PTAB

IPR2022-01015

Leggett & Platt Inc v. AlfMeier PräzisION Se

Key Events

Petition

petition

Title: Actuator for Pneumatic Valve Using Shape Memory Alloy
Brief Description: The ’219 patent relates to an actuator for a pneumatic valve, primarily for controlling air bladder adjustable supports in vehicle seats. The actuator uses a U-shaped shape memory alloy (SMA) wire that, when heated by an electric current, contracts to operate a valve element, thereby opening or closing a valve opening.

Prior Art Relied Upon: Conti Temic (German Publication No. DE102016219342.2).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Conti Temic, which discloses an SMA-actuated pneumatic valve for vehicle seats, teaches every limitation of the challenged claims. The core of the argument rested on the Patent Owner's admission during prosecution of the corresponding German application (DE089) that Conti Temic disclosed all limitations of a nearly identical claim 1. Petitioner mapped Conti Temic’s base plate (201), valve flap (8), U-shaped SMA wire (7), and connecting components (circuit board 17, contact pins 15, crimp elements 20) directly to the elements of claim 1 of the ’219 patent. Specifically for claim 5, Petitioner asserted that Conti Temic’s actuating element is not conductive and the SMA wire ends are connected to separate contacts, meeting the second alternative limitation.
- Key Aspects: Petitioner contended the U.S. examiner misunderstood Conti Temic during prosecution by incorrectly finding it lacked a "one connecting element," a misunderstanding exacerbated by the Patent Owner's failure to disclose its contrary admission in the German proceeding.

Prior Art Relied Upon: Kongsberg (U.S. Publication No. 2018/0038514A1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kongsberg, which was not considered during prosecution, discloses every limitation of the challenged claims. This ground relies on Petitioner's alternative claim construction of "one actuating element" as a structural term rather than a means-plus-function term. Kongsberg discloses a multi-valve SMA assembly for vehicle seats, teaching a base plate (mounting bar 20), an actuating element (valve element 16), a U-shaped SMA wire (21) wrapped around the actuating element, and a connecting element (printed circuit board 22) that supplies current to two fixation points of the SMA wire. Petitioner also asserted that Kongsberg’s disclosure of a unitary housing for multiple valves anticipates claims 12 and 13, and its disclosure of common pressure and venting manifolds anticipates claims 14 and 15.

Prior Art Relied Upon: Conti Temic and Kongsberg.
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that since Conti Temic anticipates claims 1, 3, 5-6, 9, and 12, those claims are necessarily obvious. For the remaining claims (e.g., 13-17), Petitioner contended that Conti Temic teaches a self-contained SMA valve element, while Kongsberg teaches arranging multiple, similar valve elements in a side-by-side configuration within a single unitary housing to control multiple air bladders.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings to implement Conti Temic’s compact and efficient valve design into Kongsberg’s established multi-valve housing arrangement. This combination would achieve a predictable, modular, and efficient system for controlling multiple comfort features in a vehicle seat, an express goal of both references.
- Expectation of Success: Given the structural and functional similarities between the valve elements in both references, a POSITA would have had a high and reasonable expectation of success in integrating Conti Temic's valve into Kongsberg's multi-valve housing to create the claimed arrangement.
Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 6 based on Kongsberg in view of Dankbaar (WO 2015/086088), arguing Dankbaar taught adding connectors to Kongsberg's base plate to fix a printed circuit board in place.

"one actuating element": Petitioner argued this term should be construed as a means-plus-function limitation under §112(f). This position was based on the generic nature of the word "element" and the fact that the Patent Owner acquiesced to the examiner's means-plus-function construction during prosecution. The corresponding structure would be "the elongated bent or step structure having either an elastic middle section or a hinge."
- As an alternative, Petitioner proposed a plain and ordinary meaning construction: "a movable part or assemblage of parts of a valve that opens and closes a valve opening." This alternative construction was central to the anticipation arguments based on Kongsberg.
"one connecting element": Petitioner argued this term should be construed to mean an "assemblage of components conductively connected together to apply electric current to an SMA element." This construction was supported by the patent specification, which describes multiple components comprising the element (e.g., PCB, crimp connector), and by the Patent Owner’s own admission during foreign prosecution that Conti Temic’s multi-part circuit board, pins, and crimps met this limitation.

Petitioner argued that discretionary denial under §325(d) would be inappropriate because the grounds presented are not the same or substantially the same as those considered during prosecution. Although the examiner reviewed Conti Temic, Petitioner contended the examiner misunderstood its teachings regarding the "connecting element." Critically, the Patent Owner failed to disclose its own admission from a parallel German prosecution that Conti Temic did, in fact, teach this element. Furthermore, the primary references for Grounds 2, 3, and 4 (Kongsberg and Dankbaar) were never before the examiner.

Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-6, 9, 12-17, 19, and 21 of the ’219 patent as unpatentable.