PTAB

IPR2019-00960

MAHLE Filter Systems North America Inc v. Ingevity South Carolina LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Evaporative Emissions Control System
  • Brief Description: The ’844 patent relates to a multi-stage automotive evaporative emissions control system designed to reduce fuel vapor "bleed emissions." The system comprises an initial high-capacity adsorbent volume followed by at least one subsequent low-capacity adsorbent volume, with the adsorbent capacities defined by the patent's proprietary "incremental adsorption capacity" (IAC) metric.

3. Grounds for Unpatentability

Ground 1: Challenged claims (except 3-5, 7, and 19) are obvious over Meiller in view of Park and Applicant-Admitted Prior Art (AAPA).

  • Prior Art Relied Upon: Meiller (Patent 6,896,852), Park (Patent 5,914,294), and AAPA.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Meiller disclosed the claimed two-stage system for solving the known problem of bleed emissions. Meiller’s system comprised a conventional high-capacity canister (the "initial adsorbent volume") connected in series with a honeycomb "scrubber" (the "subsequent adsorbent volume"). The AAPA within the ’844 patent’s specification admitted that conventional carbons for the initial canister had an IAC greater than 35 g/L. Petitioner contended that creating Meiller’s honeycomb scrubber using the manufacturing method taught by Park would inherently result in a subsequent volume with an IAC below 35 g/L. This low IAC was the natural result of two forms of volumetric dilution described in Park: (1) mixing activated carbon with non-adsorbent ceramic and flux materials, and (2) forming the mixture into a honeycomb structure with significant open-cell voidage.
    • Motivation to Combine: A POSITA would combine Park with Meiller because Meiller disclosed using a honeycomb scrubber but did not specify its method of manufacture. Park provided these missing details, teaching the creation of a honeycomb monolith specifically for use in automotive evaporative emissions systems. Petitioner also cited other art (Scardino and Sheline) from Meiller's assignee that explicitly directed a POSITA to Park for this exact purpose.
    • Expectation of Success: Success would be predictable, as Park’s honeycomb was known to provide low airflow restriction, a desirable characteristic for the scrubber function described in Meiller.

Ground 2: Challenged claims (except 3-5, 7, and 19) are obvious over Abe in view of Park and AAPA.

  • Prior Art Relied Upon: Abe (Japanese Application # 10-37812), Park (Patent 5,914,294), and AAPA.
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a nearly identical argument to Ground 1, substituting Abe as the primary reference. Petitioner asserted that Abe also taught a two-stage system comprising a conventional canister followed by a honeycomb auxiliary canister to reduce bleed emissions. As in Ground 1, AAPA was relied upon for disclosing the high-IAC initial volume. The combination of Abe’s system with Park’s manufacturing method was argued to inherently provide the claimed low-IAC subsequent volume due to the same principles of volumetric dilution.
    • Motivation to Combine: The motivation was identical to that in Ground 1. A POSITA reading Abe’s disclosure of a honeycomb canister would look to a reference like Park, which was well-known in the art, to find the specific details on how to construct such a device for an automotive application.
    • Expectation of Success: A POSITA would have a high expectation of success, as the proposed combination used known components in a known configuration to solve a widely understood problem.

Ground 3: Claims 3-5, 7, and 19 are obvious over Meiller in view of Park and Tennison.

  • Prior Art Relied Upon: Meiller (Patent 6,896,852), Park (Patent 5,914,294), and Tennison (WO 92/01585).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claims reciting specific configurations, such as having both adsorbent stages located within a single canister (claims 4, 5, 19) or having multiple subsequent adsorbent volumes (claim 3). Petitioner asserted that the base combination of Meiller and Park established the core two-stage system with the required IAC properties. Tennison was added to teach the desirability and feasibility of arranging multiple, distinct adsorbent beds within a single canister housing.
    • Motivation to Combine: A POSITA would combine Tennison’s teachings with the Meiller-Park system as a matter of known design choice for component integration and packaging efficiency. To create a system with "multiple subsequent adsorbent volumes" (claim 3), Petitioner argued a POSITA would be motivated to add the Meiller-Park honeycomb scrubber to the outlet of Tennison’s already multi-bed canister, thus creating a system with two subsequent adsorbent volumes.
    • Expectation of Success: The combination was presented as a predictable arrangement of known elements, with a high expectation of success based on the established utility of each component.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8, 11-12, 14-16, 18-21, 24-25, 27-29, 31-33, 36-37, 39-41, 43-45, 48-49, and 51-53 of Patent RE38,844 as unpatentable.