- Sharkninja Operating LLC / Sharkninja Management LLC et al. v. Irobot CorporationAll claims unpatentablePTAB · Nov 1, 2022 · PGR2021-00079 · APJ Jason W Melvin · PGR · Final written decision
Claims 1–14 are unpatentable under § 112(a) because the specification does not describe a floor plan that distinguishes carpeted from noncarpeted areas.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“II. ANALYSIS A. LEVEL OF ORDINARY SKILL IN THE ART Petitioner proposes that a person of ordinary skill “would have at least a bachelor’s degree in mechanical engineering or electrical engineering or a closely related field and at least one year of experience in the design and implementation of robotics and embedded systems.” Pet. 11 (citing Ex. 1003 ¶ 18). Patent Owner does not dispute this definition. See generally PO Resp. We adopt Petitioner’s proposed level of ordinary skill as it appears to be consistent with the level of skill reflected by the specification.” slip op. at 6
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“The claim language establishes two distinct (and mutually exclusive) types of areas: “areas with carpeting” and “areas that do not have carpeting.” Ex. 1001, 19:17–:18, 20:12–:13. Those areas, as defined, provide the antecedent basis for the later claim language requiring the areas be “identifi[ed]” in the displayed floor plan (“an identification of the areas with carpeting and the areas that do not have carpeting”). We conclude that identifying—ascertaining the identity of—two distinct types of areas requires an indication to distinguish one type of area from the other. That conclusion flows from the claim language that establishes two types of areas and then refers back to those types when requiring a floor plan that includes identification of them. Indeed, the claim as a whole depends on a distinction between the two types of areas. After establishing that the map used for navigation indicates the two types of areas, the claim requires that the robot sense its location relative to the areas and adjust its cleaning behavior based on that location. Id. at 19:16–:25, 20:11–:19. Patent Owner’s proposed construction—that “identification of the areas with carpeting and the areas that do not have carpeting” does not require distinguishing between the two types of areas—would contravene the claim’s consistent approach to the areas.3” slip op. at 8
- Disclosure Requirements (§112) › Written description (Ariad)Written description inadequateUnpatentable
“Under the construction adopted above, we conclude the specification lacks written-description support for a “displayed floor plan comprising an identification of the areas with carpeting and the areas that do not have carpeting.” As discussed, our construction requires that the floor plan itself allow users to distinguish between areas with carpeting and areas that do not have carpeting. Neither Figure 22 nor any textual description supports that capability, and Patent Owner does not argue otherwise. See PO Resp. 18–23.” slip op. at 13
Patent outcomesUS 10,990,110 unpatentableClaim construction§ 112 disclosurecites PhillipsPatents in suitUS 10,990,110 - PTAB · Sep 7, 2021 · PGR2021-00065 · APJ Terrence W Mcmillin · PGR · Institution
The Board denied PGR on all challenged claims because the petition did not show unpatentability and the claims were not PGR-eligible.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“Under 35 U.S.C. § 112(a), the patent must enable a skilled artisan to practice the invention without undue experimentation. Wyeth & Cordis Corp. v. Abbott Labs, Inc., 720 F.3d 1380, 1384 (Fed. Cir. 2013). “An enablement analysis begins with the disclosure in the specification.” Sitrick v. Dreamworks, LLC, 516 F.3d 993, 1000 (Fed. Cir. 2008). “It is the specification, not the knowledge of one skilled in the art, must supply the novel aspects of an invention in order to constitute adequate enablement.” Genentech Inc. v. Novo Nordisk A/S, 108 F.3d 1361, 1366 (Fed. Cir. 1997).” slip op. at 11
- Disclosure Requirements (§112) › Written description (Ariad)Written description adequateNot shown unpatentable
“Claim 1 recites an apparatus and requires the receiving system be configured to “autonomously identify a hot spot,” which requires that the device perform the action itself. Thus, the claim language excludes a user performing the claimed identification.6 The question is whether the Specification supports that language. Patent Owner argues that the language in the Specification—“pre- identified . . . prior to operating the robotic device”—includes “during a prior operation of the robot (e.g., during a past cleaning operation).” Prelim. Resp. 33–35 (citing Ex. 1001, 27:42–28:11). We determine that this meaning is supported by the Specification. As Patent Owner contends, the Specification discloses identifying “hot spot” cells during an operation and using those cells to maneuver the device both during the same operation and also in a later operation. Id. Thus, a reasonable interpretation of “prior to operating the robotic device” includes “during a past cleaning mission of the 6 In an Applicant-Initiated Interview Summary, the Examiner wrote that he and the Applicant’s attorney “discussed, including specifying that the identify step is performed autonomously, or without human input.” Ex. 1001, 212 (emphasis added). In the Applicant’s attorney’s interview summary of the same conversation that was included with the claim amendment adding the “autonomously identify” limitation, the Examiner’s characterization of the meaning of “autonomously” was not disputed. Id. at 225. The Applicant relied on the addition of the “autonomously identify” limitation to the claims to distinguish the cited art but did not discuss its meaning. Id. at 226 (“Allen fails to describe autonomously identifying a hot spot. Independent claim 13 [issued claim 1] is therefore allowable over Taylor and Allen.”). However, both Petitioner and Patent Owner acknowledge that Allen (US Patent No. 5,995,884) discloses a user selecting a spot or zone. Pet. 25, Prelim. Resp. 41 (citing Ex. 1027 (Allen), 47:1–28). cleaning apparatus,” because such an interpretation is consistent with the Specification.” slip op. at 18
- Disclosure Requirements (§112) › Enablement (Wands, Amgen full scope)EnabledNot shown unpatentable
“With specific regard to enablement, the Petitioner argues: The ’517 patent does not enable one skilled in the art to practice the inventions of claims 1, 4, and 15 because it does not provide any working example or guidance for performing the “autonomously identify” limitations—the very limitations that were allegedly novel over the prior art, resulting in the grant of the ’517 patent. Cowan [Ex. 1003], ¶¶ 90-91. Here, the ’517 patent’s complete lack of direction to the skilled artisan for the allegedly novel feature renders the claims invalid for lack of enablement. Pet. 51. Petitioner also argues that “the ’517 patent provides no working examples or guidance teaching one skilled in the art how to” “autonomously identify a hot spot or predefined zone in a map prior to initiation of a cleaning mission” and that “the ’517 patent does not even provide a ‘conceptual’ figure or description of how a receiving system performs the ‘autonomously identify’ limitation.” Id. at 53, 55. And still further, Petitioner argues that “[t]he ’517 patent’s complete failure to provide any example, direction, or guidance to the skilled artisan is dispositive and renders the claims invalid for lack of enablement.” Id. at 55. For factual support of its enablement argument, Petitioner refers back to its explanation as to how the ’517 patent fails to meet the written description requirement. Id. at 53. We reject Petitioner’s enablement ground for the same reasons we reject its written description ground. Based on the showing in the Petition, we are not persuaded that the Specification of the ’517 patent “does not provide any working example or guidance for performing the ‘autonomously identify’ limitation” or that there is no disclosure adequate to “teach[ ] one skilled in the art how to” “autonomously identify a hot spot or predefined zone in a map prior to initiation of a cleaning mission.” To the contrary, for the reasons detailed above, we determine that the “autonomously identify” limitations are adequately supported by the Specification of the ’517 patent and that the Specification of the ’517 patent would enable a skilled artisan to make and use the invention.” slip op. at 22
- Skill levelSkill level petitioner adoptedDecided for petitioner
“A skilled artisan would have had at least a four-year degree in mechanical engineering or electrical engineering or a closely related field and at least one year of experience in the design and implementation of robotics and embedded systems. Cowan [Ex. 1003], ¶¶ 17-19. Additional education could substitute for professional experience and vice versa.” slip op. at 8
Claim construction§ 112 disclosurecites NautilusPatents in suitUS 10,813,517 - Becton, Dickinson And Company v. Baxter Corporation EnglewoodAll claims unpatentablePTAB · Apr 29, 2020 · IPR2019-00121 · APJ Paul J Korniczky · IPR · Final written decision
Claims 1–19 are unpatentable; the revised motion to amend substitute claims 20–38 is denied for lack of written-description support and enablement.
RulingsFinal written decision- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable
“Accordingly, “the dispositive question regarding anticipation [i]s whether one skilled in the art would reasonably understand or infer from the [prior art reference’s] teaching that every claim element was disclosed in that single reference.” Dayco Prods., Inc. v. Total Containment, Inc., 329 F.3d 1358, 1368 (Fed. Cir. 2003).” slip op. at 17
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“endeavor at the time of invention and addressed by the patent can provide a reason for combining the elements in the manner claimed.” Id. at 420. Accordingly, a party that petitions the Board for a determination of unpatentability based on obviousness must show that “a skilled artisan would have been motivated to combine the teachings of the prior art references to achieve the claimed invention, and that the skilled artisan would have had a reasonable expectation of success in doing so.” In re Magnum Oil Tools Int’l, Ltd., 829 F.3d 1364, 1381 (Fed. Cir. 2016) (internal quotations and citations omitted).” slip op. at 18
- Obviousness (§103) › Objective indicia / secondary considerationsDecided for petitioner
“c. Conclusion Petitioner has shown by a preponderance of the evidence that” slip op. at 60
- 112 supportMotion to amend, deniedDenied
“claims must meet the statutory requirements of 35 U.S.C. § 316(d) and the procedural requirements of 37 C.F.R. § 42.121. Lectrosonics, Paper 15 at 4– 8. Accordingly, Patent Owner must demonstrate: (1) the amendment proposes a reasonable number of substitute claims; (2) the amendment responds to a ground of unpatentability involved in the trial, (3) the proposed claims are supported in the original disclosure (and any earlier filed disclosure for which the benefit of filing date is sought); and (4) the amendment does not seek to enlarge the scope of the claims of the patent or” slip op. at 83
Patent outcomesUS 9,474,693 unpatentable§ 102 anticipation§ 103 obviousness§ 112 disclosurecites KSR · GrahamPatents in suitUS 9,474,693 - Lippert Components, Inc. v. Days CorporationAll claims unpatentablePTAB · Sep 24, 2019 · IPR2018-00777 · APJ George R Hoskins · IPR · Final written decision
Claims 12 and 13 are unpatentable as anticipated by Uriarte and obvious over Uriarte and Fukumoto; the motion to amend claims 15 and 16 is denied.
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“nothing in the claim language itself that requires the sensor to be aligned directly along the vehicle’s longitudinal and lateral axes. Rather, the Sensor Limitations more broadly require that the sensor “sense[s] pitch and roll of the vehicle relative to a reference level plane” to produce a signal “representing the vehicle pitch and roll.” Ex. 1001, 12:61–64 (claim 12), 13:16–19 (claim 13). Any sensor that determines the relative positioning of the vehicle’s longitudinal-lateral plane with respect to the reference level plane will thereby “sense” the pitch and roll of the vehicle, to produce a signal “representing” the pitch and roll.” slip op. at 12
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“3. Remaining Claim Terms No further explicit construction of any claim term is needed to resolve the issues presented here. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co. Ltd., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (per curiam) (claim terms need to be construed “only to the extent necessary to resolve the controversy”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).” slip op. at 16
- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Level of Ordinary Skill in the Art Petitioner contends a person having ordinary skill in the art pertaining to the ’693 patent “would have either a bachelor’s degree in engineering, preferably mechanical or electrical, or at least five years of work experience in the field of vehicle leveling systems and related equipment.” Pet. 10; Ex. 1006 ¶ 18. “Patent Owner accepts this level,” despite the slightly different formulation offered by Dr. Sturges. PO Resp. 11; Ex. 2004, 5. We determine that the level of ordinary skill proposed by Petitioner, and accepted by Patent Owner, is consistent with the ’693 patent and the prior art of record. We, therefore, adopt that level in the present Decision. See Okajima v. Bourdeau, 261 F.3d 1350, 1354–55 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d 1573, 1579–80 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978).” slip op. at 16
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“We determine it would not require undue experimentation to find the proper leveling condition to use in Uriarte for stopping an automatic leveling operation, because Uriarte itself provides the answer: it is when Clr = Crf and Crr = Clf. Ex. 1004, 7:67–8:16; Ex. 1006 ¶¶ 41–43; Ex. 1015 ¶ 21. Given that disclosure, a person of ordinary skill in the art would resolve the later nonsensical disclosure as intending to state the vehicle is level when Clr/Crf = 1 and Crr/Clf = 1, without any experimentation at all, much less undue experimentation. Ex. 1015 ¶ 21. Dr. Sturges’s failure to address the first disclosure in Uriarte in his Declaration, when reaching his conclusion that “[t]here are no other disclosures in Uriarte indicating a level condition, except by manual ‘feel’ and control,” renders that conclusion unreliable. Ex. 2004, 8 (emphasis added). Moreover, when pressed during deposition, Dr. Sturges testified a person of ordinary skill in the art would understand Uriarte’s vehicle 10 is “at least near level” “when the capacitors show equal value.” Ex. 1013, 71:9–72:3. Thus, we determine Petitioner has met its burden to establish, by a preponderance of the evidence, that a person of ordinary skill in the art would be able to carry out an automatic leveling operation based on the Uriarte disclosure. In particular, the stopping condition indicating the vehicle is level occurs when Clr = Crf and Crr = Clf, or equivalently when Clr/Crf = 1 and Crr/Clf = 1.” slip op. at 23
Patent outcomesUS 6,619,693 unpatentableClaim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites KSR · GrahamPatents in suitUS 6,619,693 - Shinn Fu Company Of America, Inc. / Shinn Fu Corporation v. The Tire Hanger CorporationAll claims unpatentablePTAB · Apr 22, 2016 · IPR2015-00208 · APJ Carl M Defranco · IPR · Final written decision
Claims 1–5 are unpatentable under the stated §102 and §103 grounds; the motion to amend is granted, and substitute claims 6–10 are patentable over the prior art of record.
RulingsFinal written decision- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for patent owner
“that requires construction beyond what was done at the time of institution. Specifically, substitute claim 6 replaces the term “placing” with the new term “hanging.” We see no reason to interpret “hanging” apart from its plain and ordinary meaning. Thus, consistent with its dictionary definition, we construe “hanging” as “to fasten to some elevated point without support from below.” Merriam-Webster’s Collegiate Dictionary, 10th ed. (2000) (emphasis added). The substitute claims also use the transitional phrase “consisting essentially of,” which Shinn Fu argues should be construed presumptively as equivalent to “comprising.” Opp. 3–4 (citing Manual of Patent Examining Procedure § 2111.03). Tire Hanger argues for a narrower construction because, in its view, any additional steps would “materially change the basic and novel characteristics of the claimed method,” pointing to column 1, lines 26–59, of the ’897 patent. Reply 3 (citing Ex. 1002). We are not persuaded that a skilled artisan would view adding a simple extra step, such as raising the wheel to trip a safety latch while removing the wheel from the support arm (see, e.g., Ex. 1012, Fig. 2, 2:61–70), as materially changing the basic objective of the claimed invention in terms of being “easily accessible within the work space,” “remain[ing] out of the way,” and “not requir[ing] workers to bend over,” as made clear in the specification. Ex. 1002, 1:54–59. Thus, we determine that the phrase “consisting essentially of” should be construed as equivalent to “comprising,” so long as any additional unlisted steps “do not have a material effect on the basic and novel characteristics” of the claimed method. PPG Indus., Inc. v. Guardian Indus. Corp., 156 F.3d 1351, 1354–55 (Fed. Cir. 1998).” slip op. at 6
- ScopeMotion to amend, grantedDecided for patent owner
“enlarge the scope of the claims of the patent or introduce new matter.” Shinn Fu argues that claim 9, which Tire Hanger proposes as a substitute for original claim 4, impermissibly enlarges claim scope by deleting the requirement that the individual “does not have to bend significantly at the waist to guide the wheel over the hanger.” That omission, in Shinn Fu’s view, makes claim 9 broader, not narrower, because it infers that an individual may indeed be bending over while handling the wheel on the support arm. Id. at 21–22. We disagree. Claim 9 depends from substitute claim 6, which recites that, when the vehicle is elevated, “the human can remove the wheel without bending over,” and when the wheel is on the support arm, the wheel can be removed “without the human bending over.” Thus, as a matter of dependency, claim 9 incorporates the limitations from claim 6 that entail handling the wheel on the support arm “without the human bending over.” That an amendment simply removes a limitation from a dependent claim and adds it 11 Shinn Fu also argues that the Motion to Amend should be denied because Tire Hanger failed to comply with its obligation of first “conferring with the Board” before filing the Motion, as required by 37 C.F.R. § 42.121(a). Opp. 2. We are not inclined to deny the Motion to Amend on this procedural ground. Before filing the Motion, Tire Hanger’s legal representative contacted the Board to seek clarification on whether a conference call was necessary and was advised it was not. Ex. 2008 ¶¶ 1–4. As such, we are satisfied that Tire Hanger fulfilled its obligation of conferring with the Board. to the claim from which it depends does not mean that the amendment has broadened the scope of the dependent claim from which the limitation has been removed. As such, we are not persuaded by Shinn Fu’s argument. Rather, we find that Tire Hanger’s amendment does not violate the prohibition on enlarging claim scope.” slip op. at 17
- Disclosure Requirements (§112) › Written description (Ariad)Written description adequateDecided for patent owner
“support for its use of the term “human” in the proposed substitute claims. Opp. 23. According to Shinn Fu, the specification only refers to a “worker” performing the steps of removing and replacing the vehicle’s wheel, not a “human.” Id. In Shinn Fu’s view, by using the term “human,” rather than “worker,” in the substitute claims, Tire Hanger has broadened the claims to include “such embodiments or species as newborns, toddlers, children, disabled people, and decrepit people,” for which the specification purportedly lacks written description support. Id. We construe claims based on a reasonable interpretation in light of the specification and prosecution history. Shinn Fu’s proposed construction is unreasonable. The specification of the ’897 patent speaks expressly in terms of “individuals in handling tire/wheel assemblies when mounting and removing them from vehicles.” Ex. 1002, 1:41–43 (emphasis added). Likewise, the original claims refer to “a person” and “an individual” in describing removal of the wheel from the vehicle. Id. at 8:24–30. Those disclosures provide clear support for use of the term “human” in the substitute claims. Thus, we are not persuaded that Tire Hanger’s proposed amendment of the claims lacks written description support.” slip op. at 18
- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableMotivation not foundNot shown unpatentable
“Komorita, on the other hand, presents a different picture because it clearly discloses what is called a “tire hanger” on an automotive lift. Ex. 1004, Abstract, Fig. 29. Even so, Tire Hanger asserts that the claimed method is patentable over Komorita because Komorita “merely teaches placing a wheel in a cradle” for holding the wheel from below, not “hanging the wheel on the support arm” or “guiding a hole in the wheel over the support arm,” as required by substitute claim 6. Mot. 13–14; Reply 9; Tr. 30–31. Thus, the question arises as to whether “hanging” a wheel on “a support arm,” per claim 6, is patentably distinct from supporting the wheel from below in a cradle, per Komorita. We conclude it is. To begin, we previously construed the term “hanging” to mean “to attach or place something so that it is held up without support from below.” See section III.A.2 above. Notwithstanding that Komorita is labeled as a “tire hanger,” it is clear from Komorita that the structure actually disclosed is not a hanger but a cradle that supports the wheel from below. Ex. 1004 ¶¶ 113, 114, Fig. 29. Thus, given our claim construction, Komorita does not appear to meet the “hanging” limitation of substitute claim 6. Moreover, the ’897 patent expressly distinguishes the claimed invention from cradle-like structures, such as that of Komorita. Notably, the ’897 patent describes various embodiments of hangers, each of which is “adapted to fit inside the rim of the tire/wheel assembly.” Ex. 1002, 6:17–21 (emphasis added). Figure 6 of the ’897 patent depicts one such embodiment with the hanger inside of the tire/wheel assembly. The ’897 patent goes on to state that “other structures may be used” to support a tire/wheel assembly, such as “an arcuate cradle” configured “to receive a tire therein . . . to rest the tire in the cradle.” Id. at 6:22–24 (emphases added). Further, another embodiment of a cradle is described that includes “a plurality of arms . . . adapted to receive and hold a tire therein,” and where the tire “rests in the cradle.” Id. at 6:35–37 (emphases added). A plain reading of the ’897 patent reveals that the hanger structures (id. at 6:15–21) are a separate embodiment from the cradle structures (id. at 6:22–42) because they are disclosed as “other structures” and because their modes of retaining the tire/wheel assembly are different. The hanger structure allows the tire/wheel assembly to hang thereon, and includes a specific structure adapted to fit inside a hole in the tire rim. Id. at 6:15–21. In contrast, the cradle structure receives a tire therein, and comprises a structure adapted to fit around and below the outside of the tire. Id. at 6:22–42. As such, we find that there is a structural distinction between hangers and cradles. Although the ’897 patent discloses both hangers and cradles, proposed” slip op. at 22
Patent outcomesUS 6,681,897 unpatentableClaim construction§ 103 obviousness§ 112 disclosurePatents in suitUS 6,681,897 - TRW Automotive U.S. LLC v. Magna Electronics Inc.Institution deniedPTAB · Dec 21, 2015 · IPR2015-01436 · APJ Robert J Weinschenk · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood that claims 78–80 and 83–89 were unpatentable under § 103.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“Pet.”) requesting inter partes review of claims 78–80 and 83–89 of U.S. Patent No. 8,692,659 B2 (Ex. 1002, “the ’659 patent”). Magna Electronics Inc. (“Patent Owner”) filed a Preliminary Response (Paper 6, “Prelim. Resp.”) to the Petition. An inter partes review may not be instituted “unless . . . there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a). For the reasons set forth below, Petitioner does not demonstrate a reasonable likelihood of prevailing in showing the unpatentability of claims 78–80 and 83–89 of the ’659 patent. Accordingly, the Petition is denied, and no trial is instituted. slip op. at 2
- Disclosure Requirements (§112) › Written description (Ariad)Written description adequateDecided for patent owner
“written description of an attachment member attached to a vehicle windshield and local to a mirror mounting button, as recited in the challenged claims. Pet. 10–13 (citing Ex. 1913 ¶¶ 31–33, 40, 44–46). Petitioner’s argument is not persuasive. The ’287 patent discloses the following: As best understood from FIG. 16B, extension 8513 of header console 8512 extends downwardly behind the upper portion of windshield W (such portion of windshield W which typically includes a shadeband element as known in the art) and includes a forked portion 8513a, such as an inverted V-shaped or U-shaped portion, which straddles a mirror mounting button 8536 that is mounted to windshield W. Optionally, the downwardly extending portion of header/header console 8512 may be mounted to the inner surface of windshield W, such as by an adhesive or may be releasably, mechanically attached such as by being received by and/or supported by one or more attaching members adhered to the inner surface of the windshield, such as by attachment members, including rails, channels, or the like. Ex. 1012, col. 28, ll. 15–28 (emphasis added). The above disclosure in the ’287 patent describes a console that straddles (and thus is local to) a mirror mounting button and is mounted to a vehicle windshield using attachment members, such as rails or channels. Id. As such, the above disclosure in the ’287 patent is sufficient to show that the inventors had possession of the claimed attachment member. See Ariad Pharm., Inc. v. Eli Lilly and Co., 598 F.3d 1336, 1351 (Fed. Cir. 2010).” slip op. at 7
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentable
“camera.” Ex. 1002, col. 53, l. 63–col. 54, l. 2. Petitioner argues that the housing in Klappenbach corresponds to the claimed structure configured to accommodate a forward facing camera, and that the vehicle headlight dimming control in Schofield includes the claimed forward facing camera. Pet. 39–42. The housing in Klappenbach is designed specifically to accommodate transmitter 10 and receiver 11, as shown in Figure 1. Ex. 1010, col. 3, ll. 46–67, Fig. 1. Petitioner does not provide a specific explanation or identify specific evidence showing that the housing in Figures 1 and 2 of Klappenbach also is configured to accommodate a forward facing camera. Pet. 39–42. Therefore, on this record, Petitioner has not shown sufficiently that the combined teachings of Blank, Schofield, Klappenbach, and Carter would have taught or suggested the limitation “said structure is configured to accommodate a forward facing camera” to one of ordinary skill in the art.” slip op. at 11
§ 103 obviousness§ 112 disclosurePatents in suitUS 8,692,659
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.