`
`Patent No. 9,737,154
`Declaration in Support of Petition for Inter Partes Review
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`American National Manufacturing Inc.,
`Petitioner
`
`v.
`
`Select Comfort Corporation,
`Patent Owner
`
`____________________
`
`Case IPR: Unassigned
`____________________
`
`DECLARATION OF DR. JOSHUA PHINNEY IN SUPPORT
`OF INTER PARTES REVIEW OF U.S. PATENT NO. 9,737,154
`
`
`
`
`
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`AMERICAN NATIONAL MANUFACTURING, INC. - EX 1009 - Page 1
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`Table of Contents
`
`TABLE OF CONTENTS
`
`I.
`
`Introduction ................................................................................................... 1
`
`II. Qualifications................................................................................................. 2
`
`III. Summary of Opinions ................................................................................... 6
`
`IV. Level of ordinary skill ................................................................................ 6
`
`V. Claim Construction ....................................................................................... 7
`
`VI. LEGAL PRINCIPLES .............................................................................12
`A. Anticipation ................................................................................................12
`B. Obviousness ................................................................................................13
`
`VII. Background and Overview .......................................................................17
`A. Background on the Method for Adjusting Pressure In an Air Bed ...............18
`1. Construction ............................................................................................18
`2. Pneumatic Impedance ..............................................................................22
`3. Hunting ...................................................................................................24
`4. Compensation ..........................................................................................25
`5. Controller Implementations .....................................................................29
`6. Adaptive compensation ...........................................................................31
`B. Overview of the ’154 patent ........................................................................34
`7. Prosecution History .................................................................................40
`
`VIII. The Claimed subject matter of the ’154 Patent is Disclosed by the Prior
`Art 44
`A. Claims 1-19 are Rendered Obvious by Gifft in view of Mittal .....................45
`1. Overview of Gifft ....................................................................................45
`2. Overview of Mittal ..................................................................................45
`3. Overview of Pillsbury ..............................................................................49
`4. Motivation to combine Gifft, Mittal, and Pillsbury ..................................52
`B. Claims 1, 4-6, 10, and 12-13 are Rendered Obvious by Gifft in view of
`Mittal, Pillsbury, and Ebel ................................................................................98
`5. Overview of Ebel.....................................................................................98
`1. Motivation to combine Gifft, Mittal, Pillsbury, and Ebel ....................... 102
`
`IX. Conclusion ............................................................................................... 105
`
`
`
`i
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`
`I.
`
`I, Joshua Phinney, declare as follows:
`
`INTRODUCTION
`
`1.
`
`I am a Principal Engineer in the Electrical Engineering and Computer
`
`Science practice at Exponent, an engineering and scientific consulting firm
`
`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025.
`
`2.
`
`I have been retained as an independent expert consultant in this
`
`proceeding before the United States Patent and Trademark Office (the “Patent
`
`Office”). I am a salaried employee of Exponent. Exponent charges an hourly rate
`
`of $495 plus expenses for my work performed in connection with this case. My
`
`compensation is not dependent on the opinions I render or the outcome of this
`
`proceeding.
`
`3.
`
`I understand that this proceeding involves U.S. Patent No. 9,737,154
`
`(“the ’154 patent”). I have been asked to consider whether certain references
`
`disclose or suggest certain features recited in the claims of the ’154 patent. The
`
`references I considered are listed in the Appendix to my Declaration, and for
`
`convenience I refer to these references using the short names listed in the
`
`Appendix. It is my opinion that the references discussed below collectively
`
`disclose or suggest all of the limitations recited in claims 1–22 of the ’154 patent.
`
`4.
`
`I have been informed that the ’154 Patent, filed as U.S. Patent
`
`Application No. 14/283,675 on May 21, 2014, is a continuation of Application No.
`
`1
`
`
`
`
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`
`
`12/936,084, filed on April 4, 2008. The ’084 Application is the U.S. National
`
`Stage Application of International PCT Application No. PCT/US2008/059409,
`
`which was filed on April 4, 2008. I have been informed that the ’154 patent is
`
`assigned to respondent Select Comfort Corporation (“Select Comfort”), and the
`
`respondent has contended that the inventions disclosed in the ’154 Patent were
`
`conceived at least as early as June 29, 2007.
`
`II. QUALIFICATIONS
`
`5.
`
`I received a Ph.D. in Electrical Engineering from the Massachusetts
`
`Institute of Technology (“MIT”) in 2005. I also earned S.M. and B.S. degrees in
`
`Electrical Engineering from MIT and the University of Illinois, Chicago (“UIC”),
`
`respectively. While at MIT, I worked on the Laser Interferometric Gravitational
`
`Wave Observatory (LIGO) experiment, where I designed and tested hydraulic
`
`systems for outer-stage seismic isolation of the experimental apparatus. My job
`
`responsibilities included the design and testing of a hydraulic manifold and
`
`pressure control system, as well as the selection and testing of the pump, motor
`
`drive, pressure transducers, and hydraulic spool valves that were components of
`
`the pressure control system.
`
`6.
`
`After earning my Ph.D., I joined Exponent and have led technical
`
`investigations pertaining to portable electronic devices, microcomputers, and
`
`electromechanical devices with embedded controllers. My job functions include
`
`
`
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`analyzing hardware and software of these devices to understand their modes of
`
`failure, and testifying regarding these devices in legal matters involving patents
`
`and trade secrets.
`
`7.
`
`I have testified regarding the software-defined features, internal
`
`circuitry, and physical embodiments of electronic equipment.
`
`8.
`
`Regarding software, I have reviewed C++, Java, and machine
`
`language code for purposes of patent infringement and trade secret
`
`misappropriation. I have testified regarding microcomputer software for instrument
`
`control as well as embedded software for the control of machines, computer
`
`peripherals, tablets, cell phones, and other battery-operated equipment.
`
`9.
`
`Regarding electronics, I have testified regarding power electronics in
`
`microcomputers, peripherals, machine controllers, and consumer electronics
`
`including tablets, cell phones, and portable media players. In addition, I have
`
`testified regarding control circuitry and compensation of motion controllers,
`
`furnace controllers, pump controllers, voltage regulators, and switched-mode
`
`power converters.
`
`10. Regarding the mechanical elements of electronic equipment, I have
`
`testified regarding buttons and touch interfaces, connectors, linear and rotary
`
`actuators, position-measuring devices, and the design and construction of modular
`
`housings for computerized equipment and peripherals. In particular, I have
`
`
`
`3
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`testified regarding user interfaces (including buttons, indicators, touch interfaces
`
`and card readers) as they are constructed in relation to the housing and underlying
`
`electronic assemblies, including printed circuit boards, flex printed circuits, and
`
`other connector assemblies within the housing of electronic equipment.
`
`11.
`
`I have most recently been disclosed as an expert, at trial for testimony,
`
`deposed or submitted an Expert Report to the court in:
`
`a. Convolve, Inc. v. Compaq Computer Corp., S.D.N.Y. Civ. No.
`00-5141.
`
`b. IBM v. ASUSTek Computer, Inc., United States International Trade
`Commission Unfair Import Investigation No. 337-TA-628
`
`c. Xentaur Corp. v. Bedros Bedrossian, N.Y. Sup. Ct. No. 23403/06
`
`d. Apple
`Inc. v. Samsung Electronics. Corp., United States
`International Trade Commission Unfair Import Investigation No.
`337-TA-796
`
`e. Guzik Tech. Enterprises, Inc. v. Western Digital Corp. et al., Case
`No. 5:11-CV-03786-PSG, N.D. Cal.
`
`f. L-3 Communications Corporation et al v. Jaxon Engineering &
`Maintenance, Civil Action No. 10-cv-2868-MSK-KMT, District
`of Colorado.
`
`g. Smart Skins LLC v. Microsoft Corporation. Case No. 2:15-CV-
`00544-MJP in the United States District Court, Western District of
`Washington at Seattle.
`
`h. Commonwealth of Puerto Rico Treasury Department v. OPG
`Technology Corp., Case No. 15-3125 in the in the United States
`District Court, District of Puerto Rico.
`
`i. IPS Group, Inc. v. Duncan Solutions, Inc. and Duncan Parking
`Technologies, Inc., Case No. 3:15CV1526-CAB (MDD) in the
`United States District Court, Southern District of California.
`
`
`
`4
`
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`
`
`
`
`j. Maxell, Ltd. v. ZTE Corp. and ZTE USA Inc. and Maxell, Ltd. v.
`Huawei Device USA Inc. and Huawei Device Co., Ltd., Case Nos.
`5:16-cv-00178-RWS and 5:16-cv-00179-RWS in the United States
`District Court, Eastern District of Texas.
`
`k. IPS Group, Inc. v. CivicSmart, Inc., Duncan Parking Technologies,
`Inc., and Duncan Solutions, Inc., Case No. 3:17-CV-00632-CAB
`(MDD) in the United States District Court, Southern District of
`California.
`
`l. Qualcomm, Inc. v. Apple, Inc., Case No. 17-CV-2403-BAS-NLS in
`the United States District Court, Southern District of California.
`
`m. Siemens Industry, Inc. v. Westinghouse Air Brake Technologies
`Corp. and Wabtec Railway Electronics, Inc.., Case No. 1:16-CV-
`284-LPS in the United States District Court, District of Delaware.
`
`12.
`
`I have most recently submitted declarations to the U.S. Patent and
`
`Trademark Office concerning re-examinations of patents at stake in:
`
`a. Apple Inc. v. Yozmot, IPR2015-00761 before the U.S. Patent Trial
`and Appeal Board.
`
`b. Cypress Semiconductor Corp. v. Blackberry Ltd., IPR2014-00397
`and IPR2014-00400 before the U.S. Patent Trial and Appeal Board.
`
`c. Live Nation Entertainment, Inc. v. Songkick.com BV, PGR2017-
`00038 before the U.S. Patent Trial and Appeal Board.
`
`d. Apple Inc. v. Qualcomm Inc., Declarations in support of Inter Partes
`Review of U.S. Patent No. 7,834,591, IPR case number unassigned.
`
`13.
`
`I am co-inventor on patents for improving the performance of
`
`capacitors, EMI filters, and common-mode chokes.
`
`
`
`5
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`14. Additional details about my employment history, fields of expertise,
`
`and publications are further described in my curriculum vitae, which is attached to
`
`this Declaration as Appendix A.
`
`III. SUMMARY OF OPINIONS
`
`15. My opinions in this Declaration are based on my review of the ’154
`
`patent, its prosecution history before the Patent Office, and the materials identified
`
`in Appendix B to this Declaration. In addition, I draw upon my experience and
`
`knowledge of control systems, including pumps and pressure-control systems. For
`
`convenience, I will refer to prior art references discussed in this Declaration by the
`
`short names provided in Appendix B.
`
`16. To summarize the conclusions that I have formed based on my
`
`analysis:
`
`a. Claims 1-4, 7-14, and 16-22 are rendered obvious by Gifft in view
`
`of Mittal and Pillsbury; and
`
`b. Claims 5, 6, and 15 are rendered obvious by Gifft in view of Mittal,
`
`Pillsbury, and Ebel.
`
`IV. LEVEL OF ORDINARY SKILL
`
`17. My opinions have been guided by my consideration of how a person
`
`of ordinary skill in the art would have understood the claims of the ’154 patent on
`
`
`
`6
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`the filing date of International PCT Application No. PCT/US2008/059409, April 4,
`
`2008, which I will refer to as the “time of the alleged invention.”
`
`18. At the time of the alleged invention, a person of ordinary skill in the
`
`art related to the technology of the ’154 patent would have had an undergraduate
`
`degree (B.S.) in Mechanical or Electrical Engineering, and at least one years of
`
`experience with hydraulics, fluidic control, pneumatic air bed controllers, or the
`
`equivalent. My opinion is based on my understanding of the typical qualifications
`
`of those working in the field at that time. I have been informed that, as a matter of
`
`law, the hypothetical person of ordinary skill in the art is deemed to be aware of all
`
`relevant prior art, including all of the references discussed in this Declaration.
`
`V. CLAIM CONSTRUCTION
`
`19.
`
`I have been informed that in inter partes review of a patent, claim
`
`terms are given their ordinary and customary meaning, which is the meaning that
`
`the terms would have to a person of ordinary skill in the art (POSITA) at the time
`
`of the invention.
`
`20. For all claim terms considered in this Declaration, I have applied the
`
`plain and ordinary of those terms throughout my analysis unless noted otherwise
`
`below. I reserve the right to update my opinions should the parties agree on a
`
`construction of any claim terms.
`
`
`
`7
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`21.
`
` “Pressure setpoint” (claims 1, 10, 12, 18, and 20) is not defined in
`
`the ’154 patent. The independent claims provide “selecting a desired pressure
`
`setpoint for the air chamber.” In the claimed method, a pressure target is
`
`calculated based upon this pressure setpoint as well as the pressure adjustment
`
`factor. See ’154 patent at 7:11-25, 8:13-51. After pressure adjustment, the actual
`
`chamber pressure is compared to the desired pressure setpoint to determine an
`
`adjustment factor error. Id. 9:32-61. Consistent with a POSITA’s understanding
`
`of the use of the word “pressure” in this phrase – and consistent with the fact that
`
`the pressure setpoint is commensurable with the “actual chamber pressure” – I
`
`interpret the term “pressure setpoint” to mean the desired pressure of the air
`
`chamber.
`
`22.
`
` “Manifold” (claims 11, 12, 14-17, 19-20, 22) is not defined in the
`
`‘154 patent. Consistent with a POSITA’s understanding of a manifold, I interpret
`
`the term “manifold” to include a structure whose purpose is to control, redirect or
`
`split a pressurized fluid stream into one or more components. This meaning is
`
`consistent with the ’154 patent’s use of related term “pump manifold 43,”
`
`discussed below.
`
`23.
`
`“Pump manifold” (claims 12, 20, and 22) is identified in the ’154
`
`patent in a functional block schematic (Id. Fig. 2) . Fig. 2 depicts the pump
`
`manifold as comprising first control valve 45A, second control valve 45B, and
`
`
`
`8
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`pressure transducer 46. Id. 3:44-54. In addition, the pump manifold is modeled in
`
`the ’154 patent as part of a fluid-electrical analog: “Additionally, pump manifold
`
`(43) may be modeled by another capacitor 6 because it also acts as a chamber,
`
`albeit much smaller than the first and second chambers 14A and 14B.” Id. 5:5-8.
`
`Accordingly, I interpret the term “pump manifold” to be a manifold directly
`
`connected to a pump device which controls, redirects, or splits the output of the
`
`pump.
`
`24.
`
`“Pressure adjustment factor” is functionally defined with the
`
`independent claims of the ’154 patent, claims 1, 12, 18 and 20, viz. “…calculating
`
`a pressure target for the pump housing, wherein the pressure target for the pump
`
`housing is calculated based upon the desired pressure setpoint for the air chamber
`
`and a pressure adjustment factor.” A person of ordinary skill would understand
`
`that the ’154 patent uses the “pressure adjustment factor” to refer to a quantity
`
`which is used to calculate a pressure target value during inflation or deflation. The
`
`specification provides details of this calculation for a particular embodiment (Id.
`
`8:13-51), but the independent claims of the ’154 patent do not limit how the
`
`“pressure adjustment factor” is used to calculate a pressure target. Given that the
`
`“pressure adjustment factor” is an “adjustment,” however, a person of ordinary
`
`skill would understand that a pressure adjustment factor operates in some manner
`
`on the setpoint pressure, e.g., using an additive offset, a multiplicative factor, or
`
`
`
`9
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`some combination of the two to compensate for difference between sensed
`
`pressure and chamber pressure during flow. Therefore, and consistent with how a
`
`POSITA would interpret the term, I interpret “pressure adjustment factor” to mean
`
`“a calculation parameter used by a control system to determine a pressure target
`
`and compensate for the difference between sensed pressure and chamber pressure
`
`during flow.”
`
`25.
`
` “Determining a pressure” is used in the ’154 patent to describe
`
`various means of obtaining the pressure of the target air chamber, the pump
`
`manifold, and the pump housing. Although the ’154 patent mentions an alternative
`
`embodiment with multiple pressure sensors to measure the pressure in both the
`
`target volume (mattress) as well as the pump manifold/housing, the preferred
`
`embodiment incorporates a single pressure sensor located inside the pump
`
`manifold. Id. 3:63-4:3. The ‘154 patent uses variations of the phrase “determine a
`
`pressure” (for example “determining an actual chamber pressure” and
`
`“determining an initial pressure within the pump housing”) to refer to both direct
`
`physical measurements of a volume (i.e. using a pressure sensor) as well as indirect
`
`measurements relying on the pressure measured in an adjacent, fluidly connected
`
`volume. Specifically, the sensed pressure within the pump manifold serves as a
`
`proxy for the pressure within the final chamber (mattress) since there is a
`
`mathematical relationship between the two, Id. 4:53-59. Accordingly, and
`
`
`
`10
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`
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`consistent with how a POSITA would interpret the ’154 specification, I understand
`
`the phrase “determine a pressure” to include direct measurement of the pressure in
`
`a first volume, as well as indirect measurement via the pressure in a second volume
`
`(where the first and second volumes are fluidly coupled).
`
`26.
`
`“Adjustment factor error” is referenced in claim 1 of the ’154 patent
`
`as being determined by “comparing the actual chamber pressure to the desired
`
`pressure setpoint,” and subsequently “modifying the pressure adjustment factor
`
`based upon the adjustment factor error.” Likewise claim 12 of the ’154 patent
`
`recites “comparing the actual chamber pressure to the desired pressure setpoint for
`
`the air chamber to determine an adjustment factor error; modifying the pressure
`
`adjustment factor based upon the adjustment factor error to create a modified
`
`pressure adjustment factor configured to more accurately account for differences
`
`between sensing pressure in the manifold and sensing pressure in the air chamber.”
`
`In both instances, the ’154 patent uses “adjustment factor error” to represent a
`
`difference between the actual pressure in the chamber and the final (user-supplied)
`
`pressure setpoint for the chamber, which is then used to inform an iterative
`
`calculation of a target pressure value via the pressure adjustment factor.
`
`Accordingly, and consistent with how a POSITA would interpret this term, I
`
`interpret the term “adjustment factor error” to mean “a term representing the
`
`difference between the final desired pressure setpoint for a chamber and the actual
`
`
`
`11
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`chamber pressure such that this term is used to modify the pressure adjustment
`
`factor”.
`
`VI. LEGAL PRINCIPLES
`
`A. ANTICIPATION
`
`27.
`
`I understand that a finding of invalidity of a patent claim under 35
`
`U.S.C. § 102, which is known as “anticipation,” is a two-step process. First, the
`
`language of the claim is construed as it would be understood by one of ordinary
`
`skill in the art at the time of the filing of the patent application. Reference is made
`
`to the intrinsic evidence of record, which includes the language of the claim itself
`
`and other issued claims, the patent specification, and the prosecution history.
`
`Words in a claim will be construed according to their plain and ordinary meaning
`
`to a person of ordinary skill in the art unless it appears that the inventor used them
`
`differently. The prosecution history may limit the interpretation of the claim,
`
`especially if the patentee disavowed or disclaimed any coverage in order to obtain
`
`allowance of the claim.
`
`28. The second step requires a comparison of the claim language to the
`
`prior art on a limitation-by-limitation basis. I understand that a prior art reference
`
`“anticipates” an asserted claim, and thus renders the claim invalid, if all elements
`
`of the claim are disclosed in that prior art reference, either explicitly or inherently.
`
`
`
`12
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`29.
`
`I understand that although anticipation cannot be established by
`
`combining references, additional references may be used to interpret the
`
`anticipating reference by, for example, indicating what the anticipating reference
`
`would have meant to one having ordinary skill in the art.
`
`B. OBVIOUSNESS
`
`30.
`
`I understand that even if a patent is not anticipated, it is still invalid
`
`under 35 U.S.C. § 103 if the differences between the claimed subject matter and
`
`the prior art are such that the subject matter as a whole would have been obvious at
`
`the time of the invention to a person of ordinary skill in the art. I have been
`
`informed that an obviousness analysis requires a comparison of the properly
`
`construed claim language to the prior art on a limitation-by-limitation basis.
`
`31.
`
`I understand that an obviousness determination includes the
`
`consideration of various factors such as (1) the scope and content of the prior art,
`
`(2) the differences between the prior art and the Asserted Claims, (3) the level of
`
`ordinary skill in the pertinent art, and (4) the existence of objective indicia of non-
`
`obviousness. I understand that it is Plaintiff’s burden to make a showing objective
`
`indicia (or “secondary considerations”) of non-obviousness, which may include:
`
`i. whether the invention proceeded in a direction contrary to accepted
`wisdom in the field;
`
`ii. whether there was a long felt but unresolved need in the art that
`was satisfied by the invention;
`
`iii. whether others had tried but failed to make the invention;
`
`
`
`13
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`iv. whether others copied the invention;
`
`v. whether the invention achieved unexpected results;
`
`vi. whether the invention was praised by others;
`
`vii. whether others have taken licenses to use the invention;
`
`viii. whether experts or those skilled in the art at the making of the
`invention expressed surprise or disbelief regarding the invention;
`
`ix. whether products incorporating the invention have achieved
`commercial success that is attributable to the invention; and
`
`x. whether or not others having ordinary skill in the field
`independently made the claimed invention at about the same time
`the inventor made the invention.
`
`32.
`
`I also understand that for any such secondary consideration to be
`
`relevant, the patentee must establish a connection or nexus between the secondary
`
`consideration and the claimed invention. For example, commercial success is
`
`relevant to obviousness only if the success of the product is related to a feature of
`
`the patent claims. If, however, commercial success is due to advertising,
`
`promotion, salesmanship or the like, or is due to features of the product other than
`
`the claimed invention, then any commercial success should not be considered an
`
`indication of non-obviousness. Also, to satisfy the nexus requirement, I
`
`understand that a patent owner must demonstrate that the asserted commercial
`
`success of the product is due to the merits of the claimed invention beyond what
`
`was readily available in the prior art.
`
`
`
`14
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`33. To demonstrate unexpected results, I understand a patent owner must
`
`compare his invention to the closest prior art, even if that prior art was not relied
`
`on by the examiner. Additionally, to demonstrate failure of others to satisfy a long
`
`felt need, I understand a patent owner must establish a showing that others skilled
`
`in the art in fact perceived a need and that this perception persisted over a long
`
`period of time without resolution by the prior art.
`
`34.
`
`I understand that an obviousness evaluation can be based on a
`
`combination of multiple prior art references. I am informed that the prior art
`
`references themselves may provide a suggestion, motivation, or reason to combine,
`
`but other times the connection between two or more prior art references is common
`
`sense. I further understand that an obviousness analysis recognizes that market
`
`demand – rather than scientific literature – often drives innovation, and that a
`
`motivation to combine references may be supplied by the direction of the
`
`marketplace.
`
`35.
`
`I am also informed that if a technique has been used to improve one
`
`device, and a person of ordinary skill in the art would recognize that it would
`
`improve similar devices in the same way, using the technique is obvious unless its
`
`actual application is beyond his or her skill.
`
`36.
`
`I understand that a particular combination may be proven obvious by
`
`showing that it was obvious to try the combination. For example, when there is a
`
`
`
`15
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`design need or market demand to solve a problem and there are a finite number of
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`identified, predictable solutions, a person of ordinary skill has good reason to
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`pursue the known options within his or her technical grasp because the result is
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`likely the product not of innovation but of ordinary skill and common sense.
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`37.
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`I have been advised that the combination of familiar elements
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`according to known methods is likely to be obvious when it does no more than
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`yield predictable results. When a work is available in one field of endeavor, design
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`incentives and other market forces can prompt variations of it, either in the same
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`field or a different one. If a person of ordinary skill can implement a predictable
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`variation, 35 U.S.C. § 103 likely bars its patentability.
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`38.
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`I understand that a proper obviousness analysis focuses on what was
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`known or obvious to a person of ordinary skill in the art, not just the patentee.
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`Accordingly, I understand that any need or problem known in the field of endeavor
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`at the time of invention and addressed by the patent can provide a reason for
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`combining the elements in the manner claimed. I understand also that the
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`knowledge and understanding of a person of ordinary skill in the art provides a
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`reference point from which the prior art and claimed invention should be viewed,
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`and that analysis of whether a claimed invention is obvious must not rely on a
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`hindsight combination of prior art.
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`39.
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`I understand that a claim can be obvious in light of a single reference,
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`without the need to combine references, if the elements of the claim that are not
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`found explicitly or inherently in the reference are obvious in view of ordinary skill
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`in the art.
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`40.
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`In sum, my understanding is that prior art teachings are properly
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`combined where a person of ordinary skill in the art, having the understanding and
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`knowledge reflected in the prior art and motivated by the general problem facing
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`the inventor, would have been led to make the combination of elements recited in
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`the claims. Under this analysis, the prior art references themselves, or any need or
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`problem known in the field of endeavor at the time of the invention, can provide a
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`reason for combining the elements of multiple prior art references in the claimed
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`manner.
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`VII. BACKGROUND AND OVERVIEW
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`41. Section VII(A) provides an overview of the method of adjusting air
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`pressure within an air bed that is the focus of the ’154 patent. The disclosure of the
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`’154 patent is discussed in Section VII(B).
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`A. BACKGROUND ON THE METHOD FOR ADJUSTING PRESSURE IN AN
`AIR BED
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`1.
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`Construction
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`42. By the time of the alleged invention, inflatable air mattresses included
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`a pump unit supplying air to the inflatable chamber(s) of the mattress in response
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`to a user setting.
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`43. Referring to Figure 1, the pump unit A can be seen placed underneath
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`the air mattresses B, with a set of remote units C each connected to the pump unit
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`connected to the air system. The pump unit A supplies air to the air chambers
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`within mattresses B through supply hoses. A twin bed may only require a single
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`air chamber while a king bed may require two or more chambers, as shown in
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`Figure 1.1
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`1 See Fig. 1 of U.S. Patent 6,686,711 (“Rose et al.”) entitled “Air Mattress Control System and Method” filed on
`November 15, 2001 and assigned to Comfortaire Corporation.
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`Figure 1. perspective view showing the pump unit A, air chambers B, and remote units C
`of an air mattress system. Air hoses 10 extend between the pump unit and air chambers.
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`44. Referring now to Figure 2,2 the pump unit includes a valve assembly
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`D. In this particular embodiment, dual valve assemblies are shown to support a
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`dual chamber mattress. During inflation, the pump provides air through one or
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`more valves and supply tubes for delivery to an air chamber. Integrated with the
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`pump unit is a processor for controlling operation of the valves. Pressure
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`sensors 28a and 28b are also located on processor board 22 and are connected to
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`valve assembly D through tubes 30a and 30b. The valve assemblies are also
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`connected to processor port 22 through connections 32a and 32b. This connection
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`2 See Rose et al. Fig. 2.
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`allows processor 22 to control the opening and closing of the valves contained
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`within the valve assembly D, based on the readings of sensors 28a and 28b.
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`Figure 2. top view of the pump unit A from Figure 1.
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`45. The arrangement of components shown in Figure 1 and Figure 2 is
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`typical of many pneumatic control systems, inasmuch as the pressure sensor(s) are
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`in fluid communication with a pump manifold that is remote from the controlled
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`air chamber itself. A conduit or hose is typically interposed between a pressure
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`sensor and air chamber in other fluid-control applications, including:
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`• seating comfort adjustment systems, e.g., one or more air bladders
`internal to the seats of a motor vehicle. See, e.g., U.S. Patent
`Application Publication No. 2007/0000559 A1 (“Ebel”) filed July 22,
`2004 and entitled “Pressure Measuring Method and Device”; U.S.
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`Patent 6,088,642 (“Finkelstein”) filed July 28, 1998 and entitled
`“Interactive, Individ