`Claim Chart of ‘834 Patent Claim 1 as Applied to WeatherTech Tool No.
`02554 for 2014 – 2018 Chevrolet Silverado/Sierra 1500/2500HD/3500HD
`Double Cab (PS)
`WeatherTech Tool No. 02554 for 2014 – 2018
`Chevrolet Silverado/ Sierra 1500/2500HD/3500HD
`Double Cab (PS)
`WeatherTech molds vehicle floor trays on Tool No. 02554
`to fit into the passenger’s side (PS) vehicle foot well of the
`2014 – 2018 Chevrolet Silverado / Sierra 1500 / 2500HD /
`3500HD Double Cab. This tray may be installed by a
`consumer into a predetermined foot well of the vehicle,
`here the passenger’s side (PS) foot well. As depicted
`below, the 2014 – 2018 Chevrolet Silverado / Sierra
`1500/2500HD/3500HD Double Cab and any tray molded
`on WeatherTech Tool No. 02554, specially made for this
`vehicle, constitute a “system” as claimed.
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`A system
`including a
`vehicle and a
`floor tray for
`consumer
`installation into a
`predetermined
`foot well of the
`vehicle, the
`system
`comprising:
`
` Floor
`tray
`
`Foot
`well
`
`1
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a vehicle foot
`well having a
`floor, a
`substantially
`longitudinally
`disposed first foot
`well wall
`upstanding from
`the floor, a
`substantially
`transversely
`disposed second
`foot well wall
`upstanding from
`the floor and
`joined to the first
`foot well wall, a
`substantially
`longitudinally
`disposed third
`foot well wall
`upstanding from
`the floor and
`joined to the
`second foot well
`wall; and
`
`WeatherTech Tool No. 02554 for 2014 – 2018
`Chevrolet Silverado/ Sierra 1500/2500HD/3500HD
`Double Cab (PS)
`As depicted below, the vehicle foot well has a
`substantially carpeted upper surface. The foot well upper
`surface includes a floor and 1st, 2nd and 3rd walls extending
`upward from the floor.
`
`2nd f.
`w. wall
`
`Floor
`
`3rd f. w.
`wall
`
`1st f. w.
`wall
`
`2nd f.
`w. wall
`
`Floor
`
`2
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a vehicle floor
`tray molded from
`a sheet of
`polymeric
`material of
`substantially
`uniform
`thickness,
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness.
`
`Tray
`
`Sheet of
`uniform
`thickness
`
`3
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a central panel of
`the tray
`substantially
`conforming to the
`floor of the
`vehicle foot well,
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`As depicted below, the floor of the tray substantially
`conforms to the floor of the foot well.
`
`Central
`Panel
`
`Floor of
`foot well
`
`4
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`As depicted below, a 1st tray wall is joined to the central
`panel by way of a curved transition and upwardly extends
`from the floor of the tray. In use, the 1st panel substantially
`conforms to the 1st foot well wall.
`
`1st F. W. wall
`
`1st tray wall
`
`Curved
`transition
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a substantially
`longitudinally
`disposed first tray
`wall joined to the
`central panel by a
`curved transition
`and standing up
`from the central
`panel to
`substantially
`conform to the
`first foot well
`wall,
`
`Central
`panel
`
`5
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a substantially
`transversely
`disposed second
`tray wall joined
`to the central
`panel and to the
`first tray wall by
`respective curved
`transitions and
`standing up from
`the central panel,
`the second tray
`wall substantially
`conforming to the
`second foot well
`wall,
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`As depicted below, a 2nd tray wall is joined to the central
`panel and to the 1st tray wall by respective curved transitions
`and stands up from the central panel. In use, the 2nd tray wall
`substantially conforms to the 2nd foot well wall.
`
`1st
`tray
`wall
`
`Curved
`transitions
`
`2nd
`tray
`wall
`
`2nd f. w.
`wall
`
`Central
`panel
`
`6
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`As depicted below, a 3rd tray wall is joined to the central
`panel and to the 2nd tray wall by respective curved transitions
`and stands up from the central panel.
`
`2nd tray
`wall
`
`Curved
`transition
`2nd tray
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a substantially
`longitudinally
`disposed third
`tray wall joined
`to the central
`panel and to the
`second tray wall
`by respective
`curved transitions
`and standing up
`from the central
`panel,
`
`Central panel
`
`Curved
`transition
`2nd tray
`
`3rd tray wall
`
`7
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`Depicted below are the outer surfaces of the 1st, 2nd and 3rd
`tray walls and the central panel. The inner (upper) surfaces
`of the tray have been shown above.
`
`Outer
`surface, 2nd
`tray wall
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`The central panel
`and first, second
`and third tray
`walls each having
`an outer surface
`facing the vehicle
`foot well and an
`inner surface
`opposed to the
`outer surface,
`
`Outer
`surface, 1st
`tray wall
`
`Outer
`surface,
`central panel
`
`8
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`Outer
`surface, 3rdt
`tray wall
`
`9
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`As depicted below, the thicknesses of the central panel and
`of the 1st, 2nd and 3rd tray walls, as measured between the
`outer surfaces and the inner surfaces thereof, are
`substantially uniform throughout the tray.
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`a thickness of the
`central panel and
`of the, first,
`second and third
`tray walls
`measured
`between the outer
`surface and the
`inner surface
`being
`substantially
`uniformly
`throughout the
`tray;
`
`10
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`WeatherTech Tool No. 02554 for 2014 – 2018 Chevrolet
`Silverado/ Sierra 1500/2500HD/3500HD Double Cab (PS)
`
`The image below shows, in color, the top 1/3 of the inner
`surfaces of the 1st, 2nd and 3rd tray walls. The top 1/3 of the
`outer surfaces of the 1st, 2nd and 3rd panels correspond to the
`colored areas and are opposite from them, on the outside of
`the tray. At least 90% of these outer surfaces are no more
`than 1/8 inch from the foot well wall to which the tray wall
`in question substantially
`conforms.
`
`Top 1/3
`
`U.S. Patent No.
`8,336,834 B2
`Claim 1
`at least 90
`percent of that
`one-third of the
`outer surfaces of
`the first, second,
`and third outer
`surfaces which
`are closest to the
`respective top
`margins of the
`first, second or
`third tray walls
`being within one-
`eighth of an inch
`of the respective
`foot well walls.
`
`11
`
`MacNeil Exhibit 2084
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`