PTAB

IPR2022-00411

Thor Industries Inc v. Grand Design RV LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Toy Hauler Recreational Vehicle
  • Brief Description: The ’690 patent discloses a toy hauler recreational vehicle (RV) with a multi-level floor plan comprising three distinct living areas. The design is built on a ladder chassis featuring specific cross-member structures, including trusses and beams with different vertical profiles, to create a drop-frame section supporting a rear garage area.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 6-9, 11, and 13 by Raptor

  • Prior Art Relied Upon: Raptor (a 2013 toy hauler brochure).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the Raptor brochure discloses a commercial fifth-wheel toy hauler that contains every element of the challenged claims. The brochure illustrates a multi-level floor plan with an elevated front bedroom (first living area), a lower central living/kitchen area (second living area), and a rear garage containing a vertically movable electric bed on a platform (third living area). Petitioner asserted that the required chassis structure—including longitudinal I-beams, cross-member trusses under the central area, and a lower cross-member beam supporting an inclined "beaver tail" garage floor—is either expressly shown or inherently present in the disclosed product. Dependent claims were allegedly met by features such as the movable bed platform and a fold-down ramp door.

Ground 2: Anticipation of Claims 1, 2, 6-9, and 11 by the ’545 Patent

  • Prior Art Relied Upon: Patent 4,869,545 ("'545 patent").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted the ’545 patent, which discloses a toy hauler travel trailer, anticipates the claims. The ’545 patent allegedly discloses three living areas (a bedroom, kitchen, and a convertible couch/dining area), a garage, and a chassis that meets all limitations of claim 1. Petitioner contended the chassis includes side rails, a forward cross member ("truss"), and a rear cross member ("beam") with a depressed upper surface to accommodate a keel roller. This configuration allegedly satisfies the claim requirement for a beam having an upper surface lower than that of the truss. Dependent claims were argued to be met by the ’545 patent's disclosure of a couch on a vertically movable platform.

Ground 3: Obviousness of Claims 1, 2, 6-9, 11, and 13 over Raptor, New Vision, and Torque

  • Prior Art Relied Upon: Raptor (a 2013 brochure), New Vision (a 2008 brochure), and Torque (a 2014 brochure).

  • Core Argument for this Ground:

    • Prior Art Mapping: In the alternative to its inherency arguments for Ground 1, Petitioner argued it would have been obvious to combine Raptor with express teachings from other prior art. New Vision was cited to expressly teach the "beaver tail" floor structure and its supporting beams having a lower profile than other chassis cross-members. Torque was cited to expressly teach a vertically movable living area, consisting of a bed on a large platform, situated over a garage to provide greater clearance when raised.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Raptor with New Vision’s beaver tail design because it was a common, commercially accepted, and cost-effective method for achieving a low ramp angle. A POSITA would combine Raptor with Torque’s movable bed system to incorporate a proven design that provides a larger, more functional living space over the garage, using a standard vertical rail system that is compatible with Raptor’s layout.
    • Expectation of Success: Petitioner argued success was predictable, as these were well-known features in the RV industry. Combining them represented a predictable variation of known elements to yield predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of the ’545 patent with the ’037 patent and the Raptor brochure, relying on similar theories of combining known chassis designs and features.

4. Key Claim Construction Positions

  • Petitioner argued that no explicit claim construction was required, as the terms hold their plain and ordinary meaning to a POSITA in the RV industry.
  • However, Petitioner noted that under the doctrine of linguistic differentiation, a POSITA would understand the terms "beam" and "truss" as used in claim 1 to refer to structurally different cross members. This distinction was presented as central to its arguments regarding chassis construction, even while acknowledging that the terms were often used interchangeably in the art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 6-9, 11, and 13 of the ’690 patent as unpatentable.