throbber
Exhibit 2085
`Claim Chart of ‘834 Patent as Applied to WeatherTech Tool No. 00814 for
`2013 – 2018 Dodge RAM 1500 Quad Cab (PS)
`U.S. Patent No.
`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`8,336,834 B2
`RAM 1500 Quad Cab (PS)
`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:
`
`WeatherTech molds vehicle floor trays on Tool No. 00814 to
`fit into the passenger’s side (PS) vehicle foot well of the
`2013 – 2018 Dodge RAM 1500 Quad Cab. This tray may be
`installed by a consumer into the predetermined vehicle foot
`well for which it is made. As depicted below, the 2013 –
`2018 Dodge RAM 1500 Quad Cab and any tray molded on
`WeatherTech Tool No. 00814, specially made for this
`vehicle, constitute a “system” as claimed.
`
`floor tray
`
`foot
`well
`
`1
`
`MacNeil Exhibit 2085
`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;
`
`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`As depicted below, the vehicle foot well includes a floor
`and 1st, 2nd and 3rd foot well walls joined to and extending
`upward from the floor. The 1st and 3rd foot well walls are
`longitudinally disposed while the 2nd foot well wall is
`transversely disposed.
`
`2nd wall
`
`3rd
`wall
`
`floor
`
`1st wall
`
`2
`
`MacNeil Exhibit 2085
`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. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness.
`
`vehicle floor tray
`
`polymeric sheet of uniform
`thickness
`
`3
`
`MacNeil Exhibit 2085
`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,
`
`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,
`
`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`As depicted below, the central panel of the tray substantially
`conforms to the floor of the foot well.
`
`Central
`panel
`Floor of
`
`Floor
`of foot
`well
`
`As depicted below, a 1st tray wall is joined to the central
`panel by a curved transition and upwardly extends from the
`central panel. In use, the 1st tray wall substantially
`conforms to the 1st foot well wall.
`
`1st tray
`wall
`
`1st f. w.
`wall
`
`curved transition
`
`central
`panel
`
`4
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`

`

`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. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`As depicted below, a 2nd tray wall is substantially
`transversely disposed and is joined to the central panel and
`to the 1st tray wall by respective curved transitions. The 2nd
`tray wall stands up from the central panel so as to
`substantially conform to the 2nd foot well wall.
`
`Curved
`transition
`
`1st tray
`wall
`
`2nd f. w.
`wall
`
`2nd tray
`wall
`
`Curved
`transition
`
`Central
`panel
`
`5
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`

`

`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`As depicted below, a substantially longitudinally disposed
`3rd tray wall is joined to the 2nd tray wall and to the central
`panel by respective curved transitions. The 3rd tray wall
`stands up from the central panel.
`
`2nd tray wall
`
`Curved
`transitions
`
`3rd tray
`wall
`
`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
`
`6
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`

`

`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,
`
`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`Shown below are the outer surfaces of the 1st, 2nd and 3rd
`tray walls and of the central panel. The inner (upper)
`surfaces have been shown above.
`
`Outer
`surface of
`1st
`Tray wall
`
`Outer
`surface of
`Central
`panel
`
`Outer
`surface of
`2nd tray wall
`
`7
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`

`

`U.S. Patent No.
`8,336,834 B2
`Claim 1
`
`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`Outer
`surface of
`3rd tray
`wall
`
`8
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`

`

`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`As depicted below, the thicknesses of the central panel, the
`1st tray wall, the 2nd tray wall and the 3rd tray wall 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
`thereof being
`substantially
`uniform
`throughout the
`tray;
`
`9
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`

`

`WeatherTech Tool No. 00814 for 2013 – 2018 Dodge
`RAM 1500 Quad Cab (PS)
`
`The images below show, in color, the top 1/3 of the inner
`surfaces of the 1st, 2nd and 3rd panels. 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
`bottom/outside of the tray. At least 90% of these outer
`surfaces are no more than 1/8 inch from the respective foot
`well walls.
`
`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 tray walls
`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.
`
`Top
`1/3
`
`10
`
`MacNeil Exhibit 2085
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`

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