`Claim Chart of ‘834 Patent Claim 1 as Applied to WeatherTech Tool No.
`01846 for 2014 – 2018 Jeep Wrangler JK 4 Door Unlimited (PS)
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`WeatherTech molds vehicle floor trays on Tool No. 01846
`to fit into the passenger’s side (PS) vehicle foot well of the
`2014 – 2018 Jeep Wrangler JK 4 Door Unlimited. This
`vehicle floor 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
`Jeep Wrangler JK 4 Door Unlimited and any tray made on
`Tool No. 01846, as specially made for this vehicle,
`constitute a “system” as claimed.
`
`U.S. Patent
`No. 8,833,834
`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:
`
`1
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As depicted below, the vehicle foot well has a floor, a
`substantially longitudinally disposed first foot well wall, a
`substantially transversely disposed second foot well wall
`joined to the first foot well wall, and a substantially
`longitudinally disposed third foot well wall joined to the
`second foot well wall. The first, second and third foot well
`walls stand up from the floor.
`
`U.S. Patent No.
`8,833,834 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
`
`2
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`3
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness. The
`second photo below is of a stack of polymeric sheets prior to
`being molded into floor trays.
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`a vehicle floor
`tray molded
`from a sheet of
`polymeric
`material of
`substantially
`uniform
`thickness,
`
`4
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`5
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As depicted below, the central panel of the tray substantially
`conforms to the floor of the foot well.
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`a central panel of
`the tray
`substantially
`conforming to
`the floor of the
`vehicle foot
`well,
`
`6
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As depicted below, a substantially longitudinally disposed first
`tray wall is joined to the central panel by a curved transition
`and stands up from the central panel to substantially conform
`to the first foot well wall.
`
`U.S. Patent No.
`8,833,834 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,
`
`7
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep Wrangler
`JK 4 Door Unlimited (PS)
`
`As depicted below, a 2nd tray wall is substantially transversely
`disposed, is joined to the central panel and to the first tray wall by
`respective curved transitions, and stands up from the central panel
`so as to substantially conform to the second foot well wall.
`
`U.S. Patent
`No. 8,833,834
`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,
`
`8
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As depicted below, a 3rd tray wall is substantially longitudinally
`disposed, stands up from the central panel and is joined to the 2nd
`tray wall and to the central panel by respective curved
`transitions.
`
`U.S. Patent
`No. 8,833,834
`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;
`
`9
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As depicted below, each of the central panel and the 1st, 2nd
`and 3rd tray walls have an outer surface and an inner surface
`opposed to the outer surface.
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`the central panel
`and the 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,
`
`10
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`11
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`12
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`As a consequence of being thermoformed from a sheet of
`uniform thickness, the thickness of the central panel and of
`the first, second and third tray walls, as measured between the
`inner surface and the outer surface thereof, is substantially
`uniform throughout the tray.
`
`U.S. Patent No.
`8,833,834 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;
`
`13
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`The first images below show, in color, the top 1/3 of the inner
`surfaces of the 1st, 2nd and 3rd floor tray walls. The top 1/3 of
`the outer surfaces of the 1st, 2nd and 3rd floor tray walls
`correspond to the colored areas and are opposite from them, on
`the bottom/outside of the tray. Images of such outer surfaces
`follow. At least 90% of these outer surfaces are no more than
`1/8 inch from the respective foot well walls.
`
`U.S. Patent No.
`8,833,834 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.
`
`14
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`15
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 15
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 01846 for 2014 – 2018 Jeep
`Wrangler JK 4 Door Unlimited (PS)
`
`16
`
`MacNeil Exhibit 2086
`Yita v. MacNeil IP, IPR2020-01139
`Page 16
`
`