PTAB

IPR2020-01139

Yita LLC v. MacNeil IP LLC

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1. Case Identification

2. Patent Overview

  • Title: Vehicle Floor Tray
  • Brief Description: The ’186 patent relates to vehicle floor trays manufactured via thermoforming from a sheet of thermoplastic polymer. The trays are designed to conform closely to a vehicle's footwell and include features such as a central reservoir and upstanding, hollow baffles to contain liquids and elevate an occupant's feet.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rabbe, Yung, and Gruenwald - Claims 1-7 are obvious over Rabbe, Yung, and Gruenwald under 35 U.S.C. §103.

  • Prior Art Relied Upon: Rabbe (French Application No. 2,547,252), Yung (Application # 2002/0045029), and Gruenwald (Thermoforming: A Plastics Processing Guide, 1998).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary references disclose all key limitations of the challenged claims. Rabbe taught a vehicle floor tray with a central panel and multiple integrated, upstanding side panels that "perfectly conform" to the contour of a vehicle's footwell to protect against soiling. While Rabbe disclosed using semi-rigid rubber, Petitioner asserted a POSITA would have implemented the design using thermoformed thermoplastics as taught by Yung and Gruenwald. Yung taught a thermoformed vehicle mat made from polyethylene that included a central reservoir for collecting liquid and a plurality of upstanding, hollow, elongate baffles (termed "umbos") to elevate an occupant's feet and impede fluid movement. Yung also disclosed curved transitions between the central panel and sidewalls. Finally, Gruenwald, a treatise on thermoforming, described methods to control material thinning during the process to achieve a final product with "substantially uniform" wall thickness, a key limitation of claim 1. Gruenwald also taught the importance of using curved transitions to avoid stress and thinning at corners. Petitioner contended that the combination of Rabbe’s conforming tray, Yung’s reservoir and hollow baffle features, and Gruenwald's teachings on thermoforming processes rendered claims 1-7 obvious.
    • Motivation to Combine: Petitioner asserted multiple motivations for a POSITA to combine the references. A POSITA starting with Rabbe’s conforming tray design, which was silent on manufacturing method, would combine it with the well-known, cost-effective thermoforming process described in Yung and Gruenwald. To improve Rabbe’s design, a POSITA would incorporate Yung’s reservoir and hollow baffle features to better contain fluids and reduce product weight and cost. Further, to address the known problem of non-uniform thinning inherent in thermoforming, a POSITA would be motivated to apply the techniques taught in Gruenwald (e.g., plug-assist forming, billow forming) to achieve the claimed "substantially uniform thickness," thereby preventing weak spots and improving durability. The use of curved transitions, as taught by Gruenwald and shown in Yung, was a standard practice to improve stiffness and prevent thinning, providing further motivation for the combination.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because the combination involved applying known manufacturing techniques (thermoforming) to a known product (a vehicle floor tray) to integrate predictable features (reservoirs, baffles, conforming walls). The underlying technologies, including 3D scanning of vehicle footwells to create precise molds, were well-established and would have led to a predictable and successful outcome.

4. Key Claim Construction Positions

  • "thickness...being substantially uniform throughout the tray": Petitioner argued this limitation, central to claim 1, required a construction beyond the inherent result of basic thermoforming. Based on the prosecution history, where the applicant distinguished the invention by overcoming thinning issues, Petitioner contended the term meant achieving a uniformity in thickness "approaching complete uniformity." This would be accomplished by actively employing known techniques to limit and mitigate the localized thinning that naturally occurs during the thermoforming process, as described in the Gruenwald reference.

5. Key Technical Contentions (Beyond Claim Construction)

  • Thermoforming Process Limitations and Solutions: A central technical contention was that non-uniform wall thickness is a well-known, inherent problem in the thermoforming arts. Petitioner argued that because this issue and its solutions (e.g., pre-stretching, plug assists, avoiding sharp corners) were extensively documented in prior art like Gruenwald, achieving a "substantially uniform" thickness was not an inventive step. Rather, it was the predictable result of applying known solutions to a known problem to improve product quality and durability.

6. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate because the core prior art and arguments were not previously before the USPTO. Specifically, Rabbe and Gruenwald were never presented to the Examiner. While a related patent to Yung was cited in an Information Disclosure Statement (IDS), it was never substantively applied in a rejection. Petitioner asserted that the Examiner's reason for allowance—that the prior art lacked a combination showing hollow baffles—was incorrect, as Yung explicitly disclosed this feature.

7. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-7 of the ’186 patent as unpatentable.