Pride Mobility Products Corp. v. Permobil, Inc., 818 F.3d 1307

Pride Mobility owns U.S. Pat. Nos. 8,408,598 and 8,408,343 claiming power-wheelchairs whose front casters are biased upward by motor torque to traverse obstacles.
Permobil petitioned for inter partes review (IPR) of both patents, asserting obviousness mainly over Goertzen (primary reference) in combination with Hosino, Mulhern, and Schaffner.
Goertzen discloses a curb-climbing wheelchair with a pivot positioned above a line between the drive-wheel and front-caster axes; Hosino and Mulhern disclose lower pivot locations below that line. Schaffner discloses a motor/drive housing.
The PTAB instituted IPRs, and ultimately cancelled all claims of both patents for obviousness; it construed claim 7 of the ’343 patent to read the drive-wheel axis as perpendicular to a planar plate in a non-ordinary-geometric way (allowing a one-dimensional motor axis analogy).
Pride Mobility appealed: it challenged the Board’s construction of claim 7 and argued that a skilled artisan would not have been motivated to lower Goertzen’s pivot because doing so would reduce stability.
The Federal Circuit reversed the Board’s construction and cancellation of claim 7 (finding ordinary geometric perpendicularity controls) but affirmed the Board’s obviousness cancellations as to the other claims based on a motivation to combine Goertzen with Hosino.

Issue	Pride (Plaintiff) Argument	Permobil (Defendant) Argument	Held
Proper construction of claim 7’s phrase "mounting plate is substantially planar and is oriented perpendicular to the drive wheel axis"	Claim 7 requires the drive-wheel axis be perpendicular to the planar surface of the mounting plate in ordinary geometric terms	The Board/Permobil read the claim broadly to include perpendicularity to a one-dimensional feature (analogous to Schaffner’s motor axis)	Reversed: claim 7 requires ordinary geometric perpendicularity between the drive-wheel axis and the plate’s substantially planar surface
Whether Goertzen combined with Hosino (lower pivot) is motivated and renders claims obvious (other claims)	Lowering Goertzen’s pivot would introduce instability that a skilled artisan would avoid or could not compensate for without degrading performance	A skilled artisan would be motivated to lower the pivot to help caster climb and would know ways to compensate for any stability loss	Affirmed: substantial evidence supports motivation to combine and the Board’s obviousness findings for all claims except claim 7

In re Sullivan, 362 F.3d 1324 (Fed. Cir.) (APA standard for reviewing PTO decisions)
Dickinson v. Zurko, 527 U.S. 150 (U.S.) (standard of review for PTO factfinding under APA)
Power Integrations, Inc. v. Lee, 797 F.3d 1318 (Fed. Cir.) (IPR review principles)
Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064 (Fed. Cir.) (obviousness and APA review framework in IPRs)
Teva Pharms. USA, Inc. v. Sandoz, Inc., 135 S. Ct. 831 (U.S.) (deference and review scope for factual findings in claim construction)
Ethicon Endo-Surgery, Inc. v. Covidien, Inc., 796 F.3d 1312 (Fed. Cir.) (claim construction review principles)