BIEN FAIT
`Translation and Patent Services
`Bruce D. Popp, PhD
`ATA Certified Translator, French into English
`USPTO Registered Patent Agent
`
`DECLARATION OF BRUCE D. POPP
`
`I, Bruce D. Popp, hereby declare as follows:
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`1.
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`I possess advanced knowledge of the French and English languages. I have
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`more than 15 years of experience translating patents and patent-related
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`documentation from French into English. I have been an independent
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`translator since 2002.
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`2.
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`I am certified by the American Translators Association for French into
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`English translations. In 2017, I was the recipient of the S. Edmund Berger
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`Prize for Excellence in Scientific and Technical Translation.
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`3.
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`I am a grader (for French into English) in the American Translators
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`Association Certification Program.
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`4.
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`I am a registered patent agent with the United States Patent and Trademark
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`Office (registration number 66903).
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`5.
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`I have in-depth knowledge of relevant sections of the European Patent
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`Convention and French Code de la propriete industrielle.
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`BDPopp@bien-
`fait.com
`
`660 BOAS ST., APT. 1011
`HARRISBURG, PA 17102
`UNITED STATES
`
`866-243-6324
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`6.
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`I have translated over 500 French and European patents to English.
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`7.
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`I was awarded a PhD degree in Astronomy by Harvard University in 1985
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`and an AB in Physics, magna cum laude, by Cornell University in 1979.
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`8.
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`I have received the Diplome approfondi de la langue francaise, C2 level
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`(mastery) certification in French-language abilities.
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`9.
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`I have authored the following publications in the previous ten years:
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`•
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`I currently have a book project in the field history of physics under
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`contract with Springer with a tentative publication date in 2023.
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`• Henri Poincare: From Electrons to Special Relativity, Springer, New
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`York, 2020.
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`• Dealing with Terminology Drift, The ATA Chronicle, vol. XLVIII,
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`num. 1, Jan/Feb. 2019.
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`• The Three-Body Problem and the Equations of Dynamics: Poincare's
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`Foundational Work on Dynamical Systems Theory, Springer, New
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`York, 2017.
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`• Accuracy in Patent Translation, Boston Patent Law Association
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`Newsletter, vol. 40, issue 3, summer 2010.
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`• Using Patents to Find the Terminology You Need, The ATA Chronicle,
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`vol. XXXVIII, num. 5, May 2009.
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`10. I have reviewed and been asked to comment on the translation of French
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`Patent Application Pre-Grant Publication No. 2547252 to Rabbe, prepared
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`by Mr. John Dawson and submitted by Petitioner Yita LLC as Exhibit 1005
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`in IPR2020-01139 and IPR2020-01142.
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`11. I prepared for that review by independently translating the Rabbe patent. In
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`preparing that translation I used my preferred, standard reference works
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`including:
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`• Le Petit Robert de la langue francaise © 2017 Dictionnaires Le Robert:
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`a software application installed on my computer and sold by a leading
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`French publisher of dictionaries. I have used this reference work for
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`several years and consider it to be a reliable authority. It is a French
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`dictionary, and does not provide translations to English.
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`• Collins Le Robert Comprehensive Dictionary: French-English,
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`English-French © 2017 Dictionnaires Le Robert/HarperCollins
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`Publishers: also a software application installed on my computer. I have
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`used this reference work for several years and consider it to be a reliable
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`authority. It
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`is a French-into-English and English-into-French
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`dictionary.
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`12. This translation that I prepared is attached to my declaration as Attachment
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`A. As indicated above, I am a professional translator fluent in French and
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`English and I am American Translators Association Certified for translation
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`from French into English. I state that to the best of my knowledge and belief
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`I have accurately translated the Rabbe patent from French into English and
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`that said accurate translation is attached.
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`13. The French word "rebord" is used in several places in the Rabbe reference.
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`One place "rebord" is used is in Claim 4. Ex. 1005, p. 016. Claim 4 of Rabbe
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`uses the term "rebord" and makes reference to numeral "(4)" of the drawings.
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`Figures 3 and 4, for example, include reference numeral 4:
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`3
`
`2
`
`2
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`4
`
`4
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`14. In Claim 4, Mr. Dawson has translated "rebord" as "flange." Ex. 1005, p. 6.
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`I translated the same term as "rims." While I prefer "rims" as a better
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`translation, the translation to "flange" is not indefensible. There is at least
`
`some dictionary support for that translation as noted below. However, the
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`typical French words for "flange" would be "bride" or "collerette." See Ex.
`
`2029, Richard Ernst, Dictionnaire des techniques et sciences appliquees
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`published in Paris in 2002 by Dunod, pages 138 and 233, and also Ex. 2025,
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`Collins Le Robert Comprehensive Dictionary, referenced above. If one
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`meant to use the term "flange" in French, one would typically choose "bride"
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`or "collerette." Thus, it would not be typical to translate "rebord" as "flange"
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`unless the context in which the word was used clearly indicated more
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`common translations of "rebord" did not make sense.
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`15. Ex. 2025 contains the entry for "rebord" from the 2017 Collins Le Robert
`
`Comprehensive Dictionary, referenced above. That dictionary includes
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`"rim," "edge" and "hem" as options for translating rebord. Ex. 2025 also
`
`contains the entry for "bride," including "flange" or "strap" as options for
`
`translating bride, and the entry for "collerette," including "flange" as an
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`option for translating collerette.
`
`16. Ex. 2026 is the entry for "rebord" from the Collins 1993 French to English
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`dictionary. That dictionary includes "rim" "edge," "window sill," and
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`"window ledge" as options for rebord.
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`17. Ex. 2027 is the entry for "rebord" from the Larousse 2010 French to English
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`dictionary. That dictionary includes "edge," "rim," "mantlepiece," and
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`"ledge" as options for translating rebord.
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`18. Ex. 2028 is the entry for "rebord" from the Collins 1964 French to English
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`dictionary. That dictionary includes "edge," "hem," "border," "rim," and
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`"flange" as options for translating rebord.
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`19. Ex. 2029 contains the entry for "rebord," from the Ernst 2002 Dictionnaire
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`des techniques et sciences appliquees French to English dictionary, including
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`"shoulder, edge," "rim," "lining, bordering," "moulding," "detachable
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`endless flange," "detachable spring flange," "gearbox flange," "brim, edge
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`of a cavity," "window sill," "choke flange," "wheel rim" and "edge of
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`flange" as options for translating rebord, alone and in combination and in
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`various technical fields. Ex. 2029 also contains the entry for "bride,"
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`including "strap," "flange," and "collar" as options for translating bride, and
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`the entry for "collerette," including "skirt" and "flange" as options for
`
`translating collerette.
`
`20. A second use of the term "rebord" appears on Page 2 of Rabbe. Again, the
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`term is used in connection with reference numeral 4. Ex. 1005, p. 15 (see
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`Line 18). Mr. Dawson again has translated "rebord" as "flange." Ex. 1005,
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`p. 5 (see line 14).
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`21. A third use of the term "rebord" appears on the cover page of Rabbe. Again,
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`the term is used in connection with reference numeral 4. Ex. 1005, p. 13.
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`Mr. Dawson again has translated "rebord" as "flange." Ex. 1005, p. 3.
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`22. A fourth use of the term "rebord" appears in Claim 6 of Rabbe. Ex. 1005, p.
`
`16. Mr. Dawson again has translated "rebord" as "flange." Ex. 1005, p. 6
`
`(see line 21).
`
`23. A fifth use of the term "rebord" appears on Page 1 of Rabbe. Ex. 1005, p. 14
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`(see Line 3). Mr. Dawson here has translated "rebord" as "sides." Ex. 1005,
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`p. 4 (see Line 3). This translation is not consistent with the meanings of
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`"rebord" that I am aware of. I believe this translation is wrong for at least
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`three reasons.
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`24. First, none of the dictionaries cited in this declaration include "sides" as a
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`meaning of "rebord" and I am not aware of one that does.
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`25. Second, Mr. Dawson translated the term "rebord" four different times as
`
`"flange." Given that Mr. Rabbe chose this specific term to refer to what is
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`shown by numeral 4 in the drawings, the term should be translated
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`consistently unless there is a compelling reason not to do so.
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`26. Third, as a matter of physics, given that the rims (or flanges as Mr. Dawson
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`calls them), labeled 4 in the drawings of the Rabbe patent, stick out from the
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`side, it is logical that these rims, not the "sides" would conform to the relief
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`of the vehicle interior. In each of the Figures of the Rabbe patent, the rims 4
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`are shown as protruding from the sides of the tray. As these are said to
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`provide stability for the assembly, the contact of the rims with the walls of
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`the vehicle would push the sides of the tray away from the sides of the
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`footwell of the vehicle.
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`27. I affirm that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true.
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`I declare under penalty of perjury under the laws of the United States that
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`the foregoing is true and correct.
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`Executed on:
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`3 07(2(31
`
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`
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`
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`
`Vet AVIV444taivekre'reity
`
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`Attaghmcnt A
`Attachment A
`
`. MacNeiI Exhibit 2024
`
`Yita v. MacNeiI IP, |PR2020-01139
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`Page 9
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`MacNeil Exhibit 2024
`Yita v. MacNeil IP, IPR2020-01139
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`(19)
`
`FRENCH REPUBLIC
`
`INSTITUT NATIONAL
`
`DE LA PROPRIETE INDUSTRIELLE
`
`PARIS
`
`(11)
`
`Publication Number:
`
`(Only to be used for
`copy orders)
`National registration number:
`
`Int Cl3: B 60 N 3/04.
`
`(21)
`
`(51)
`
`2,547,252
`
`83/009624
`
`(12)
`
`UTILITY PATENT APPLICATION
`
`Al
`
`(22) Filing date: June 8, 1983.
`(30) Priority:
`
`(43) Date application made available to the public: BOPI
`« Brevets » num. 50 of December 14, 1984.
`(60) References to other related national documents:
`
`(71)
`
`(72)
`
`Applicant(s): Rabbe, Michel. — FR.
`
`Inventor(s): Michel Rabbe.
`
`(73)
`
`Owner(s):
`
`(74)
`
`Agent(s):
`
`(54) Protection-Tray for Vehicle Interiors.
`
`(57) 1. "Protection-Tray" for Vehicle Interiors.
`2. The invention relates to floormats with raised edges that form
`trays and provide effective protection of the floors and lateral walls
`of vehicle interiors near the driver's feet, passengers' feet and also
`trunks against water, mud, snow and other dirt.
`The protection-tray is made of semirigid rubber or other material
`having the same properties. The pliability of the material used gives
`it good handling and the stiffness flattens the raised edges against the
`walls.
`3. The floor 1 is entirely covered. The raised edges conform to
`the relief of the passenger compartment 2 and 3, and do not change
`the aesthetic appearance sought by the manufacturer. Some rims 4
`are retaining in order to provide a good stability to the assembly.
`Judiciously arranged handles 5 make handling and placement of the
`protection-tray easier.
`
`5
`
`3
`
`4 -
`
`/
`
`-2
`
`Booklets sold at IMPRIMERIE NATIONALE [Government Printing Office]. 27, rue de la Convention 75732 PARIS CEDE( 15
`
`FR 2,547,252 - Al
`
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`2547252
`
`1
`The subject matter of the present invention is the protection of floors and lateral walls of
`vehicle interiors; the invention relates to car floormats, in tray form for which rims perfectly
`conform to the relief of the vehicle interior, near the driver's feet, front and rear passengers'
`feet and also the front and rear trunks, for the purpose of assuring effective protection against
`any dirt.
`
`In known devices of this type, only the floor is protected, and partially at that, against
`water, mud, snow and other dirt. As a result, the vehicle interior is poorly protected and is
`harmed. Maintenance, often difficult, must be done frequently if one wants to maintain a
`presentable interior. Transporting dirtying materials in the trunk, such as sand, is not
`possible, unless lots of time is spent detaching and cleaning the walls.
`These disadvantages can be avoided with the protection-tray according to the invention.
`The edges thereof, with unequal heights, are raised several centimeters around the entire
`
`perimeter thereof and serve to keep the dirt inside the tray thus formed. The protection-tray,
`made of semi-rigid rubber or another material having the same properties, follows the relief
`
`5
`
`10
`
`15
`
`of the passenger compartment and because of the pliability thereof the handling and
`
`placement thereof are simple. The stiffness of the material used flattens the assembly against
`
`the lateral walls of the vehicle. Once the protection-tray is out of the vehicle, cleaning is easy,
`
`spraying off is sufficient. The transport in the trunk of sand, gravel, more or less sealed jugs
`
`does not present any problem for maintenance of the vehicle. Muddy boots, snow and water
`
`20
`
`cannot harm the vehicle interiors. The thinness of the material used only infringes a few
`
`millimeters into the space designed by the vehicle manufacturer and therefore does not
`
`change the aesthetic appearance sought.
`
`The attached plates are given as examples:
`Plate 1/5 is a rear three-quarter profile view at an angle of 45° of a protection-tray for a "Lada
`
`25 Niva" 4x4 trunk, with the rear seat folded down forward.
`
`Plate 2/5 is a rear three-quarter profile view at an angle of 45° of a protection-tray for a "Lada
`
`Niva" 4x4 trunk, with the rear seat in functional position.
`
`Plate 3/5 is a rear three-quarter profile view at an angle of 45° of a protection-tray positioned
`under the feet of the driver of a Lada Niva 4x4.
`
`30
`
`Plate 4/5 is a rear three-quarter profile view at an angle of 45° of a protection-tray positioned
`
`under the feet of the front passenger of a Lada Niva 4x4.
`Plate 5/5 is a front three-quarter profile view at an angle of 45° of a protection-tray positioned
`under the feet of the rear passengers of a Lada Niva 4x4.
`
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`2
`
`2547252
`
`As shown, the protection-tray comprises: a) a striated bottom (1) covering the entire
`floor; b) raised edges (2) with unequal heights following the interior relief of the vehicle, in
`particular the wheel wells (3). The walls and the bottoms are made of semi-rigid rubber or
`another material having the same properties. Pressure exerted on the walls, by using
`
`5
`
`judiciously arranged handles (5), folds the walls and serves to release the protection-tray in
`
`order for it to be withdrawn from the vehicle compartment.
`
`Some rims will have retentive shape (4) so as to get a better stability of the assembly.
`The present invention may equip any vehicle, whether they are for tourism or utility.
`
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`3
`
`CLAIMS
`
`2547252
`
`1) A protection-tray for automobile or other vehicle, characterized by the fact that the
`protective edges are raised over the entire perimeter, by unequal heights according to the
`relief encountered, in order to form a tray, made of semi-rigid rubber or another material
`
`5
`
`having the same properties, intended to protect the floor and the interior walls of the
`
`vehicle against any dirt.
`
`2) The protection-tray according to claim 1, characterized in that the raised edges conform
`
`to the relief of the passenger compartment (3).
`3) The protection-tray according to claims 1 and 2, characterized in that the pliability of the
`material gives it good handling and in that the stiffness of the material serves to flatten it
`against the walls of the passenger compartment.
`4) The protection-tray according to claims 1, 2 and 3, characterized in that the rims may be
`retaining (4) in order to increase the stability of the assembly.
`5) The protection-tray according to claim 1, characterized in that the bottom thereof is
`striated in the direction of the length in order to limit transverse sliding. (1).
`6) The protection-tray according to claims 1, 2, 3 and 4, characterized in that the rims may
`be equipped with handles (5) in order to make handling easier.
`
`10
`
`15
`
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`2547252
`
`2547252
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`1/5
`1/5
`
`
`
`z
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`2547252
`2547252
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`2/5
`2/5
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`
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`MacNeiI Exhibit 2024
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`Page 15
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`2547252
`2547252
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`3/5
`3/5
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`
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`MacNeiI Exhibit 2024
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`2547252
`2547252
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`4/5
`4/5
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`
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`2547252
`2547252
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`5/5
`5/5
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`
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