`Claim Chart of ‘834 Patent Claim 1 as Applied to WeatherTech Tool No.
`00944 for 2013 – 2018 Toyota 4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`WeatherTech molds vehicle floor trays on Tool No. 00944
`to fit into the passenger’s side (PS) vehicle foot well of the
`2013 – 2018 Toyota 4Runner / 2014 – 2017 Lexus GX460.
`Each tray molded on Tool No. 00944 is a tray which may be
`installed by a consumer into a predetermined foot well of the
`vehicle, in this case the front row passenger’s side (PS). As
`depicted below, the 2013 – 2018 Toyota 4Runner / 2014 –
`2017 Lexus GX460 and any floor tray molded on
`WeatherTech Tool No. 00944, 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 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`As depicted below, the vehicle foot well has a substantially
`longitudinally disposed 1st foot well wall, a substantially
`transversely disposed 2nd foot well wall joined to the 1st foot
`well wall, and a substantially longitudinally disposed 3rd foot
`well wall joined to the 2nd foot well wall. The 1st, 2nd and 3rd
`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 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`U.S. Patent
`No. 8,833,834
`B2 Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`3
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness.
`
`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 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`As depicted below, the central panel of the tray
`substantially conforms to the floor of the vehicle 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,
`
`5
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`As depicted below, a substantially longitudinally disposed
`1st tray wall is joined to the central panel by a curved
`transition, and stands up from the central panel to
`substantially conform to the 1st 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,
`
`6
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`As depicted below, a substantially transversely disposed 2nd
`tray wall is joined to the 1st tray wall and to the central panel
`by respective curved transitions. The 2nd tray wall stands up
`from the central panel to substantially conform to the 2nd 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,
`
`7
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`As depicted below, a substantially longitudinally disposed
`3rd tray wall is joined to the central panel and to the 2nd tray
`wall by respective curved transitions. The 3rd tray wall
`stands up from the central panel.
`
`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,
`
`8
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`Depicted below are the outer surfaces of the 1st, 2nd and 3rd
`tray walls, followed by sectional views of the tray walls
`and of the central panel demonstrating that the thicknesses
`of 1st, 2nd and 3rd tray walls, and of the central panel, are
`substantially uniform throughout the tray.
`
`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,
`
`9
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`10
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`11
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`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;
`
`12
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`13
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`The images immediately below show, 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
`bottom/outside of the tray; these outer surfaces appear in the
`photographs following and are highlighted in color. At least
`90% of these outer surfaces are within 1/8 inch of their
`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 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`15
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 15
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`16
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 16
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00944 for 2013 – 2018 Toyota
`4Runner / 2014 – 2017 Lexus GX460 (PS)
`
`17
`
`MacNeil Exhibit 2087
`Yita v. MacNeil IP, IPR2020-01139
`Page 17
`
`