Filed on behalf of: Canon Kabushiki Kaisha
`
`Paper No. ____
`Filed: August 29, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`General Plastic Industrial Co., Ltd.
`Petitioner,
`v.
`Canon Kabushiki Kaisha
`Patent Owner.
`________________
`
`Case IPR2016-01361
`U.S. Patent 8,909,094
`________________
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`
`

`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION ...........................................................................................1
`
`THE PETITION SHOULD BE DENIED UNDER 35 U.S.C.
`§ 314(a)............................................................................................................5
`
`III.
`
`TECHNOLOGICAL BACKGROUND ........................................................10
`
`A.
`
`B.
`
`The ’094 Patent ...................................................................................10
`
`Yasuda.................................................................................................24
`
`IV.
`
`V.
`
`PERSON OF ORDINARY SKILL ...............................................................27
`
`CLAIM CONSTRUCTION ..........................................................................28
`
`A.
`
`B.
`
`C.
`
`D.
`
`“A toner supply container”..................................................................29
`
`“a rotational force receiving portion …” ............................................30
`
`“displacing force receiving portion …” and “projecting
`portion …”...........................................................................................33
`
`“configured and positioned to receive a rotational drive
`force …”..............................................................................................35
`
`VI.
`
`LEGAL STANDARDS .................................................................................39
`
`VII. YASUDA DOES NOT RENDER OBVIOUS ANY OF THE
`CHALLENGED CLAIMS ............................................................................40
`
`A.
`
`B.
`
`C.
`
`Petitioner Fails to Show that Yasuda Discloses or
`Suggests a Coupling Portion “Configured and Positioned
`to Receive a Rotational Drive Force” .................................................40
`
`Petitioner Fails to Show that Yasuda Discloses or
`Suggests the “Rotational Force Receiving Portion”
`Required by Claims 1 and 11 ..............................................................45
`
`Petitioner Fails to Show that Yasuda’s Alleged
`“Engaging Portion” Is Displaceable with the Alleged
`“Supporting Portion”...........................................................................47
`
`i
`
`

`
`D.
`
`E.
`
`A.
`
`B.
`
`Petitioner Fails to Show that It Would Have Been
`Obvious to Modify Yasuda’s Alleged “Displacing Force
`Receiving Portion” or “Projecting Portion” to Have the
`Required Relative Radial Dimensions ................................................49
`
`Petitioner Fails to Show that Yasuda Discloses or
`Suggests a Coupling Portion Including “At Least Two
`Supporting Portions Provided on the Sealing Portion at
`Diametrically Opposed Positions” ......................................................56
`
`Petitioner Fails to Show that Yasuda Discloses or
`Suggests a Sealing Member Including a “Sealing Portion
`Provided at a Side Adjacent the Container Body” and a
`“Coupling Portion Provided at a Side Remote from the
`Container Body”..................................................................................59
`
`Petitioner Fails to Show that Yasuda Discloses or
`Suggests All the Limitations of Claims that Depend from
`Claims 1 and 11...................................................................................63
`
`VIII. CONCLUSION..............................................................................................64
`
`ii
`
`

`
`TABLE OF AUTHORITIES
`
`Cases
`Aspex Eyewear, Inc. v. Marchon Eyewear, Inc.,
`672 F.3d 1335 (Fed. Cir. 2012) .....................................................................37
`
`Cuozzo Speed. Techs., LLC v. Lee,
`136 S. Ct. 2131 (2016)...............................................................................5, 28
`
`Ex parte Icon Health & Fitness, Inc.,
`496 F.3d 1374 (Fed. Cir. 2007) .....................................................................32
`
`Gardner v. TEC Sys., Inc.,
`725 F.2d 1338 (Fed. Cir. 1984) .............................................................. 53, 63
`
`Graham v. John Deere Co. of Kansas City,
`383 U.S. 1 (1966)...........................................................................................39
`
`Hartness Int’l Inc. v. Simplimatic Eng’g Co.,
`819 F.2d 1100 (Fed. Cir. 1987) .....................................................................63
`
`In re Giannelli,
`739 F.3d 1375 (Fed. Cir. 2014) ........................................................ 32, 38, 42
`
`In re Gordon,
`733 F.2d 900 (Fed. Cir. 1984) .......................................................................54
`
`In re Man Machine Interface Techs. LLC,
`822 F.3d 1282 (Fed. Cir. 2016) .....................................................................28
`
`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007).......................................................................................39
`
`Microsoft Corp. v. Proxyconn, Inc.,
`789 F.3d 1292 (Fed. Cir. 2015) .....................................................................28
`
`Straight Path IP Grp., Inc. v. Sipnet EU S.R.O.,
`806 F.3d 1356 (Fed. Cir. 2015) .....................................................................36
`
`Tec Air, Inc. v. Denso Mfg. Mich. Inc.,
`192 F.3d 1353 (Fed. Cir. 1999) .....................................................................54
`
`iii
`
`

`
`Trivascular, Inc. v. Samuels,
`812 F.3d 1056 (Fed. Cir. 2016) .....................................................................36
`
`Statutes
`
`35 U.S.C. § 314(a) ........................................................................................ 2, 3, 5, 8
`
`35 U.S.C. § 316(a)(11)...............................................................................................5
`
`Regulations
`
`37 C.F.R. § 42.65(a).............................................................................. 40, 48, 53, 64
`
`37 C.F.R. § 42.100(b) ..............................................................................................28
`
`37 C.F.R. § 42.104(b)(1)............................................................................................4
`
`37 C.F.R. § 42.104(b)(3)..........................................................................................48
`
`37 C.F.R. § 42.104(b)(4)................................................................................... 40, 48
`
`37 C.F.R. § 42.104(b)(5)..........................................................................................40
`
`37 C.F.R. § 42.108(a).................................................................................................5
`
`37 C.F.R. § 42.108(b) ................................................................................................5
`
`37 C.F.R. § 42.108(c)...........................................................................................3, 39
`
`P.T.A.B.
`Conopco, Inc. v. Procter & Gamble Co.,
`IPR2014-00506, Paper 25 (P.T.A.B. Dec. 10, 2014)......................................6
`
`Conopco, Inc. v. Procter & Gamble Co.,
`IPR2014-00628, Paper 21 (P.T.A.B. Oct. 20, 2014).......................................8
`
`Ex parte Ahlfeld,
`Appeal 2012-006205, 2015 WL 6774437 (P.T.A.B. Oct. 30, 2015) ............37
`
`Ex parte Goodrich,
`Appeal 2009-009437, 2010 WL 3441066 (B.P.A.I. Aug. 30, 2010) ............53
`
`Ex parte Icon Health & Fitness, Inc.,
`Appeal No. 2006-0790, 2006 WL 1665623 (B.P.A.I. May 16, 2006)..........32
`
`iv
`
`

`
`Ex parte Lee,
`Appeal 2013-009889, 2015 WL 5719912 (P.T.A.B. Sept. 22, 2015)...........37
`
`Ex parte Lin,
`Appeal 2011-010005, 2015 WL 2063245 (P.T.A.B. May 1, 2015)..............37
`
`Ex parte Murata,
`Appeal 2013-007289, 2015 WL 4628749 (P.T.A.B. July 31, 2015) ............53
`
`Ex parte Tombroff,
`Appeal 2012-010047, 2015 WL 779583 (P.T.A.B. Feb. 20, 2015)..............37
`
`General Elec. Co. v. TAS Energy Inc.,
`IPR2014-00163, Paper 11 (P.T.A.B. May 13, 2014) ....................... 40, 53, 64
`
`General Plastic Indus. Co. v. Canon Inc.,
`IPR2015-01954, Paper 9 (P.T.A.B. Mar. 9, 2016)..........................................1
`
`General Plastic Indus. Co. v. Canon Inc.,
`IPR2015-01954, Paper 11 (P.T.A.B. May 19, 2016) ......................................1
`
`Great West Cas. Co. v. Intellectual Ventures II LLC,
`IPR2016-00453, Paper 12 (P.T.A.B. June 9, 2016) ........................................6
`
`NVIDIA Corp. v. Samsung Elec. Co.,
`IPR2016-00134, Paper 9 (P.T.A.B. May 4, 2016) ................................. 3, 6, 8
`
`Roche Molecular Sys., Inc. v. Illumina, Inc.,
`IPR2015-01091, Paper 18 (P.T.A.B. Oct. 30, 2015).......................................8
`
`Samsung Elecs. Co. v. Rembrandt Wireless Techs., LP,
`IPR2015-00118, Paper 14 (P.T.A.B. Jan. 28, 2015) .......................................7
`
`Synopsys, Inc. v. Mentor Graphics Corp.,
`IPR2012-00041, Paper 16 (P.T.A.B. Feb. 22, 2013) ....................................40
`
`Travelocity.com L.P. v. Cronos Techs., LLC,
`CBM2015-00047, Paper 7 (P.T.A.B. June 15, 2015) .....................................7
`
`v
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`Canon Kabushiki Kaisha1
`
`(“Patent Owner”)
`
`respectfully submits this
`
`preliminary response to the petition of General Plastic Industrial Co., Ltd.
`
`(“Petitioner”) seeking inter partes review (“IPR”) of claims 1, 7-9, 11, 16-18, 29,
`
`and 38 of U.S. Patent No. 8,909,094 (“the ’094 patent”).
`
`I.
`
`INTRODUCTION
`
`This is not Petitioner’s first attempt at challenging claims 1, 7-9, 11, 16-18,
`
`29, and 38 of the ’094 patent. Previously, on September 25, 2015, in IPR2015-
`
`01954, Petitioner alleged claims 1, 7-9, 11, 16-18, 29, and 38 of the ’094 patent
`
`were unpatentable over U.S. Patent No. 5,903,806 (“Matsuoka”). That previous
`
`petition was supported by the declaration of Dr. Brian Springett,
`
`the same
`
`declarant who submitted a declaration in support of the instant petition. The Board
`
`found that the previous petition failed to establish a reasonable likelihood of
`
`prevailing with respect to any challenged claim and declined to institute IPR.
`
`General Plastic Indus. Co. v. Canon Inc., IPR2015-01954, Paper 9 (P.T.A.B. Mar.
`
`9, 2016) (denying institution); General Plastic Indus. Co. v. Canon Inc., IPR2015-
`
`01954, Paper 11 (P.T.A.B. May 19, 2016) (denying rehearing).
`
`1 The English translation of “Canon Kabushiki Kaisha” is “Canon Inc.”
`
`1
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`Petitioner filed the instant petition, as well as two additional petitions each
`
`challenging a subset of the previously-challenged ’094 patent claims (IPR2016-
`
`01359 and -01360), after it had received Patent Owner’s preliminary response and
`
`the Board’s non-institution and rehearing decisions in IPR2015-01954.2 The
`
`instant petition (and the additional petitions) are devoid of any explanation as to
`
`whether Petitioner knew of the prior art that it now asserts and why petitioner
`
`waited more than nine months since its first petition to file additional petitions
`
`against the same claims.3
`
`Consistent with its precedent and policy, the Board should exercise its
`
`discretion to deny institution pursuant to 35 U.S.C. §§ 314(a). As explained
`
`below, the factors outlined in NVIDIA Corp. v. Samsung Elec. Co., IPR2016-
`
`2
`
`In addition to the four petitions challenging the ’094 patent, Petitioner also filed
`
`one previously-denied petition (IPR2015-01966) and two pending petitions
`
`(IPR2016-01357 and -01358) challenging Patent Owner’s related U.S. Patent
`
`No. 9,046,820 (“the ’820 patent”). Each petition against the ’094 and ’820
`
`patents was accompanied by a declaration of Dr. Springett.
`
`3 As detailed in Section II below, the record makes clear that Petitioner should
`
`have known of the prior art that it now asserts when it filed its first petition.
`
`2
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`00134, Paper 9 (P.T.A.B. May 4, 2016) (“NVIDIA factors”) weigh heavily against
`
`institution here. Petitioner already has had its chance to challenge the ’094 patent
`
`claims at issue here, and failed in its attempt to do so. Now, without justification,
`
`and with the Patent Owner’s preliminary response and the Board’s prior decisions
`
`from IPR2015-01954 in hand, Petitioner seeks another opportunity to attack the
`
`same claims. Such serial attacks waste the Board’s limited resources, impose
`
`undue burdens on Patent Owner, and frustrate the final resolution of the dispute
`
`between the parties.
`
`The Board should also decline to authorize IPR because Petitioner has failed
`
`to meet its burden of demonstrating a reasonable likelihood of prevailing with
`
`respect to at least one claim under either of its two alleged obviousness grounds.
`
`See 35 U.S.C. § 314(a); 37 C.F.R. § 42.108(c). Challenged claims 1, 7-9, 11, 16-
`
`18, 29, and 384 of the ’094 patent are each directed a toner supply container, such
`
`4 The petition identifies claim 38 as a challenged claim, but Petitioner’s claim
`
`chart purportedly for claim 38 actually recites claim 46’s language. Compare
`
`Petition at 63, 65 with Ex. 1001 at claims 38, 46. This paper addresses how
`
`Petitioner’s arguments fail to establish a reasonable likelihood of prevailing
`
`3
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`

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`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`as a toner bottle that would be used for supplying toner to a copy machine.
`
`Petitioner requests institution of IPR for alleged obviousness over a single
`
`reference, U.S. Patent No. 5,481,344 (“Yasuda”).
`
`Petitioner has failed to show that Yasuda discloses or suggests multiple
`
`limitations of each of the challenged claims, and therefore has not established a
`
`likelihood of success, as discussed in Section VII below. For example, Petitioner
`
`has failed to show that Yasuda discloses or suggests a toner supply container with
`
`a sealing member that has a sealing portion provided at a side adjacent the
`
`container body and a coupling portion provided at a side remote from the container
`
`body. Yasuda also does not disclose a sealing member that has a coupling portion
`
`“configured and positioned to receive a rotational drive force,” as required by all of
`
`the challenged claims. As a further example, Yasuda does not disclose or suggest
`
`the rotational force receiving portion required by claims 1, 7-9, 11, and 16-18.
`
`Section VII below also identifies additional limitations of each challenged claim
`
`that Petitioner has failed to show are taught or suggested by the prior art.
`
`with respect to claims 1, 7-9, 11, 16-18, 29, and 38, which are the claims
`
`Petitioner identified pursuant to 37 C.F.R. § 42.104(b)(1). See id. at 4, 15.
`
`4
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`II.
`
`THE PETITION SHOULD BE DENIED
`UNDER 35 U.S.C. § 314(a)
`
`Institution of
`
`IPR is discretionary.
`
`35 U.S.C. § 314(a); 37 C.F.R.
`
`§ 42.108(a)-(b); Cuozzo Speed. Techs., LLC v. Lee, 136 S. Ct. 2131, 2140 (2016).
`
`When exercising its discretion with respect to a follow-on IPR petition, such as the
`
`instant one, the Board considers the following non-limiting factors:
`
`(1) the finite resources of the Board;
`(2) the requirement under 35 U.S.C. § 316(a)(11) to issue a final
`determination not later than 1 year after the date on which the
`Director notices institution of review;
`(3) whether the same petitioner already previously filed a petition
`directed to the same claims of the same patent;
`(4) whether at the time of filing of the first petition the petitioner
`knew of the prior art asserted in the second petition or should have
`known about it;
`(5) whether at the time of filing of the second petition the petitioner
`already received patent owner’s preliminary response to the first
`petition or received the Board’s decision on whether to institute
`review in the first petition;
`(6) the length of time that elapsed between the time petitioner learned
`of the prior art asserted in the second petition and filing of the
`second petition; and
`
`5
`
`

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`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`(7) whether petitioner provides adequate explanations for the time
`elapsed between the filings of multiple petitions directed to the
`same claims of the same patent.
`
`NVIDIA, IPR2016-00134, Paper 9, at 6-7; Great West Cas. Co. v. Intellectual
`
`Ventures II LLC, IPR2016-00453, Paper 12, at 7-8 (P.T.A.B. June 9, 2016). The
`
`foregoing NVIDIA factors, and additional considerations, weigh heavily against
`
`authorizing IPR in this case.
`
`With respect to the Board’s limited resources and the statutory requirement
`
`for it to issue a final determination no later than one year after institution (NVIDIA
`
`factors 1-2), the Board has explained that allowing petitioners to file follow-on
`
`second petitions in an attempt to correct deficiencies noted by the Board when
`
`denying first petitions “would allow petitioners to unveil strategically their best
`
`prior art and arguments in serial petitions, using [the Board’s] decisions on
`
`institution as a roadmap, until a ground is advanced that results in review—a
`
`practice that would tax Board resources, and force patent owners to defend
`
`multiple attacks.” Conopco, Inc. v. Procter & Gamble Co., IPR2014-00506, Paper
`
`25, at 4-5 (P.T.A.B. Dec. 10, 2014). The Board has similarly explained that an
`
`institution denial “is not simply part of a feedback loop by which a petitioner may
`
`perfect
`
`its challenges through a subsequent filing,” and “[p]ermitting second
`
`chances without constraint ties up the Board’s limited resources; [the Board] must
`
`6
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`be mindful not only of
`
`this proceeding, but of
`
`‘every proceeding.’”
`
`Travelocity.com L.P. v. Cronos Techs., LLC, CBM2015-00047, Paper 7, at 13
`
`(P.T.A.B. June 15, 2015); Samsung Elecs. Co. v. Rembrandt Wireless Techs., LP,
`
`IPR2015-00118, Paper 14, at 6 (P.T.A.B. Jan. 28, 2015) (citations omitted).
`
`As noted above, the same Petitioner previously filed a petition directed to
`
`the same claims of the same patent on September 25, 2015 (NVIDIA factor 3).
`
`When it filed the instant petition on July 8, 2016, Petitioner had received Patent
`
`Owner’s December 22, 2015 preliminary response in prior IPR2015-01954, as well
`
`as the Board’s March 9, 2016 decision declining to institute IPR and the Board’s
`
`May 19, 2016 decision denying Petitioner’s request for rehearing (NVIDIA factor
`
`5). Petitioner has not provided any explanation, let alone an adequate one, for the
`
`time elapsed between its filings of multiple petitions directed to the same claims of
`
`the same patent (NVIDIA factor 7). Furthermore, Petitioner has not identified
`
`when it first learned of the presently asserted reference, or justified any time that
`
`elapsed between when it learned of that reference and its filing of the instant
`
`petition on July 8, 2016 (NVIDIA factors 4 and 6).
`
`Petitioner at least should have known of Yasuda before filing its first IPR
`
`petition, since Yasuda is cited on the face of Matsuoka, the reference Petitioner
`
`asserted in IPR2015-01954. Ex. 2203 at 1. At the very least, Petitioner’s failure to
`
`7
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`

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`Case IPR2016-01361
`U.S. Patent No. 8,909,094
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`offer any explanation of when it learned of Yasuda supports a reasonable inference
`
`that Yasuda was known or available to Petitioner at the time it filed its first
`
`petition. Roche Molecular Sys., Inc. v. Illumina, Inc., IPR2015-01091, Paper 18, at
`
`15 (P.T.A.B. Oct. 30, 2015); Conopco, Inc. v. Procter & Gamble Co., IPR2014-
`
`00628, Paper 21, at 11 (P.T.A.B. Oct. 20, 2014).
`
`The Board’s precedent and policy support declining review pursuant to 35
`
`U.S.C. § 314(a). See, e.g., Great West Cas., IPR2016-00453, Paper 12, at 7-13;
`
`NVIDIA, IPR2016-00134, Paper 9, at 6-12; Conopco, IPR2014-00628, Paper 21, at
`
`11-12. Petitioner’s serial filings place unjustified burdens on both the Board and
`
`Patent Owner. As the Board has explained, declining review under circumstances
`
`such as these will,
`
`in the interests of
`
`fairness, economy, and efficiency,
`
`“discourage[] the filing of a first petition that holds back prior art for use in
`
`successive attacks, should the first petition be denied.” Conopco, IPR2014-00628,
`
`Paper 21, at 11. And declining review will avoid the inequity to Patent Owner that
`
`would result from Petitioner having received the benefit of studying Patent
`
`Owner’s preliminary response and the Board’s decisions in earlier IPR2015-01954
`
`before filing the instant petition. NVIDIA, IPR2016-00134, Paper 9, at 8.
`
`It is also worth noting that, prior to filing any of its IPR petitions, Petitioner
`
`declined an opportunity to challenge the ’094 patent’s validity in In the Matter of
`
`8
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`Certain Toner Supply Containers and Components Thereof, Inv. No. 337-TA-960
`
`(U.S.I.T.C. instituted July 10, 2015). In that case, Patent Owner accused Petitioner
`
`of infringing the same ’094 patent claims now at issue. Instead of defending itself,
`
`Petitioner unilaterally moved to terminate the investigation based on a voluntary
`
`consent order prohibiting future infringement. Ex. 2201; Ex. 2202.
`
`In so doing,
`
`Petitioner represented that termination would be “in the public interest, which
`
`favors the settlement of dispute[s] to avoid needless litigation and to conserve
`
`resources,” because it would “conserve the time and resources of both the
`
`Commission and the private parties ….” Ex. 2201 at 2, 7-8. Patent Owner did not
`
`oppose, and the ITC granted Petitioner’s motion and entered the consent order that
`
`Petitioner requested on September 2, 2015. Ex. 2202. As it turns out, the consent
`
`order did not settle the dispute, because Petitioner has since filed four IPR petitions
`
`asking both the government and Patent Owner to expend time and resources
`
`repeatedly addressing the ’094 patent’s validity, in an attempt to get out from
`
`under the very consent order to which Petitioner voluntarily agreed. The Board
`
`should exercise its discretion and deny institution here to discourage such
`
`gamesmanship.
`
`9
`
`

`
`Case IPR2016-01361
`U.S. Patent No. 8,909,094
`
`III. TECHNOLOGICAL BACKGROUND
`
`A.
`
`The ’094 Patent
`
`The challenged claims of the ’094 patent are directed to a toner supply
`
`container of the type used in an electrophotographic image forming apparatus, such
`
`as a copying machine. Ex. 1001 at col. 1:26-36, claims 1, 7-9, 29. In FIG. 3 of the
`
`’094 patent, shown below, an exemplary toner supply container is denoted by
`
`reference number 1 and a main assembly of a copier is denoted by reference
`
`number 100. The toner supply container is installed in the copier by inserting it in
`
`the direction indicated by arrow “a.” Id. at cols. 7:5-23, 9:25-27.
`
`FIG. 3
`
`The toner supply container has an opening 1a at one end. Id. at FIGS. 8, 10,
`
`col. 9:37-39. The opening is sealed when the toner supply container is outside of
`
`10
`
`

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`Case IPR2016-01361
`U.S. Patent No. 8,909,094
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`the copier. Id. at col. 9:41-47. When the toner supply container is installed in the
`
`copier, two things happen: (1) the opening is unsealed; and (2) when the copier is
`
`being used, the toner supply container is rotated. Id. at cols. 7:24-8:54. The toner
`
`supply container has an internal structure, such as the helical projection shown in
`
`FIG. 8 of the ’094 patent, that causes the toner inside of the container to be fed out
`
`of the opening and into a toner hopper within the copier when the container is
`
`rotated. Id. at FIG. 8, cols. 9:64-10:37.
`
`The challenged independent claims recite as follows:
`
`1. A toner supply container comprising:
`
`i) a container body configured to contain toner and rotatable about an
`axis thereof, the container body including a cylindrical portion and an
`opening provided at one axial end portion thereof and configured to
`permit discharge of the toner contained in the container body; and
`
`ii) a sealing member provided at the one axial end portion of the
`container body, the sealing member being movable relative to the
`container body in an axial direction of the container body, the sealing
`member including:
`
`ii-i) a sealing portion provided at a side adjacent the container
`body and configured to seal the opening when the sealing member
`and the container body are in a first position relative to one
`another, the opening becoming unsealed by relative movement of
`the sealing member and the container body away from one another
`
`11
`
`

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`Case IPR2016-01361
`U.S. Patent No. 8,909,094
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`from the first position to a second position relative to one another;
`and
`ii-ii) a coupling portion provided at a side remote from the
`container body and configured and positioned to receive a
`rotational drive force for rotating the sealing member and the
`container body about the rotation axis of the container body, the
`coupling portion including:
`
`ii-ii-i) a supporting portion provided on the sealing portion, the
`supporting portion being elastically displaceable in an inward
`direction toward the rotation axis of the container body and
`elastically restorable in an outward direction away from the
`rotation axis of the container body;
`ii-ii-ii) an engaging portion provided at a free end of the
`supporting portion and being displaceable with the supporting
`portion, the engaging portion including:
`
`ii-ii-ii-i) a rotational force receiving portion capable of being
`abutted in a direction that is concentric with a circumference
`of the cylindrical portion of the container body to receive a
`rotational drive force for rotating the sealing member and
`the container body; and
`ii-ii-ii-ii) a locking portion capable of being abutted in a
`direction parallel to the rotation axis of the container body to
`enable the relative movement of the sealing member and the
`container body from the first position, in which the opening
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`is sealed, to the second position, in which the opening is
`unsealed; and
`ii-ii-iii) a displacing force receiving portion provided on the
`supporting portion at a position closer to the container body
`than the engaging portion,
`the displacing force receiving
`portion being displaceable with the supporting portion and
`having a radially outermost part that is more remote from the
`rotation axis of the container body than a radially outermost
`part of the engaging portion,
`the engaging portion, and the
`wherein the supporting portion,
`displacing force receiving portion are integrally molded.
`
`11. A toner supply container comprising:
`i) a container body configured to contain toner and rotatable about an
`axis thereof, the container body including a cylindrical portion and an
`opening provided at one axial end portion thereof and configured to
`permit discharge of the toner contained in the container body; and
`
`ii) a sealing member provided at the one axial end portion of the
`container body, the sealing member being movable relative to the
`container body in an axial direction of the container body, the sealing
`member including:
`
`ii-i) a sealing portion provided at a side adjacent the container
`body and configured to seal the opening when the sealing member
`and the container body are in a first position relative to one
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`another, the opening becoming unsealed by relative movement of
`the sealing member and the container body away from one another
`from the first position to a second position relative to one another;
`and
`
`ii-ii) a coupling portion provided at a side remote from the
`container body and configured and positioned to receive a
`rotational drive force for rotating the sealing member and the
`container body about the rotation axis of the container body, the
`coupling portion including:
`ii-ii-i) at least two supporting portions provided on the sealing
`portion at diametrically opposed positions, each supporting
`portion being elastically displaceable in an inward direction
`toward the rotation axis of the container body and elastically
`restorable in an outward direction away from the rotation axis
`of the container body;
`
`ii-ii-ii) an engaging portion provided at a free end of each
`supporting portion and being displaceable with the supporting
`portion on which it
`is provided, each engaging portion
`including:
`
`ii-ii-ii-i) a rotational force receiving portion capable of being
`abutted in a direction that is concentric with a circumference
`of the cylindrical portion of the container body to receive a
`rotational drive force for rotating the sealing member and
`the container body; and
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`ii-ii-ii-ii) a locking portion capable of being abutted in a
`direction parallel to the rotation axis of the container body to
`enable the relative movement of the sealing member and the
`container body from the first position, in which the opening
`is sealed, to the second position, in which the opening is
`unsealed; and
`ii-ii-iii) a displacing force receiving portion provided on
`each supporting portion at a position closer to the container
`body than the engaging portion provided at the free end of
`that supporting portion,
`the displacing force receiving
`portion being displaceable with the supporting portion on
`which it is provided and having a radially outermost part
`that is more remote from the rotation axis of the container
`body than a radially outermost part of the engaging portion
`provided at the free end of that supporting portion.
`
`29. A toner supply container comprising:
`i) a container body configured to contain toner and rotatable about an
`axis thereof, the container body including a cylindrical portion and an
`opening provided at one axial end portion thereof and configured to
`permit discharge of the toner contained in the container body; and
`ii) a sealing member provided at the one axial end portion of the
`container body, the sealing member being movable relative to the
`container body in an axial direction of the container body,
`the sealing member including:
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`ii-i) a sealing portion provided at a side adjacent the container
`body and configured to seal the opening when the sealing member
`and the container body are in a first position relative to one
`another, the opening becoming unsealed by relative movement of
`the sealing member and the container body away from one another
`from the first position to a second position relative to one another;
`and
`ii-ii) a coupling portion provided at a side remote from the
`container body and configured and positioned to receive a
`rotational drive force, the coupling portion including;
`ii-ii-i) a supporting portion provided on the sealing portion, the
`supporting portion being elastically displaceable in an inward
`direction toward the axis of the container body and elastically
`restorable in an outward direction away from the axis of the
`container body;
`
`ii-ii-ii) an engaging portion provided at a free end of the
`supporting portion and being displaceable with the supporting
`portion; and
`ii-ii-iii) a projecting portion provided at a position closer to the
`container body than the engaging portion, the projecting portion
`projecting radially from an outer surface of the supporting
`portion such that a radially outermost part of the projecting
`portion is more remote from the axis of the container body than
`a radially outermost part of the engaging portion, and the
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`projecting portion being displaceable with the supporting
`portion,
`the engaging portion, and the
`wherein the supporting portion,
`projecting portion are integrally molded.
`
`38. A toner supply container comprising:
`
`i) a container body configured to contain toner and rotatable about an
`axis thereof, the container body including a cylindrical portion and an
`opening provided at one axial end portion thereof and configured to
`permit discharge of the toner contained in the container body; and
`
`ii) a sealing member provided at the one axial end portion of the
`container body, the sealing member being movable relative to the
`container body in an axial direction of the container body, the sealing
`member including:
`
`ii-i) a sealing portion provided at a side adjacent the container
`body and configured to seal the opening when the sealing member
`and the container body are in a first position relative to one
`another, the opening becoming unsealed by relative movement of
`the sealing member and the container body away from one another
`from the first position to a second position relative to one another;
`and
`
`ii-ii) a coupling portion provided at a side remote from the
`container body and configured and positioned to receive a
`rotational drive force, the coupling portion including;
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`ii-ii-i) at least two supporting portions provided