`Claim Chart of ‘834 Patent Claim 1 as Applied to WeatherTech Tool No.
`00840 for 2013 – 2017 Honda Accord (PS)
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`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:
`
`WeatherTech molds vehicle floor trays on Tool No. 00840
`to fit into the passenger’s side (PS) vehicle foot well of the
`2013 – 2017 Honda Accord. Each of these trays is a floor
`tray which may be installed by a consumer into a
`predetermined vehicle foot well, in this case the passenger’s
`side (PS) foot well. As depicted below, the 2013 – 2017
`Honda Accord, and any tray made on WeatherTech Tool
`No. 00840 (specially made for this vehicle), constitute a
`“system” as claimed.
`
`1
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`As depicted below, the vehicle foot well has a floor. A
`substantially longitudinally disposed 1st foot well wall stands
`up from the floor. A substantially transversely disposed 2nd
`foot well wall stands up from the floor and is joined ot the
`first foot well wall.
`
`1st Foot well wall
`
`2nd Foot well wall
`
`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,
`
`Floor
`
`2
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`The foot well further has a substantially longitudinally
`disposed 3rd wall that stands up from the floor and is joined
`to the 2nd foot well wall.
`
`U.S. Patent
`No. 8,833,834
`B2 Claim 1
`a substantially
`longitudinally
`disposed third
`foot well wall
`upstanding
`from the floor
`and joined to
`the second
`foot well wall;
`and
`
`3
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness. The
`second image below is of a stack of sheet blanks, all of
`uniform thickness, that WeatherTech uses in its tray
`molding process.
`
`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 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`U.S. Patent
`No.
`8,833,834
`B2 Claim 1
`
`5
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`As depicted below, the floor 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,
`
`6
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`As depicted below, a substantially longitudinally disposed
`1st tray wall is joined to the central panel by a curved
`transition, and stand up from the central panel so as 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 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`As depicted below, a substantially transversely disposed 2nd
`tray wall 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.
`
`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 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (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,
`
`9
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`In the images below, the outer surfaces of each of the 1st, 2nd
`and 3rd tray walls are shown in color.
`
`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 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`U.S. Patent
`No. 8,833,834
`B2 Claim 1
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`11
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`As shown, the thicknesses of the central panel and of the
`1st, 2nd and 3rd tray walls are 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;
`
`12
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (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 these
`surfaces is adjacent to the top margins of the 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. At least 90% of these outer
`surfaces are no more than 1/8 inch from respective ones of
`the 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.
`
`13
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`U.S. Patent No.
`8,336,944 B2
`Claim 13
`
`WeatherTech Tool No. 00840 for 2013 – 2017 Honda
`Accord (PS)
`
`14
`
`MacNeil Exhibit 2089
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
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