Airbus Americas Inc v. Harper Engineering Co

1. Case Identification

• Case #: IPR2022-00192
• Patent #: 10,760,315
• Filed: November 12, 2021
• Petitioner(s): Airbus Americas, Inc.
• Patent Owner(s): Harper Engineering Company
• Challenged Claims: 1-17

2. Patent Overview

• Title: Stowage Bin Assembly Having Flush Hinge Assembly
• Brief Description: The ’315 patent describes an aircraft stowage bin assembly featuring a hinge assembly that is received within a notch in the bin bucket’s sidewall. This design allows the interior surface of the hinge housing to be flush with the interior surface of the sidewall, maximizing usable storage space by eliminating hinge protrusion into the bin.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 7-11 are anticipated by Rheaume

• Prior Art Relied Upon: Rheaume (Application # 2020/0040633).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Rheaume discloses every limitation of the challenged claims. Rheaume teaches an aircraft storage bin with a hinge assembly received in a "cut-out" (notch) in the bin's sidewall. Petitioner asserted that Rheaume explicitly describes making the interior surface of its hinge housing flush with the bin’s interior sidewall by defining an "indentation" in the wall body at the connection point, which ensures "substantially the entire width W of the storage space 16 remains available for storage." This configuration, intended to avoid any obstruction, allegedly anticipates the core "flush" limitation of claim 1. Petitioner further argued Rheaume discloses the elements of dependent claims, including a damper (claim 7) and various alignment and support features (claims 8-11).

Ground 2: Claims 2-6 and 12-17 are obvious over Rheaume in view of Savian

• Prior Art Relied Upon: Rheaume (Application # 2020/0040633) and Savian (WO 2014/127161).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground asserted that it would have been obvious to modify the flush-hinge bin assembly of Rheaume by incorporating the self-opening mechanisms taught by Savian. Rheaume provides the base assembly with the flush-mounted hinge. Savian discloses various self-opening and assist mechanisms, including "assist springs," rotary dampers, and rotary cranks, which are housed within its own hinge assembly to aid a user in opening or closing a bin. These mechanisms from Savian were alleged to meet the limitations of claims 2-6 and 12-17.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve the functionality of Rheaume’s bin. Both references address improving overhead aircraft stowage bins, a field where maximizing space and improving user convenience are key goals. Petitioner argued a POSITA would be motivated to add Savian's well-known assist mechanisms to Rheaume's space-efficient design to create a bin that is both easy to use and has maximum capacity.
  • Expectation of Success: A POSITA would have a high expectation of success because the combination involves incorporating commonplace mechanical components (springs, cranks) into a predictable mechanical system. The similar bin geometries and shared technical goals of the references would make the integration straightforward, leading to the predictable result of a self-opening, flush-hinge bin.

Ground 3: Claims 1-17 are obvious over Savian in view of Frazier

• Prior Art Relied Upon: Savian (WO 2014/127161) and Frazier (Patent 9,090,351).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground argued that if Savian alone is not found to teach a perfectly flush hinge, the combination with Frazier renders the claims obvious. Savian discloses a bin assembly where the hinge is located in a "cut out" and its sidewalls are described as being in a "generally common plane," which Petitioner contended discloses a flush configuration. However, to the extent that teaching is insufficient, Frazier explicitly teaches creating "voids" in a bin sidewall to receive a pivot mechanism. Frazier’s stated purpose for these voids is to "maximize the internal width (storage volume)" of the bin by ensuring the hinge mechanism does not protrude into the storage space.
  • Motivation to Combine: The motivation stems from the shared, explicit goal of both references to maximize bin storage capacity. A POSITA, recognizing Savian's objective, would have been motivated to incorporate Frazier’s simple and effective solution of using a "void" to fully recess the hinge mechanism. This modification would have been an intuitive design choice to ensure Savian's hinge was completely flush with the sidewall, thereby achieving the desired maximization of storage space.
  • Expectation of Success: Success would have been highly predictable. Applying Frazier's teaching of recessing a hinge into a void within Savian’s similar pivot-bin design is a simple mechanical adaptation. Petitioner contended this would be a mere workshop improvement within the grasp of a POSITA to achieve the known benefit of increased storage capacity.

4. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv): Petitioner argued against discretionary denial, asserting that the co-pending litigation was in its early stages with no substantive orders issued. Petitioner offered a stipulation to not pursue any IPR grounds in the district court if review were instituted, thus mitigating concerns of parallel proceedings. Furthermore, Petitioner argued that potential trial date postponements in the litigation favored institution and that the merits of the petition were strong, as the primary prior art references and combinations were not considered during the original prosecution.
• §325(d): Petitioner contended that denial under §325(d) was not warranted because the Examiner did not previously consider the primary references (Rheaume and the specific Savian WO publication) or the asserted combinations. Petitioner argued the Examiner erred during prosecution by narrowly interpreting a different Savian reference and failing to appreciate its disclosure of a flush hinge assembly, particularly the teaching that sidewall components were "positioned in a generally common plane."

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 10,760,315 as unpatentable.