PTAB

IPR2021-00080

Shenzhen BuXiang Network Technology Co Ltd v. IDEAL Time Consultants Ltd

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Inflatable Mattress Assembly
  • Brief Description: The ’555 patent describes an inflatable mattress with an integrated peripheral frame on its upper surface. The design intends to mimic the appearance and feel of a traditional two-layered, pillow-top mattress by using an internal wall to create a stable, defined edge structure.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-4 and 6-8 under §102

  • Prior Art Relied Upon: Metzger (Patent 7,089,618).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Metzger anticipated all limitations of claims 1-4 and 6-8. Metzger discloses an inflatable mattress with top, bottom, and peripheral side panels. Its "side support beams" (25) function as the claimed "internal wall," and are welded to the top panel (7) and side panel (9) at locations that are "substantially below" the top surface and "substantially inwardly" from the mattress edge, forming the claimed "peripheral frame." Petitioner asserted that the gaps shown at the corners between Metzger’s four support beams inherently create the claimed "fluid passage," as such a passage is necessary to inflate the entire peripheral frame from a single valve, a configuration disclosed by Metzger. Further, the natural bulging of the pressurized top and side panels forms the claimed "arcuate cross-section" and creates the "pillow-top appearance."
    • Key Aspects: Petitioner contended that Metzger was not considered during prosecution, and its teachings, combined with the claim constructions for "substantially below" and "substantially inwardly," directly read on the challenged claims.

Ground 2: Obviousness of Claims 5 and 9 over Metzger in view of Wolfe

  • Prior Art Relied Upon: Metzger (’618 patent) and Wolfe (Patent 5,598,593).
  • Core Argument:
    • Prior Art Mapping: This ground addressed claims 5 and 9, which add the limitation of a "felt-like upper surface" over the entire top panel. Petitioner asserted that Metzger taught the underlying mattress structure of claim 4 (and by extension claim 8). Wolfe taught an inflatable air bed with a "flocking material to provide a soft, material-like finish" that is sprayed on to create a "velvet-like finish." Petitioner argued that "felt-like" and "velvet-like" are synonymous terms for a person of ordinary skill in the art (POSITA).
    • Motivation to Combine: A POSITA would combine Metzger’s mattress design with Wolfe’s surface coating to solve the well-known problem of user discomfort caused by direct contact with vinyl or plastic mattress surfaces. Applying a known comfort-enhancing coating like flocking to a mattress was a simple and common solution.
    • Expectation of Success: The combination was a predictable application of a known surface treatment to a known product type to achieve the expected result of improved user comfort, with no technical hurdles.

Ground 3: Obviousness of Claims 1-4 and 6-8 over Metzger in view of Wu

  • Prior Art Relied Upon: Metzger (’618 patent) and Wu (Application # 2006/0265810).

  • Core Argument:

    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, assuming the Board found Metzger did not disclose a continuous peripheral frame with a fluid passage. Petitioner argued that Wu taught these missing elements. Wu discloses an inflatable mattress with a contiguous, circumferential "pull band" (an internal wall) that is inclined to provide support. Crucially, Wu explicitly teaches including "circular or an oval air vent channels" in its pull band to allow fluid communication.
    • Motivation to Combine: A POSITA would have recognized that both Metzger and Wu used oblique internal structures to limit outward expansion and improve edge support. A POSITA would combine Metzger's design with Wu's continuous, vented internal wall to achieve superior and more uniform edge support, particularly at the corners where Metzger’s discontinuous beams could lead to bulging—a problem Wu was designed to solve.
    • Expectation of Success: Combining the similar structural features from Metzger and Wu to enhance mattress stability and aesthetics was presented as a predictable design modification with a high expectation of success.

  • Additional Grounds: Petitioner asserted two additional grounds. The first was an obviousness challenge to claims 1-4 and 6-8 based on Metzger alone, as an alternative to the anticipation ground. The second was an obviousness challenge to claims 5 and 9 based on the combination of Metzger, Wu, and Wolfe, adding Wolfe’s felt-like surface to the mattress structure established by Metzger and Wu.

4. Key Claim Construction Positions

  • "substantially below": Petitioner argued this term should be construed to mean on the order of "several inches below" the top panel. This construction was based on exemplary language directly in the ’555 patent specification ("...located substantially below (such as several inches below) a level of the top panel...").
  • "substantially inwardly": Similarly, Petitioner asserted this term should be construed to mean on the order of "several inches inwardly" from the side panel. This construction was also based on exemplary language in the ’555 patent specification ("...located substantially inwardly (such as several inches inwardly)..."). These constructions were central to the argument that the weld locations in the Metzger prior art met the claim limitations.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-9 of the ’555 patent as unpatentable.