IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`American National Manufacturing Inc.,
`Petitioner
`
`v.
`
`Select Comfort Corporation,
`Patent Owner
`
`
`Patent No. 5,904,172
`Filing Date: July 28, 1997
`Issue Date: May 18, 1999
`Title: VALVE ENCLOSURE ASSEMBLY
`
`
`
`OPENING EXPERT REPORT OF DR. ROBERT GIACHETTI IN
`SUPPORT OF
`PETITIONER AMERICAN NATIONAL MANUFACTURING, INC.’S
`PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT 5,904,172
`
`
`
`
`
`
`
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`AMERICAN NATIONAL MANUFACTURING, INC. - EX 1005 - Page 1
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`
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`
`
`TABLE OF CONTENTS
`
`BRIEF STATEMENT OF QUALIFICATIONS .............................................................. 4
`
`I HAVE BEEN ADEQUATELY AND ACCURATELY INSTRUCTED
`ON THE LAW OF CLAIM INTERPRETATION, ANTICIPATION,
`AND OBVIOUSNESS .................................................................................................... 6
`
`a.) Anticipation .................................................................................................... 7
`
`b.) Obviousness .................................................................................................... 9
`
`BACKGROUND OF THE ‘172 INVENTION .............................................................. 13
`
`I HAVE DETERMINED THE APPROPRIATE LEVEL OF SKILL ............................. 26
`
`I HAVE INTERPRETED GIFFT ‘172 PATENT CLAIM TERMS
`‘FLUIDLY COUPLED’, ‘PRESSURE MONITOR MEANS’, ‘SNAP-
`FIT’, ‘MONITORING THE PRESSURE’ ..................................................................... 27
`
`VI.
`
`THE ASSERTED PATENT, U.S PATENT NO. 5,904,172 (GIFFT ‘172) ..................... 30
`
`VII. CLAIMS 2, 9, 12, 22 AND 23 OF GIFFT ‘172 ARE ANTICIPATED BY
`SHAFER, A PRIOR ART PATENT .............................................................................. 33
`
`A.
`
`Overview of WO 96/13947: “Improved Air Control System For
`An Air Bed” ....................................................................................................... 33
`
`B.
`
`Analysis of Gifft Claims 2, 12, 22, and 23 In View Of Shafer: ........................... 35
`
`VIII. CLAIMS 3 AND 13 OBVIOUS OVER SHAFER IN VIEW OF
`CAMMACK, A PRIOR ART PATENT ........................................................................ 60
`
`A.
`
`B.
`
`C.
`
`Overview of U.S. Patent 4,309,783: “Adjustably Conformable
`Bed” .................................................................................................................. 60
`
`Motivation to Combine Shafer and Cammack .................................................... 61
`
`Analysis of Gifft ‘172 Claims 3 and 13 in View of Shafer and
`Cammack ........................................................................................................... 62
`
`IX.
`
`CLAIMS 4, 11, 14, AND 19 ARE OBVIOUS OVER SHAFER IN VIEW
`OF DUNHAM, A PRIOR ART PATENT ..................................................................... 67
`
`A.
`
`B.
`
`C.
`
`Overview of U.S. Patent 3,155,991, “Mattress With Pump and
`Method For Forming Same” ............................................................................... 67
`
`Motivation to Combine Shafer and Dunham....................................................... 68
`
`Analysis of Claims 4, 11, 14 and 19 In View Of Shafer and
`Dunham: ............................................................................................................ 69
`
`X.
`
`CLAIMS 4, 5, 11, 14, AND 15 ARE OBVIOUS OVER SHAFER IN
`VIEW OF RAMACIER, A PRIOR ART PATENT ....................................................... 86
`
`A.
`
`Overview of U.S. Patent 4,494,074: “Quick Connection Coupling
`
`1
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`B.
`
`C.
`
`Valve Assembly” ............................................................................................... 86
`
`Motivation to Combine Shafer and Ramacier ..................................................... 87
`
`Analysis of Gifft ‘172 Claims 4, 5, 11, 14, and 15 in View of
`Shafer and Ramacier .......................................................................................... 90
`
`XI.
`
`CLAIMS 6, 7, 8, 16, 17, 18, 20, 21, 24 AND 25 ARE OBVIOUS OVER
`SHAFER IN VIEW OF GRANT, A PRIOR ART PATENT ........................................ 104
`
`A.
`
`B.
`
`C.
`
`Overview of U.S. Patent 5,353,838: “Pressurized Diaphragm Pump
`and Directional Flow Controller Therefor” ....................................................... 104
`
`Motivation to Combine Shafer and Grant ......................................................... 105
`
`Analysis of Gifft ‘172 Claims 6, 7, 8, 16, 17, 18, 20, 21, 24 and 25
`in View of Shafer and Grant ............................................................................. 108
`
`XII. CLAIMS 2, 6, 12, 16, 20, 24 ARE ANTICIPATED BY VRZALIK, A
`PRIOR ART PATENT ................................................................................................ 123
`
`A.
`
`B.
`
`Overview of U.S. Patent 5,044,029: “Alternating Pressure Low Air
`Loss Bed” ........................................................................................................ 123
`
`Analysis of Gifft Claims 2, 6, 12, 16, 20, and 24 In View Of
`Vrzalik: ............................................................................................................ 125
`
`XIII. CLAIM 22 IS OBVIOUS OVER SHAFER IN VIEW OF VRZALIK ......................... 151
`
`A.
`
`B.
`
`Motivation to Combine Shafer and Vrzalik ...................................................... 151
`
`Analysis of Gifft Claim 22 in View of Shafer and Vrzalik ................................ 152
`
`XIV. CLAIMS 2 AND 9 ARE OBVIOUS OVER SHAFER IN VIEW OF
`KASHIWAMURA, A PRIOR ART PATENT ............................................................. 153
`
`A.
`
`B.
`
`C.
`
`Overview of U.S. Patent 4,655,505: “Pneumatically Controlled
`Seat for Vehicle” .............................................................................................. 153
`
`Motivation to Combine Shafer and Kashiwamura ............................................ 155
`
`Analysis of Gifft Claims 2 and 9 In View Of Shafer and
`Kashiwamura: .................................................................................................. 156
`
`XV. CLAIMS 4 AND 19 ARE OBVIOUS OVER SHAFER IN VIEW OF
`KASHIWAMURA AND DUNHAM ........................................................................... 163
`
`A.
`
`Analysis of Gifft Claims 4 and 19 In View Of Shafer,
`Kashiwamura, and Dunham: ............................................................................ 163
`
`XVI. CLAIMS 6 AND 20 ARE OBVIOUS OVER SHAFER IN VIEW OF
`KASHIWAMURA AND GRANT ............................................................................... 170
`
`A.
`
`Analysis of Claims 6 and 20 in Light of Shafer, Kashiwamura, and
`Grant ................................................................................................................ 170
`
`XVII. CLAIM 12 IS OBVIOUS OVER SHAFER IN VIEW OF DYE .................................. 175
`
`A.
`
`Overview of U.S. Patent 5,383,894: “Compression Device Having
`
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`Stepper Motor Controlled Valves” ................................................................... 175
`
`Motivation to Combine Shafer and Dye ........................................................... 176
`
`Analysis of Claim 12 in View of Shafer and Dye ............................................. 176
`
`B.
`
`C.
`
`XVIII. CLAIMS 11 AND 14 ARE OBVIOUS OVER SHAFER IN VIEW OF
`DYE AND DUNHAM ................................................................................................ 180
`
`A.
`
`Analysis of Claims 11 and 14 in View of Shafer, Dye, and
`Dunham ........................................................................................................... 180
`
`XIX. CLAIM 16 IS OBVIOUS OVER SHAFER IN VIEW OF DYE AND
`GRANT ....................................................................................................................... 185
`
`A.
`
`Analysis of Claim 16 in View of Shafer, Dye, and Dunham ............................. 185
`
`XX. CONCLUSION ........................................................................................................... 187
`
`XXI. APPENDIX A: U.S. PATENT NO. 5,904,172 CLAIM LISTING................................ 188
`
`XXII. APPENDIX B: U.S. PATENT NO. 5,904,172 INVALIDITY GROUNDS .................. 201
`
`
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`3
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`I.
`
`BRIEF STATEMENT OF QUALIFICATIONS
`
`1.
`
`I am a Licensed Professional Engineer in Illinois and Oklahoma, with
`
`over 10 years of experience in mechanical engineering. My experience in machinery
`
`and mechanisms spans numerous industries; I have worked directly designing
`
`mechanical systems and machinery and have consulted on the operation of
`
`machinery in various fields including rail, hydraulic equipment, hydraulic cylinders,
`
`and industrial machinery.
`
`2.
`
`I am currently employed by Exponent, Inc. as a Senior Managing
`
`Engineer. I joined Exponent in June 2008 after graduating from the University of
`
`Wisconsin-Madison and University of Illinois at Chicago where I achieved a Ph.D.
`
`in mechanical engineering and a master’s in mechanical engineering, respectively.
`
`My graduate studies involved advanced coursework in in fluid dynamics and
`
`controls.
`
`3. My responsibilities with Exponent include engineering consulting and
`
`testing with respect to consumer product design and machinery design, product and
`
`machinery performance, accident reconstruction, and failure analysis. As part of
`
`these studies I use standardized tests and I also design and develop custom testing
`
`methods and devices. As an example, this work has involved the development of a
`
`hydraulic test bed and computer control system that was used to fill and relieve
`
`flexible/expandable client devices using pumps, computer controlled solenoid
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`4
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`valves, manifolds, pressure sensors, and computer control that processes the pump
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`state and pressure state to maximize the speed of fill to a set point pressure and also
`
`to drain as quickly as possible. I developed this system from the ground up and have
`
`implemented it using two different methods: pneumatically driven water flow (air
`
`compressor), and pump driven (high flow and high pressure pumps working in
`
`parallel). I have been involved in other cases as the lead developer of test equipment
`
`that functions similarly for evaluation of other products using both pneumatics (air)
`
`and hydraulics (water).
`
`4.
`
` Prior to attending graduate school, I worked as a project engineer,
`
`designing industrial machinery at Braner USA that involved selecting hydraulics for
`
`the machinery and I worked as an estimator and designer at Alloy Sling Chain, IND.
`
`LTD.
`
`5.
`
`I am an active member of the ASTM International committees that
`
`oversee sports equipment and consumer products. I have been recognized as an
`
`expert in mechanical power transmission equipment and serve on the American
`
`Society of Mechanical Engineers (ASME) Power Transmission and Gearing
`
`Committee. I have also participated, by invitation, in the National Council of
`
`Examiners for Engineering and Surveying (NCEES) Mechanical Professional
`
`Activities and Knowledge Studies (PAKS) committee. This committee reviews and
`
`5
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`evaluates the problems and problem types that appear on the Mechanical
`
`Engineering Professional Engineering exam.
`
`6.
`
`For nearly 18 years, I have worked in the area of machine design and
`
`applications of machine design. These machines and products have ranged from
`
`children’s mattresses, to garden hoses, to pressure cookers, electronic tire/raft
`
`inflators, and industrial equipment including hydraulic cylinders.
`
`7. My Curriculum Vitae is attached as Exhibit 1006 along with my current
`
`four-year testimony list.
`
`8.
`
`I am a salaried employee of Exponent. In 2018 Exponent charges an
`
`hourly rate of $340 for my time, plus reasonable expenses. I have no financial
`
`interest in the outcome of this case.
`
`
`
`II.
`
`I HAVE BEEN ADEQUATELY AND ACCURATELY INSTRUCTED
`
`ON THE LAW OF CLAIM INTERPRETATION, ANTICIPATION,
`
`AND OBVIOUSNESS
`
`9. My opinion will concern U.S. Patent No. 5,904,172 with a filing date
`
`of July 28, 1997, titled “VALVE ENCLOSURE ASSEMBLY”, naming inventors
`
`James Edwin Gifft and Paul James Mahoney. I will call this patent “Gifft ‘172”, “the
`
`patent”, and “’172”.
`
`6
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`10.
`
`I have been instructed and understand that the ‘172 patent has patent
`
`claims, that the claims are numbered statements at the end of the patent, that the
`
`claims define the invention that the patent protects, and that each claim is to be
`
`considered in its own right relative to other claims on the matter for which I consider
`
`it. I understand that the disputed claims of the ‘172 are claims 2 through 9 and 11
`
`through 25.
`
`11.
`
`I have been instructed and understand that the ‘172 patent is Exhibit
`
`1001 and is to be cited “G-” with additional page, line and similar references to the
`
`specific portions referenced.
`
`
`
`12.
`
`Invalidity:
`
`
`
`a.) Anticipation
`
`i.)
`
`I have been informed and understand that in order to
`
`demonstrate invalidity of a patent claim based on anticipation
`
`under 35 U.S.C. § 102, there must be clear and convincing
`
`evidence that (a) the invention was known or used by others in
`
`this country, or patented or described in a printed publication
`
`in this or a foreign country, before the invention thereof by the
`
`7
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`applicant for a patent, or (b) the invention was patented or
`
`described in a printed publication in this or a foreign country or
`
`in public use or on sale in this country, more than one year prior
`
`to the date of the application for patent in the United States. 35
`
`U.S.C. § 102(a), (b).
`
`ii.)
`
`I have been informed and understand that if every element in a
`
`claim is found—expressly or inherently—in a single prior art
`
`reference, then the claim is anticipated and invalid.1 This is
`
`also true even where the prior art reference did not appreciate
`
`or recognize the “inventive concept” of the invention claimed
`
`in the challenged patent (“Our cases have consistently held that
`
`a reference may anticipate even when the relevant properties of
`
`the thing disclosed were not appreciated at the time.”). 2
`
`
`
`
`1 See Planet Bingo, LLC v. Gametech Int’l, Inc., 472 F.3d 1338, 1346 (Fed. Cir.
`
`2006).
`
`2 Verdegaal Bros., Inc. v. Union Oil Co. of Cal., 814 F.2d 628, 633 (Fed. Cir.
`
`1987); see also Abbott Labs. v. Baxter Pharm. Prods. Inc., 471 F.3d 1363, 1367
`
`(Fed. Cir. 2006).
`
`8
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`b.) Obviousness
`
`i.)
`
`I have been informed and understand that a patent claim is invalid if
`
`it can be shown by clear and convincing evidence that “the
`
`differences between the subject matters sought to be patented and the
`
`prior art are such that the subject matter as a whole would have been
`
`obvious at the time the invention was made to a person having
`
`ordinary skill in the art to which said subject matter pertains.” 35
`
`U.S.C. § 103(a).
`
`ii.)
`
`I understand obviousness is a question of law that considers (1) the
`
`scope and content of the prior art; (2) any differences between the
`
`claimed subject matter and the prior art; (3) the level of skill of one
`
`in the art; and (4) where in evidence, so-called secondary
`
`considerations, such as commercial success, long-felt but unsolved
`
`needs, and the failures of others.3
`
`
`
`
`
`
`
`
`3 See Graham v. John Deere Co. of Kansas City, 383 U.S. 1, 17-18 (1966).
`
`9
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`13. Combining References:
`
`a.) Reason to Combine:
`
`i.)
`
`I have been informed that in order to combine prior art
`
`references in an obviousness analysis, motivation or
`
`reason to combine them must be articulated and made
`
`explicit. (“It is well established that “[t]he normal
`
`desire of artisans to improve upon what is already
`
`generally known can provide the motivation to
`
`optimize variables.”);4 (“[A]n implicit motivation to
`
`combine exists . . . when the ‘improvement’ is
`
`technology-independent and
`
`the combination of
`
`references results in a product or process that is more
`
`desirable, for example because it is stronger, cheaper,
`
`cleaner, faster, lighter, smaller, more durable, or more
`
`efficient.”).5
`
`
`4 In re Ethicon, 844 F.3d 1344, 1351 (Fed. Cir. 2017).
`
`5 See also DyStar Textilfarben GmbH & Co. Deutschland KG v. C.H. Patrick Co.,
`
`464 F.3d 1356, 1368 (Fed. Cir. 2006).
`
`10
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`ii.) An effort that merely makes a slight modification to the
`
`prior art using the same elements, performing the same
`
`functions, and achieving the same result is not novel.6
`
`“In determining whether the subject matter of a patent
`
`claim is obvious, neither the particular motivation nor
`
`the avowed purpose of the patentee controls.”7 Rather,
`
`“if a person of ordinary skill can implement a
`
`predictable variation [of a work], § 103 likely bars its
`
`patentability.”8
`
`iii.)
`
`I understand that it is improper to use hindsight as a
`
`reason to combine prior art references. In other words,
`
`it is improper to look to the patented invention, or
`
`references that post-date the patented invention, to find
`
`a reason to combine various references that pre-date the
`
`patented invention.
`
`
`6 KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007).
`
`7 KSR, 550 U.S. at 419.
`
`8 KSR, 550 U.S. at 401
`
`11
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`b.) All Elements
`
`i.)
`
`I understand that, even if a reason to combine prior art
`
`references were adequately articulated, the combination of
`
`prior art references must disclose every limitation of the
`
`claimed
`
`invention,
`
`in accordance with
`
`the Court’s
`
`interpretations of the claim language, the plain and ordinary
`
`meaning of the terms, and/or the parties’ agreed upon
`
`constructions.
`
`
`
`14.
`
`Indefiniteness: I have been informed and understand that a patent must
`
`conclude with one or more claims particularly pointing out and distinctly claiming
`
`the subject matter that the applicant regards as his invention. I have been informed
`
`and understand that claims are indefinite when “read in light of the specification
`
`delineating the patent, and the prosecution history,” they “fail to inform, with
`
`reasonable certainty, those skilled in the art about the scope of the invention.”9
`
`
`9 Nautilus, Inc. v. Biosig Instruments, Inc., 134 S.Ct. 2120 (2014).
`
`12
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`15.
`
`I have been informed and understand that even if a claim term’s
`
`definition can be put into words, the claim is still indefinite if a person of ordinary
`
`skill in the art cannot translate the definition into meaningfully precise claim scope.10
`
`
`
`III. BACKGROUND OF THE ‘172 INVENTION
`
`16. The ‘172 invention is comprised of an air mattress, a pump to fill the
`
`mattress, valves and an enclosure to direct air from the pump to the mattress and
`
`electronics to take user input and translate the user input into automatic control of
`
`the pump and valves. (see, e.g. the abstract of the ‘172). Air mattresses with pumps
`
`have been known for well over 100 years.
`
`17. The book by Thomas Hancock on manufacturing of rubber goods
`
`provides evidence of air mattresses with multiple independent chambers having been
`
`in production prior to 1856.11 Hancock describes single chamber air beds that were
`
`
`10 Halliburton Energy Servs., Inc. v. M-I LLC, 514 F.3d 1244 (2008).
`
`11 See “Personal narrative of the origin and progress of the cautchouc or India-
`
`rubber manufacture in England” by Thomas Hancock, published in 1856. It
`
`includes a patent from 1847 for “Vulcanised Solutions” granted (England) to
`
`Thomas Hancock and Reuben Phillips that describes air beds (“pneumatic beds”).
`
`13
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`unusable as beds when use was attempted that then evolved into independent multi-
`
`chambered air beds that were functionally feasible for users. This book describes
`
`methods to fill the air-beds with air from a manual pump (bellows). The Hancock
`
`1856 book ties a multitude of inflatable objects together and it also ties associated
`
`components together to those objects in the art including air- and water- cushions,
`
`air- and water- beds, life preservers, pumps (manual), valves, inflatable boats,
`
`pontoons, flexible seals (i.e. gaskets, rubber washers, “washers for flange and socket
`
`joints,” etc.), pistons/stems, and other applications of air tight materials. See Figure
`
`1, below.
`
`18. The ‘172 patent uses automatic feedback control to energize a pump
`
`and solenoid valves inside of an enclosure while receiving commands from the user
`
`and feedback from a pressure sensor. The specific type of valve used in the ‘172 is
`
`pilot-operated poppet check valve. Enclosures that divert air streams have been
`
`known for hundreds of years and the term for such a device is: manifold. Manifolds
`
`are used in nearly every application where fluid is diverted from one stream into
`
`multiple streams.
`
`19. Manifolds are common pieces of equipment today and they were
`
`common pieces of equipment well before the ‘172 application. They are common in
`
`hydraulic applications, and any application where one is interested in dividing or
`
`adding air streams. Another common application of manifolds is that by their nature
`
`14
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`

`they are objects that are substantially air tight and provide a solid base where sensors,
`
`like flow or pressure sensors, can be easily mounted. Even today, when searching
`
`for split-hoses on the primary industrial site, McMaster.com, there are no air hoses
`
`that split, only manifolds whereby one duct or hose can be connected to multiple
`
`hoses.
`
`Figure 1. Images from Hancock. Hancock’s air-bed and manual pumps (bellows),
`
`sections of valves and pumps (including stops), flexible seals, and a one way “flap”
`
`or check valve, as published in his 1856 book. The independent chambers of the air
`
`beds are visible in the images. Bellows, or manual hand pumps, contain at least two
`
`check valves in order to function (one for filling and one for expelling air).
`
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`20. The type of valve taught by the ‘172 is, at its most basic description, a
`
`poppet check valve. A poppet valve includes a stem and a head that form the poppet,
`
`similar to a piston, where the movement of the poppet engages a seat which can seal
`
`an opening, selectively allowing the valve to open and close. A check valve is a
`
`valve that allows fluid flow in one direction, but then closes when the fluid attempts
`
`to flow in the opposite direction, and frequently include a spring or other compliant
`
`member to assist with valve closure. These check valves and poppet valves have
`
`been known for at least 100 or more years prior to the application of the ‘172, a good
`
`example of a poppet check valve is the typical nozzle on a bicycle tire, that is
`
`compatible with the typical air chuck pump nozzle. A valve whose opening or
`
`closing action is assisted by pressure or other means, e.g. electro-mechanical, is
`
`called a pilot valve, or pilot-operated valve. Pilot valves are common valves.
`
`Because the action of the valve in the ‘172 is assisted by a solenoid, it is a pilot-
`
`operated poppet check valve. These valves were known in the art prior to the
`
`application of the ‘172, see for example the 1982 patent issued to Kolchinsky and
`
`Kazi for a “cartridge solenoid poppet valve arranged to use a single size pilot valve”
`
`(US Patent 4,540,154 “Solenoid Valve”).
`
`21.
`
`In support of this historical concept of the poppet valve, poppet check
`
`valve, and pilot-operated poppet check valve, textbook references contemporary
`
`with the ‘172 corroborate the fact that these types of poppet valves and features of
`
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`poppet valves were well known before the priority date of the ‘172. At least three
`
`textbooks from the timeframe of the ‘172 provide examples that describe features of
`
`the ‘172 valve. These books are the “Power Transmission Handbook,” “Pneumatic
`
`Systems Principles and Maintenance,” and “the Valve Primer.”
`
`22. The First Edition Power Transmission Handbook, a book that is
`
`essentially an encyclopedia of common mechanical elements ranging from
`
`hydraulics to conveyors to pressure sensors and computer feedback control, was
`
`published in 1993 (see, e.g., Ex. 1027). The First Edition Power Transmission
`
`Handbook (“PT Handbook”) from 1993 also describes compressors, valves,
`
`hydrostatic drives, fluid power drives, and valves (see, e.g., Ex.1028). The PT
`
`Handbook describes poppet mechanisms: “the relative position of the poppet with
`
`respect to a seat controls fluid flow. Cartridge valves consist of a poppet, sleeve, and
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`spring that are contained within a machined manifold block…Valves are actuated
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`by various means...Electrically actuated valves are normally powered by small
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`solenoids. The solenoid plunger moves the spool or poppet directly on small
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`valves…These are called solenoid-controlled, pilot-operated valves.”
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` This
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`description is consistent with the terminology described above. The image
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`accompanying this description in the PT Handbook (Ex. 1028 Fig. 9-12) shows a
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`poppet situated inside of a guide and sealing against a seat.
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`23. The book entitled “Pneumatic Systems Principles and Maintenance” by
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`SR Majumdar © 1995, states “Electromagnet is very commonly used for actuation
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`of pneumatic valves. It consists of a plunger in a ‘C’ frame structure. The armature
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`plunger
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`presses
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`on
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`the
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`valve
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`spool when
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`the
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`electromagnet
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`is
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`excited…Disadvantage of magnetic actuation Sensitive against mechanical load.”
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`(No emphasis added). When seated, the poppet is stopped by the seat, and is guided
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`to the seat through the housing, i.e. the “C” frame structure. This book goes on to
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`state that a seat valve is better than a spool valve if a leak-proof arrangement is
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`desired.
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`24. The textbook entitled “The Valve Primer” by Brent Stojkov © 1997,
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`describes many types of valves, including check valves. Stojkov calls poppet valves
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`“lift valves” and indicates that these valves include a piston or disc as the flow
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`control element. Stojkov states that piston check valves are commonly used at places
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`in a system where different portions join at a common header (i.e. a manifold), at the
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`outlet of centrifugal pumps, and to isolate separate services connected to a common
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`header to prevent fluid flow from one service to another. Stojkov explicitly states
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`in the chapter on check valves that “piston and disc flow control elements must be
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`guided to ensure alignment of the seating surfaces.” Stojkov also includes
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`illustrations showing guides and stops in the lift valves and actuators, see Figure 2,
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`below.
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`Figure 2. Stojkov figs. 4-6, 12-4, and 12-5 showing stem guides and piston stops in
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`
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`poppet type valves.
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`25. Stojkov also provides definitions for valve elements, which are
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`generally consistent with the description of valve elements herein. For example,
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`Stojkov includes the following definitions in his textbook:
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`a. Flow control element as: “The part of a valve that obstructs and
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`controls fluid flow; it determines the valve type and the nature of
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`fluid control for which the valve is suited.”
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`b. Seat as: “The portion of the valve body that the flow control
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`element contacts to seal against internal leakage; it can be a separate
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`part fastened in the body or can be integral with the body (a
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`machined surface in the body).”
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`c. Lift check valve as: “A type of check valve in which the flow
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`control element moves parallel to the direction of fluid flow; the
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`force of the fluid lifts the flow control element off its seat.”
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`d. Disc as: “The flow control element of a globe valve, check valve,
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`or butterfly valve.”
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`e. Controller as: “A component of an automatic control system; it
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`compares input and feedback signals and generates an error signal
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`based on the difference between the two.”
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`f. Conical seat as: “A design of a globe valve seat in which the seating
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`surfaces of both the disc and the seat ring are cone-shaped.”
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`g. Stem as: “The part of a gate valve, globe valve, or diaphragm valve
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`that moves the flow control unit.”
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`h. Linear valve actuator as: “An actuator that produces linear motion
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`for use with valves having translating stems, that is, gate, globe,
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`and diaphragm valves.” (E.g., a solenoid).
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`26. While there are textbooks, as shown above, that describe the features
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`of poppet valves known at the time of the ‘172, numerous examples of aged prior art
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`also exist that inform the reader of the need for stops, guides, alignment, and
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`arrangement of solenoids inside of air chambers for usage in poppet check valves.
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`A non-exhaustive chronological list of exemplar art with some excerpts from the art
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`is provided below:
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`a. Poppet valve. US 2,364,812 (1944), Exhibit 1016
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`• “A washer 29 adjoins a guide aperture 30 in the lock nut 27
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`for resilient engagement with the pin 28 so as to exclude the
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`admission of dirt particles, moisture, and other foreign
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`material… the bore 23 guides the head 22 during the
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`unseating operation and yet allows sufficient relative
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`swiveling motion between the head 22 and pin 28 to provide
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`accurate mating between the head 22 and the seat 5… guide
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`body G shown in Fig. 2 in that it comprises a tubular member
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`adapted to enclose and guide a poppet valve P' for movement
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`to and from a valve seat 5'. Additionally, the upper body U
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`provides an annular discharge chamber f8 formed between its
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`outer periphery and the inner periphery of the cylindrical
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`casing form…”
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`b. Self-aligning poppet valve. US 2,713,986 A (1955), Exhibit 1017
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`• “Furthermore, even with precision machining of the valve
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`components the desired seal is frequently not present after the
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`valve has been in use for a substantial length of time since
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`wear of the valve seat or poppet may cause misalignment,
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`lack of concentricity, and other factors resulting in leakage.
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`In addition to creating leakage the excessive wear on the
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`poppet and seat may disrupt the operation of the valve, for
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`example when the valve is of a balanced type and it is
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`necessary that the various sealing diameters be maintained
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`constant.”
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`c. Check valve with self-centering poppet. US 3,346,009 A (1967),
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`Exhibit 1018
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`• " The nub of the present invention is the elimination of the
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`cage which slides within the valve body to support and guide
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`the poppet into and out of valve seating position and to
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`transfer these functions to a uniquely constructed spring”
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`d. Check valve. US 4,368,756 A (1983), Exhibit 1019
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`• “A guide for a poppet in a check valve includes an annular,
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`cylindrical rim and a guide hub concentric therewith. At least
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`one web extends radially from the guide hub to the rim. The
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`outer periphery of the rim includes at least one projection
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`defined at a position angularly spaced from the web. The
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`projection is engaged by the inner periphery of the check
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`valve such that the guide is held within the check valve, with
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`a stem on the poppet extending through the guide hub. The
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`guide hub includes at least one lug to engage the stem to
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`prevent rotation of the stem