ’747 patent discloses a system for adjusting air pressure in an inflatable object, such as an air bed. The system determines the actual pressure in an air chamber by measuring pressure at a remote pump manifold and applying a "pressure adjustment factor" to compensate for pressure differentials that occur during inflation or deflation, thereby aiming to achieve a desired pressure more quickly and accurately.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gifft, Mittal, and Pillsbury - Claims 1-4, 7-12, and 14-19 are obvious over Gifft in view of Mittal and Pillsbury.

  • Prior Art Relied Upon: Gifft (Patent 5,904,172), Mittal (Patent 5,629,873), and Pillsbury (Patent 5,277,187).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gifft disclosed the foundational air bed system, including an air chamber, a pump with a housing/manifold, a controller, and a pressure sensor located at the pump manifold remote from the air chamber. However, Gifft did not teach an advanced method for compensating for the pressure difference between the sensor and the chamber during airflow. Petitioner asserted that Mittal (for tire inflation systems) and Pillsbury (for blood pressure monitors) both remedied this exact problem in analogous pneumatic systems. Both references taught using "offset values" (the claimed "pressure adjustment factor") to calculate a target pressure that accounts for the dynamic pressure drop. Crucially, both Mittal and Pillsbury also taught adaptively updating these offset values by comparing the actual static pressure (measured after flow stops) to the desired setpoint and calculating an error (the claimed "adjustment factor error") to modify the offset for subsequent cycles.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the adaptive control methods of Mittal and Pillsbury with the basic air bed of Gifft to solve the known problem of slow and inaccurate pressure adjustments. The inefficiency of the Gifft system, which required iterations of filling and waiting to reach a target pressure, would have prompted a POSITA to look to known solutions in the broader field of pneumatic controls. Applying the offset compensation and adaptive error correction from Mittal and Pillsbury to Gifft’s air bed was a straightforward application of known principles to improve a known device.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved applying well-understood pneumatic control principles to a predictable system. The underlying physics of pressure differentials in hoses are the same whether inflating a tire, a blood pressure cuff, or an air mattress, making the results of the combination predictable.

Ground 2: Obviousness over Gifft, Mittal, and Ebel - Claims 1, 4-6, 10, and 12-13 are obvious over Gifft in view of Mittal and Ebel.

  • Prior Art Relied Upon: Gifft (Patent 5,904,172), Mittal (Patent 5,629,873), and Ebel (Application # 2007/0000559).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on the same teachings from Gifft and Mittal as Ground 1 but substituted Pillsbury with Ebel to provide further rationale for using different types of adjustment factors. Petitioner argued that Ebel, which concerned pressure measurement in a car seat air bag, explicitly disclosed compensating for "conduit effects" by using both multiplicative factors and offset terms in distinct "filling" and "emptying" equations. Ebel’s use of fluid-electrical equivalent circuits demonstrated how a multiplicative relationship between sensed pressure and actual pressure naturally arises in systems like Gifft's where a sensor is located between a conduit impedance and a vent impedance. This teaching directly supported the use of a multiplicative "pressure adjustment factor" as claimed.
    • Motivation to Combine: A POSITA looking to improve the Gifft system would be motivated to consult related arts, such as Ebel’s disclosure on controlling pressure in inflatable occupant supports. Ebel provided a more detailed analysis than Mittal, teaching the use of multiplicative factors in addition to additive offsets. A POSITA would combine Ebel's more sophisticated compensation techniques with the Gifft/Mittal system to achieve even greater accuracy and efficiency, particularly for modeling deflation, which Ebel showed could be represented by a multiplicative factor.
    • Expectation of Success: The combination would have been successful and predictable. Ebel's teachings on compensating for conduit effects are based on fundamental engineering principles directly applicable to the pneumatic system disclosed in Gifft.

4. Key Claim Construction Positions

  • "Pressure setpoint": Petitioner argued this term means "the desired pressure of the air chamber." This construction was necessary to map the "target pressure" or "desired pressure" disclosed in the prior art to this claim limitation.
  • "Pressure adjustment factor": Petitioner proposed this term means "a calculation parameter used by a control system to determine a pressure target and compensate for the difference between sensed pressure and chamber pressure during flow." This broad construction was critical to encompass the additive "offset values" from Mittal and Pillsbury as well as the multiplicative factors and offset terms from Ebel.
  • "Pump housing": Petitioner argued this term is equivalent to "pump manifold," as the patent uses them interchangeably to refer to the location where pressure is measured. This allowed Petitioner to apply prior art disclosing manifold-based measurements to claims reciting a pump housing.

5. Relief Requested

  • Petitioner requested institution of an inter partes review for claims 1-19 of the ’747 patent and cancellation of those claims as unpatentable.