Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 1 of 43 PageID #: 4973
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 12-574 (LPS)(CJB)
`(CONSOLIDATED)
`
`REDACTED PUBLIC VERSION
`FILED 5/1/2015
`
`))))))))))))
`
`
`
`ROBERT BOSCH LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`ALBEREE PRODUCTS, INC., API KOREA
`CO., LTD., SAVER AUTOMOTIVE PROD-
`UCTS, INC., and COSTCO WHOLESALE
`CORPORATION,
`
`
`Defendants.
`
`APPENDIX OF EXHIBITS TO OPENING BRIEF IN SUPPORT OF
`COSTCO’S MOTION FOR SUMMARY JUDGMENT
`AS TO THE GOODYEAR HYBRID WIPER PRODUCT
`AND REGARDING CLAIM CONSTRUCTION
`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`Mary B. Graham (#2256)
`Thomas Curry (#5877)
`1201 N. Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`mgraham@mnat.com
`tcurry@mnat.com
`Attorneys for Costco Wholesale Corporation
`
`
`
`
`
`OF COUNSEL:
`
`James W. Dabney
`Diane E. Lifton
`Walter M. Egbert, III
`Richard M. Koehl
`Stephen Kenny
`Erik Huestis
`Greta Fails
`Stefanie Lopatkin
`HUGHES HUBBARD & REED LLP
`One Battery Park Plaza
`New York, NY 10004-1482
`(212) 837-6000
`
`April 24, 2015
`
`
`
`

`
`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 2 of 43 PageID #: 4974
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`TAB
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`DESCRIPTION
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`History of Windshield Wiper Development
`
`U.S. Patent No. 743,801 to Anderson, issued November 10, 1903
`
`U.S. Patent No. 762,889 to Douglas, issued June 21, 1904
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`GB Patent No. 190321790 to Apjohn, issued August 11, 1904
`
`U.S. Patent No. 2,303,694 to Horton, issued December 1, 1942
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`U.S. Patent No. 2,596,063 to Anderson, issued May 6, 1952
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`U.S. Patent No. 2,814,820 to Elliott et al., dated December 3, 1957
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`U.S. Patent No. 3,418,679 to Barth et al., issued December 31, 1968
`
`DE Patent No. 1,028,896B to Hoyler, issued April 24, 1958
`
`U.S. Patent No. 3,192,551 to Appel, issued July 6, 1965
`
`U.S. Patent No. 3,427,637 to Quinlan et al., issued February 11, 1969
`
`U.S. Patent No. 3,717,900 to Quinlan et al., issued February 27, 1973
`
`U.S. Patent No. 3,881,214 to Palu, issued May 6, 1975
`
`U.S. Patent No. 4,063,328 to Arman, issued December 20, 1977
`
`U.S. Patent No. 5,485,650 to Swanepoel, issued January 23, 1996
`
`U.S. Patent No. 6,000,093 to Charng, issued December 14, 1999
`
`U.S. Patent No. 6,553,607 to de Block, issued April 29, 2003
`’607 File History - 12-30-02 NOA
`
`U.S. Patent No. 6,611,988 to de Block, issued September 2, 2003
`’988 File History - 02-06-02 Office Action
`’988 File History - 05-01-02 Amendment
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 3 of 43 PageID #: 4975
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`TAB
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`DESCRIPTION
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`’988 File History - 07-01-02 Amendment
`’988 File History - 08-13-02 Office Action
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`U.S. Patent No. 6,668,419 to Kotlarski, dated December 30, 2003
`’419 File History - 12-05-02 Office Action
`’419 File History - 04-04-03 Amendment
`
`U.S. Patent No.6,836,926 to de Block, issued January 4, 2005
`’926 File History - 02-10-04 Amendment
`’926 File History - 04-08-04 Amendment
`’926 File History - 09-10-04 Office Action
`
`U.S. Patent No. 6,973,698 to Kotlarski, issued December 13, 2005
`’698 File History - 01-09-02 Brief on Appeal
`’698 File History - 05-28-03 Decision on Appeal
`’698 File History - 02-24-05 Amendment
`
`U.S. Patent No. 7,228,588 to Kraemer et al., issued June 12, 2007
`’588 File History - 08-07-06 Office Action
`’588 File History - 01-08-07 Amendment
`
`U.S. Patent No. 7,484,264 to Kraemer et al., issued February 3, 2009
`’264 File History - 01-09-08 Office Action
`’264 File History - 07-09-08 Amendment
`
`U.S. Patent No. 8,099,823 to Kraemer et al., issued January 24, 2012
`
`U.S. Patent No. 8,272,096 to Wilms et al., issued September 25, 2012
`’096 File History - 03-06-12 Office Action
`’096 File History - 06-05-12 Interview Summary Record
`’096 File History - 06-06-12 Amendment
`’096 File History - 06-20-12 Notice of Allowance
`
`Transcript of Deposition of Chris Wood, April 22, 2015
`Wood Deposition Exhibit 1 – ICON Wiper Blades, Bosch Auto Parts,
`https://www.boschautoparts.com/auto/wiper-blades/icon-wiper-blades
`(last visited Apr. 22, 2015)
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 4 of 43 PageID #: 4976
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`TAB
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`DESCRIPTION
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`Wood Deposition Exhibit 2 – Corrected Declaration of Chris Wood,
`Robert Bosch LLC v. Trico Products Corp., No. 12 CV 437 (N.D.Ill.
`Sept. 9, 2013)
`Wood Deposition Exhibit 3 – Plaintiff Robert Bosch LLC’s First
`Supplemental Response to Defendant Costco Wholesale Corporation’s
`First Set of Interrogatories (No. 1), dated April 17, 2015
`Wood Deposition Exhibit 4 – Excel file titled “Blades sold by Bosch
`LLC to OE market,” dated April 9, 2015
`Wood Deposition Exhibit 5 – Untitled and undated Excel file
`
`Declaration of Daniel H. Kruger, dated April 23, 2015
`Exhibit 1 – Animations
`Exhibit 2 – Goodyear Hybrid Photographs
`
`Report of Eric H. Maslen, Ph.D., dated April 23, 2015
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 5 of 43 PageID #: 4977
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`Tutorial History of Windshield Wiper Development
` Eric H. Maslen
`April 15, 2015
` The development of the windshield wiper is linked inextricably with that of the
`windshield. Horse drawn vehicles nearly universally did not have windshields for
`the driver because of the need for close interaction between the driver and the
`horse or horses. This meant that, when horse drawn vehicles were fitted with
`windows facing forward, these were only for the passengers and were able to be
`cleaned by the driver. Consequently, horse drawn vehicles created no significant
`need for a mechanically driven windshield wiper. The first motor-drawn vehicles of
`any commercial importance were trains or streetcars and these vehicles did place a
`sheet of glass in front of the driver, forming the earliest windshields. These
`windshields were flat rectangular pieces of glass.
`
`First Patents. The first patents for windshield (or windscreen) wipers were
`intended primarily for use either on locomotives or street cars and were granted in
`1903 to Mary Anderson (US 743,801), Robert Douglass (US 762,889), and John
`Apjohn (GB190321790). As illustrated in Figure 1, the ‘801 patent swept a rigid
`squeegee-style wiper blade across a portion of a flat, rectangular windshield.
`
`Figure 1: US743,801 (Anderson) Figure 6 showing a mechanism for sweeping a rigid squeegee-style
`wiper blade across a portion of a flat rectangular windshield.
`
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`The wiper blade in ‘801 was attached to the sweeping mechanism at a single point
`midspan of the wiper blade, as illustrated in Figure 2. The wiper blade comprised a
`rigid wooden stiffener (feature “H” in Fig. 3 of ‘801, shown here in Figure 3) that
`captured and held a rubber wiper (feature “T” in Fig. 3 of ‘801, shown here in Figure
`3.)
`
`Figure 2: US743,801 (Anderson) Figure 3 showing the means of attachment of the wiper blade to the
`sweeping mechanism: a single point at the midspan of the wiper.
`
`
`
`Figure 3: US743,801 (Anderson) Figure 3 showing the cross section of the wiper and means of
`attachment to the sweeping mechanism.
`
`
`The wiper blade itself was adapted directly from a conventional squeegee as used
`then and now to clean windows.
` US762,889 (to Douglass, 1904) is directed specifically at locomotive cab windows
`and describes the patented design as “an improved device of this character which is
`simple in construction, durable, and efficient in operation.” This suggests that
`mechanical windshield wipers for locomotives predate the 1903 filing. As illustrated
`in Fig.1 of ‘889 (Figure 4 here), the mechanism provides an adjustable motion
`sweeping a squeegee-style wiper blade as in ‘801 across a portion of a flat
`rectangular windshield.
`
`
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`2
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`A-2
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`Figure 4: US762,889 (Douglass, 1904) Fig. 1 shows the general layout of the wiper system.
`
`
`
`Squeegee Principles. The physical principles underlying the design of this
`“conventional squeegee” style blade are relatively simple. The goal of the design is
`to put a blade in sufficiently close contact with the glass surface along its length as to
`penetrate any water film. This requires a combination of contact force to break the
`water film and overcome the effects of surface tension which tend to draw adjacent
`films together and sufficient compliance in the contacting blade as to adapt closely
`enough to the surface that any gaps between blade and surface are smaller than
`some scale dictated by water surface tension but on the order of a few molecules.
`The blade should also not scratch the glass when swept across its surface.
` To this end, a flexible rubber blade is combined with some form of stiffening
`element as illustrated in Figure 3. The stiffening element distributes force from the
`point of application (where the sweeping mechanism attaches to the blade) across
`the length of the rubber blade. Any beam supported at its center and subject to
`uniform reaction loading across its length will deflect away from the load: the
`deflection will be zero at the center and increase toward each end. The effect of this
`deflection is to make the contact force also vary along the length of the beam.
`Squeegees keep this deflection and its attendant contact force variation to an
`acceptable level by making the stiffener very stiff in response to loads applied in the
`direction perpendicular to the windshield.
`
`Early Windshields. As early as 1904, many roadway motor vehicles provided
`optional windshields. These were typically one or two flat rectangular pieces of
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`glass oriented essentially vertically in front of the driver and passenger. In most
`cases, the windshields were designed to be folded. Such an arrangement is
`illustrated in Figure 5, which is an advertisement for a 1913 Reo automobile.
`
`
`By the late 1910’s, many automobile manufacturers had begun to offer windshield
`wipers as accessories and, as illustrated in Figure 6, these used a wiper blade and
`mechanism not substantially different from that introduced by the ‘801 patent to
`Anderson from 1903.
`
`Figure 5: Advertisement for a 1913 Reo automobile.
`
`Figure 6: 1926 Ford advertisement for an automatic windshield wiper accessory.
`
`
`Windshields remained largely unchanged until about 1930 when the first split
`windshields (reflecting contemporaneous innovations in aircraft windshields) were
`introduced: initially on exotic automobiles such as the 1930 Cord and eventually
`reaching mass produced vehicles such as Fords by 1936. This innovation provided a
`more aerodynamic form but at the cost of a vertical divider in the middle of the
`windshield. Significantly, the glass in these windshields remained flat and that
`meant that windshield wipers could still be essentially squeegees, as in the ‘801
`patent of 1903.
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`Curved Windshields. Curved windshield glass began to appear on new vehicles in
`the 1940’s. This development led to the introduction of new windshield wiper
`designs that could conform to the shape of curved windshield glass well enough to
`provide satisfactory wiping. This transition to curved glass, and the implications for
`the wiper blade, is discussed as early as the 1940 filing of US2,303,694 (granted to
`Horton in 1942) who says (at column 1, line 1), “This invention relates to a
`windshield wiper which is especially adapted for the cleaning of curved window
`surfaces.” As illustrated in Figure 7, Horton’s solution was a mild adaptation of the
`current art: he simply cut the stiffener of the conventional squeegee-style blade into
`two pieces, leaving the rubber blade continuous. Each half of the stiffener was
`pivoted from the ends of a “bridge member” (feature “6” of ‘694, Figure 7 here) that
`was, in turn, attached to the arm of the sweep mechanism.
`
`Figure 7: US2,303,694 (Horton, 1942) Figures illustrating an early approach to wiping curved
`windshields.
`
`
`Bracket-Style Wiper Supports. This introduction of a bridge member in ‘694 to
`support two separate blade stiffeners presaged the emergence of the bracket-style
`wiper support designs. Perhaps the first of these is documented in US2,596,063 to
`Anderson in 1952, filed in 1945 and illustrated by Figure 8. At column 1, line 1 of
`‘063, Anderson says, “This invention relates generally to windshield or window
`cleaners or wiper devices and more particularly is directed to a device adapted to
`clean or wipe a curved surface as well as a substantially planar surface.”
`
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`Figure 8: US2,596,063 (Anderson 1952) Fig. 2 shows the general layout of an early bracket-style wiper
`blade.
`
`
`The design of ‘063 has essentially all of the elements of a modern bracket-style
`wiper blade including a bridge element (feature “35” in ‘063), a pair of secondary
`supports referred to as “links” (features “33” and “34” in ‘063) pivoted from the
`ends of the bridge element and attached to the blade stiffeners (feature “15” in ‘063)
`of the blade using claws (features “30” in ‘063). This attachment is illustrated in Fig.
`7 of ‘063 reproduced here in Figure 9.
`
`Figure 9: US2,596,063 (Anderson 1952) Fig. 7 illustrating the manner in which the secondary supports
`33 attach to the blade stiffeners 15 using claws 30.
`
`
`An important step in the progression from ‘694 to ‘063 relates to the blade stiffener.
`Prior to ‘694, the blade stiffener was designed to be very stiff in response to forces
`applied by the wiper arm in the direction perpendicular to the windshield. The
`innovation of ‘694 was to cut this stiffener into two pieces to provide a bit of
`flexibility but much of the responsibility for conforming to a curved windshield was
`still delegated to the rubber blade itself. In ‘063, the stiffener was designed to be stiff
`in the sweep direction but very flexible in the direction perpendicular to the
`windshield: the stiffener was now very thin in a direction perpendicular to the
`windshield but wide in a direction parallel to the windshield. This innovation
`enabled the wiper blade to more readily conform to the curved surface of the
`windshield but necessitated the more complex bracket-style support structure
`(bridge plus pivoted secondary supports) in order to ensure a relatively uniform
`distribution of contact load along the length of the blade.
`
`Physical Principles of the Bracket-Style Wiper Supports. The core objective of
`the bracket-style wiper supports is to distribute the forces applied by the sweeping
`mechanism at a single point on the blade structure to a nearly uniform line loading
`of the blade edge. There are three key elements to this. First is the system of load
`distribution elements (brackets) and pivots, second is the stiffening element
`attached to the wiper blade, and third is the wiper blade itself.
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`To understand the load distribution elements, consider the very simple balance
`mechanism illustrated in Figure 10, sometimes called a “Whiffletree”. If a load is
`applied at the center of the balance bar, then the reaction forces at the two ends are
`the same regardless of the angle of the bar. This provides a simple means to spread
`one applied load to two reaction loads without knowing the shape of the contacted
`surface.
`
`
`The idea is readily extended to more points of contact by adding additional levels.
`Figure 11 illustrates a two-level mechanism distributing a single load to four points
`of contact.
`
`Figure 10: Simple load balancing mechanism: for a given center load, the end reactions are the same
`regardless of the angle of the balance bar.
`
`Figure 11: Two-level load-balancing mechanism. The reactions at the four end points are the same even
`when the contacted surface is very uneven. Note that when the three pivots are not on the same line, the
`load balance between the two ends depends on the bar angle. For small bar angles, this effect may be
`neglected.
`
`
`Other variations in behavior of the mechanism can be realized by moving the pivot
`points away from the centers of the beams: the end nearest the pivot will exhibit a
`higher contact reaction force than at the opposing end.
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`The combination of the wiper and the stiffener attached to the wiper serves to
`further spread point loads applied to the stiffening strip to more uniform contact
`loading at the blade edge. When the stiffener is very stiff, then this redistribution of
`point loads to line contact at the edge of the blade is very uniform as long as the
`unloaded shape of the stiffener and blade match that of the windshield well. Making
`the stiffener more flexible allows it to better conform to windshield curvature but
`also reduces the uniformity of the contact load distribution. If the stiffener is too
`flexible, then the blade contact load will be highest directly under the applied point
`loads. If the stiffener is too stiff, then the blade contact load will be highest where
`the stiffener would need to deflect the most in order to conform to the windshield
`contour.
`Aerodynamic lift. One problem recognized relatively early in the development of
`windshield wipers is that air flow over the hood and windshield of the car is
`disrupted by the wiper blades and, at high speeds, this can sometimes create
`aerodynamic lift that reduces the contact loading between the blade and the
`windshield and, in the most severe circumstances, can lead to the blade actually
`lifting out of contact with the windshield. This problem was recognized at least as
`early as the 1953 filing date of US2,814,820 issued to Elliot in 1957 and focused on
`application to aircraft. Subsequently, many patents have been issued for windshield
`wiper assemblies with cross sections meant to reduce the tendency to lift at high
`speeds or for airfoils or spoilers that attach to wiper blades with the same objective.
`An illustrative example is provided by US3,418,679 to Barth in 1968. The general
`configuration of the bracket-style wiper support is shown in Figure 12 and Barth’s
`thoughts on the associated aerodynamic behavior are illustrated in Figure 13. Given
`the speed limits enforced in the United States, it is unlikely that aerodynamic lift is
`ever an issue at legal speeds so the profusion of aerodynamic wiper blade
`assemblies likely represents more of an aesthetic preference than an actual need to
`prevent lift.
`
`
`
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`
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`Figure 12: Barth Figs. 1 and 2, US 3,418,679
`
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`Figure 13: Barth Figs. 5-7, US3,418,679.
`
`
`
`First Beam-Style Wiper Supports. An alternative to the bracket-style wiper
`support, also intended to manage wiping of curved windshields, was provided by
`DE1028896B, filed in 1954 and granted to Hoyler in 1958. This design, illustrated in
`Figure 14, dispenses with the mechanical complexity of the bracket-style wiper
`support by introducing a flexible, molded “profile bar” that is contiguous with the
`wiper blade and has slots into which pre-curved flexible springs are inserted. The
`springs are retained in the slots of the profile bar by clips “6” and “9” of the patent.
`The goal is to recapture the simplicity of the original squeegee-style wipers – in
`particular to eliminate the various flexure joints – while capturing the form-
`following features of bracket-style wiper supports that enable them to conform to
`curved windshields. The form of the profile bar in conjunction with the stiffness of
`the springs acts to distribute the force applied by the sweep arm across the length of
`the wiper blade more or less uniformly even when wiping a curved windshield. As
`discussed in column 3 of ‘896B at lines 6 through 10, “Such a bar can be cut in the
`stretched form in a conventional manner at the wiper edge, then the springs 5 are
`inserted into the slots and clamped. When used on a planar windshield, stretched
`springs are inserted, in case of curved glass springs preliminarily bent according to
`the curvature of the windshield.”
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`Figure 14: DE1028896B (Hoyler, 1958) Fig. 1 illustrates the use of a non-articulated profile beam to
`distribute the forces of the sweep mechanism uniformly along the length of the wiper blade.
`
`
`Subsequent Beam-Style Wiper Supports. Between 1958 and the present,
`numerous patents relating to beam-style wiper supports have been granted.
`Presented here are just a few examples.
` Appel (US 3,192,551; 1965) describes a single flat spring support connected to the
`wiper blade and shifted the connection of the wiper arm from the profile beam of
`Hoyler to this flat spring support, as illustrated in Figure 15. Appel considered a
`spring support of uniform thickness and width as well as a spring support whose
`width and thickness are greatest near the point of attachment of the wiper arm and
`taper toward the ends of the blade.
`
`
`
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`Figure 15: Appel Fig. 5 US 3,192,551.
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`Quinlan (US 3,427,637; 1969) describes a composite stiffener consisting of multiple
`flat springs captured inside a casing that holds the wiper against the springs and is
`attached at its center to the wiper arm as indicated in Figure 16. A subsequent
`Quinlan patent (US 3,717,900; 1973) eliminates the casing and inserts a stack of one
`or more flat springs into a sleeve molded as part of the wiper itself. Both Quinlan
`patents use pre-curvature of the flat springs to provide, as nearly as possible, a
`uniform blade loading along the length of the blade when pressed against a
`windshield of specific shape.
`
`Figure 16: Quinlan Figs. 13-14 US 3,427,637.
`
`
`
` Dal Palu (US 3,881,214; 1975) describes a composite support structure that is
`uniform in cross section along the full length of the blade and consists of a
`thermoplastic body with a “T” slot that captures both a flat spring and the “T”-
`shaped top edge of the rubber wiper strip, as illustrated in Figure 17. The
`thermoplastic body may be molded with a pre-curvature and the flat spring may
`also have a pre-curved form prior to insertion in the slot of the thermoplastic body.
`
`
` Arman (US 4,063,328; 1977) discloses a flat spring support that connects directly to
`the wiper arm and has a slot running down the center of the spring for its entire
`length with formed bridges spanning the slot. A “T”-shaped top edge of the molded
`rubber wiper strip engages with this slot to retain the wiper strip in the support.
`Again, the flat spring support is pre-curved to ensure uniform blade loading when
`pressed against a flat or curved windshield. The geometry of this disclosure is
`illustrated in Figure 18.
`
`Figure 17: Dal Palu Figs. 1 and 3 US 3,881,214.
`
`
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 16 of 43 PageID #: 4988
`
`Figure 18: Arman Fig. 2 US 4,063,328.
`
`
`
`Swanepoel (US 5,485,650; 1996) describes a flat spring support whose width and
`thickness of the spring support tapers in a specific manner from center to each end
`and is pre-curved in a specific manner as to achieve both uniform loading along the
`length of the blade and maintain an essentially constant wiping angle between the
`blade and the windshield along the length of the blade. Figure 19 illustrates this
`design.
`
`
`
`
`
`Figure 19: Swanepoel Fig. 1 US 5,485650.
`Mechanical Principles of Beam-Style Wiper Supports. As discussed previously
`for squeegee style windshield wipers, any beam subject to uniform loading will
`deflect away from the load. If the shape of the line of contact between the wiper and
`the windshield is known very precisely and doesn’t change with the sweep motion,
`then a very stiff beam could be shaped to match this line of contact and the
`distribution of contact load along the length of the wiper would be very uniform.
`The squeegee could adopt such a strategy because the associated windshields were
`flat and the line of contact between wiper and windshield was straight, regardless of
`wiper arm position.
` With a curved windshield, the shape of the line of contact changes as the wiper
`blade is swept through its full motion and the wiper blade must somehow
`accommodate this changing shape. One solution to accommodating this changing
`shape is to adopt a very flexible wiper/stiffener combination and then load the
`stiffener toward the windshield at multiple points along its length: this is the
`approach adopted by bracket-style wiper supports but it comes at the cost of a
`somewhat complicated load distribution mechanism.
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 17 of 43 PageID #: 4989
`
`An alternative is to simply eliminate the multiple points of loading and only press
`the wiper blade toward the windshield at the center. This is the approach adopted
`by beam-style wiper supports. For any given combination of contact line shape, flat
`spring support stiffness, and wiper arm force, there is an ideal pre-curved form for
`the flat spring that will produce perfectly uniform contact loading along the entire
`length of the wiper - this is what is intended by Hoyler’s provision that “…in case of
`curved glass springs preliminarily bent according to the curvature of the
`windshield” (DE1028896B at column 3, lines 9 through 10).
` This pre-curvature shape can readily be computed given these parameters and
`manufacturing processes exist for imparting such a specific curvature to a flat
`spring support, so such an approach is feasible. The approach to computing the pre-
`curvature is straightforward: given the known mechanical properties of the flat
`spring stiffener and assuming a uniform contact reaction along the wiper’s length
`(arm force divided by wiper length), compute the resulting deflection away from the
`windshield. This deflection is then added to the shape of the contact line to produce
`the total pre-curvature shape.
` The drawbacks to this approach are that the shape of the line of contact a) is
`different for each vehicle model and b) depends on the wiper arm angle as the blade
`is swept across the windshield. For many windshield forms, the latter effect is
`relatively modest except at the extreme positions of the wiper – particularly the
`“park” position of the passenger side wiper. In this case, the variation in wiper
`contact force distribution along the length of the wiper blade can be made
`acceptably small over most of the range of sweep by the right choice of pre-
`curvature. This leaves the challenge of differing windshield form between vehicle
`models and means that proper wiping performance can only be assured for beam-
`style wiper supports by tailoring them to the specific vehicle model they are
`intended to fit.
`
`Hybrid Wiper Supports. Hybrid wiper blade supports provide the appearance of
`beam-style wipers and the ability to conform to a wider range of windshield forms
`offered by bracket-style wipers. While the external appearance of hybrid wiper
`supports approximates that of beam-style wiper supports, they are composed of
`several articulated support components that, collectively, constitute a conventional
`bracket structure. An example is disclosed in US6,000,093 to Charng in 1999,
`depicted in Figure 20.
` This functionality is disguised by covering the components with shrouds that
`provide the beam-style appearance. The shrouds also reduce accumulation of snow
`and ice inside the bracket structure and thereby make these blades somewhat less
`vulnerable to the depredations of cold weather than are conventional bracket-style
`wiper supports. As such, hybrid wiper supports arguably provide the most
`advanced wiper performance currently available. The Goodyear Hybrid windshield
`wiper is an example of this type of hybrid wiper blade assembly.
`
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 18 of 43 PageID #: 4990
`
`Figure 20: From Charng Fig. 1, US6,000,093. Dotted lines added to illustrate obscured features.
`
`
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`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 19 of 43 PageID #: 4991
`Case 1:12—cv—OO574—LPS Document 166 Filed 05/01/15 Page 19 of 43 Page|D #: 4991
`
`TAB 1
`
`TAB1
`
`

`
`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 20 of 43 PageID #: 4992
`
`-No. 743,801.
`
`PATENTED NOV. 10, 1903.
`
`M. ANDERSON.
`WINDOW CLEANING DEV~CE.
`APPf.{CATIOlf FILED JUNE 18, 1903.
`
`NO l!ODEL .
`
`Fig-1 .
`
`G_W~
`cllfilbm. ~ .Fig.5.
`~&~
`
`A-15
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`

`
`Case 1:12-cv-00574-LPS Document 166 Filed 05/01/15 Page 21 of 43 PageID #: 4993
`
`No. 743,801.
`
`Patented November 10, 1903.
`
`UNITED STATES PATENT O FFICE.
`
`MARY ANDERSON, OF BJRMINGHAM, ALABAMA.
`
`WINOOW·CLEANING DEVICE.
`
`SPECIFICATION forming part of Letters Patent No. 743,801, dated November 10, 1903.
`Applloa.t!0111iled Jone 181 1903. Serial No.l62,125. <No mode),)
`
`J.'o aU whom it 7l?tay conce1'n:
`Be it known that I, MARY ANDERSON, a citi(cid:173)
`zen of the United States, residing at Birming(cid:173)
`ham, in the county of Jefferson and State of
`s Alabama, have invented a new and nsefol
`Improvement in Window-Cleaning Devices,
`of which the following is a specification.
`My invention relates to an improvement in
`window-cleaning devices in which a radially-
`to S\Vinging arm is actnated by a handle from
`the inside of a car-vestibule; and the objects
`of my invention are as follows: first, to pro(cid:173)
`vide a device operating on the outside of the
`glass to remove snow, rain, or sleet from the
`IS center vestibule-window of modern electric(cid:173)
`motor cars and operable from the inside of
`the vestibule, at the same time providing
`means \vbereby the window-cleaning devices
`are rendere~ easily removable when not re-
`:zo qait·ed, thns leaving nothing to mar the usual
`appearance of the car during fair weather;
`second, to provide means for maintaining a
`uniform pressure upon the glass throughout
`the entire area swept by my improved win-
`25 dow-cleaning· device; third, to so construct
`my improved win~ow-cleaning device as to
`make it up of two or more independent parts,
`so that an obstruction to one \Vill not affect
`the other or others.
`"With these several objects in view my in(cid:173)
`vention consists in certain novel features of
`construction and combinations of parts, which
`will be hereinafter described, and pointed out
`in the claims.
`In the accompanyingdra\vings, Figure 1 is
`a vertical section through the center vesti(cid:173)
`bule-post on line 11 of Fig. 2. Fig. 2 is a
`view in front elevation, showing the appara(cid:173)
`tus in position. Fig. 3 is a.section on line 3 3
`40 of Fig. 5. Fig. 4 is a section on line 4 4 of
`Fig. 5. Fig. 5 is a fragmentary detail,enlarged,
`of the arm; and Fig. 6 is a detail showing the
`manner in which the spindle d is placed in
`the frame and the manner in which the arm
`45 is secured to the spindle.
`The arm is composed, mainly, of the socket
`Band the tubing D, secured therein. The
`tubing D or its equivalent, which might be
`a solid bar of metal, if desil'ed, is adapted to
`so carry the cleaners, of which there may be one
`or mor