In an IPR petition filed by petitioner C&D Zodiac, Inc., the petitioner sought review of patent owner, B/E Aerospace, Inc.'s U.S. Patent No. 8,590,838, directed to space-saving aircraft enclosures, including lavatories, closets, and galleys. The petition challenged the validity of claims under Section 102 and 103 based on, among other things, a publication entitled McDonnell Douglas DC-10 Customer Configuration Summary (Oct. 1978) referred to as an "Orange Book," presumably because of its orange cover.
The Board granted the petition based on multiple grounds, including the obviousness of the claims in view of a prior art patent to Betts and the Orange Book. Critical to the Board's holding was its determination that the Orange Book satisfied the printed publication requirement for prior art purposes.