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`Petitioner RTIC Cooler LLC’s Petition for Inter Partes Review of
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`U.S. Patent No. 8,910,819
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`Mail Stop Inter Parties Review
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`Attn: Patent Trial and Appeal Board
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`Commissioner for Patents
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`PO Box 1450
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`Alexandria, VA 22313-1450
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`
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`Commissioner:
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`I, David L. Trumper, declare as follows:
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`1
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`RTIC 1004
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`YETI Coolers, LLC, Ex. 2001
`RTIC Coolers, LLC and Velky Brands, LLC v. YETI Coolers, LLC
`IPR2016-01207
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`1
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`
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`the ’819 Patent. Brady discloses an “Insulated Receptacle” where the frame of the
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`insulated portable container “may preferably be moulded from a suitable high
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`impact plastic,” 2:8-10 (emphasis added), and the frame contains “a thoroughly
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`insulated compartment utilizing modern insulating materials.” 1:50-51. See also
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`Fig. 3 (right). Companies like The Coleman Company, Inc. have been making and
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`selling plastic molded coolers since the 1960s.5 Thus, a POSITA working and
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`designing molded-plastics products would have been well aware of the methods of
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`molding plastic containers, including insulated coolers, long before the earliest
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`effective filing date of the ’819 patent.
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`38. Roto-molding is also known to have certain drawbacks. For example,
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`the roto-molding process is known to be not very precise due to the large size of
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`the parts typically molded using this process, and the fact that the large molds used
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`in the roto-molding process are commonly made from castings of hand-made solid
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`patterns, which is not a very precise process. Imprecisions in a roto-molded
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`product are common due to the many variables that impact the success of the
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`process: complexity of the shape of the mold, part shrinkage as the material cools,
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`the temperature of the oven is too high or low, the time in the oven is too long or
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`short, the speed ratio for turning the mold is not correct, or the quality of the
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`5 See, e.g., “On the Bubble (1954-1999),” http://www.coleman.com/NewCoolers/
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`21
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`2
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`materials used.6 Because roto-molded plastics are not precisely molded for the
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`above reasons, roto-molded products can benefit from using a forgiving, flexible
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`latching mechanism that can adapt to various imperfections, size variations,
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`parting-line ridges, or other types of irregularities common to roto-molded
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`products.
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`39. A POSITA designing molded-plastic products such as insulated
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`coolers would also have been aware that there are a variety of mechanisms for
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`fastening or securing two opposing portions of a container together. For example,
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`metal buckle-type spring latches, hard-plastic toggle-type snap latches, compliant
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`elastomeric buckle latches, elastomeric strap latches, molded elastic flaps that snap
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`over molded ridges or detents, etc. These various fastening mechanisms each have
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`different benefits and thus have different common applications, depending on their
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`advantages and disadvantages.
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`40. As acknowledged by the ’819 Patent, the flexible draw latch, often
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`made of rubber or similar flexible, extensible material, was one such well-known
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`6 RTIC1021, R.J. Crawford & J.L. Throne, Rotational Molding Technology, 9-13
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`(Williams Andrew Pub. 2002), avail. at https://books.google.com/books?id
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`=N_2B0kW-_JQC&lpg=PP1&pg=PR4#v=onepage&q&f=false.
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`22
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`3
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`129.
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`I reserve the right to supplement my opinions in the future to respond,
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`to the extent permissible, to any argument the Patent Owner may raise, taking into
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`account new information as it becomes available to me.
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`130.
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`I declare that all statements made in this declaration are of my own
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`knowledge and are true and that all statements made on information and belief are
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`believed to be true; that these statements were made with the knowledge that
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`willfiil false statements and the like so made are punishable by fine or
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`imprisonment, or both under Section 1001 of Title 18 of the United States Code.
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`Signed: J7me ‘I, «XW6
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`David L. Trumper
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`72
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`4
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