`Claim Chart of ‘834 Patent as Applied to WeatherTech Tool No. 00804 for
`2015 – 2018 Ford Escape (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 Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`WeatherTech molds vehicle floor trays on Tool No. 00804 to
`fit into the passenger’s side (PS) vehicle foot well of the 2015
`– 2018 Ford Escape. Each floor tray molded on Tool No.
`00804 may be installed by a consumer into a predetermined
`vehicle foot well for which the tray is intended, in this case
`the passenger’s side (PS) foot well. As depicted below, the
`2015 – 2018 Ford Escape, and any tray molded on Tool No.
`00804 and specially made for this vehicle, constitute a
`“system” as claimed.
`
`1
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`As depicted below, the vehicle foot well has a floor and 1st,
`2nd and 3rd foot well walls standing up from the floor. The 1st
`foot well wall is substantially longitudinally disposed. The 2nd
`foot well wall is substantially transversely disposed and is
`joined to the 1st foot well wall. The 3rd foot well wall is
`substantially longitudinally disposed and is joined to the 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, a
`substantially
`longitudinally
`disposed third
`foot well wall
`upstanding from
`the floor and
`joined to the
`second foot well
`wall; and
`
`2
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`3
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford Escape (PS)
`
`WeatherTech’s vehicle floor tray is molded from a sheet of
`polymeric material of substantially uniform thickness. In the
`second image below, a stack of polymeric sheet blanks prior
`to their being molded into floor trays is shown.
`
`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 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`5
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (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,
`
`6
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`As depicted below, a substantially longitudinally disposed 1st
`tray wall is joined to the central panel by a curved transition.
`The 1st tray wall 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,
`
`7
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (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 in order 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 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (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 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`The first 3 images below show the outer surfaces of the 1st,
`2nd and 3rd tray walls in color. This is followed by some
`longitudinal and sectional views of this floor tray. As
`shown, a thickness, as measured between the inner surface
`and the outer surface, of the central panel and the 1st, 2nd and
`3rd tray walls, is 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,
`
`10
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (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;
`
`Substantially uniform thickness
`
`11
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`Substantially uniform thickness
`
`Substantially uniform thickness
`
`12
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`The images below show, in color, the top 1/3 of the inner
`surfaces of the 1st, 2ndnd 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 walls
`of the foot well.
`
`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 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`U.S. Patent No.
`8,833,834 B2
`Claim 1
`
`WeatherTech Tool No. 00804 for 2015 – 2018 Ford
`Escape (PS)
`
`14
`
`MacNeil Exhibit 2132
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
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