Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 1 of 15 PageID #: 5765
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 12-574 (LPS)(CJB)
`(CONSOLIDATED)
`
`
`
`))))))))))))
`
`
`RESPONSIVE DECLARATION OF DR. STEVEN DUBOWSKY
`
`
`I, Steven Dubowsky, declare as follows:
`
`
`1.
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`As set forth in my declaration dated April 22, 2015, I am Professor Emeritus in
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`the Department of Mechanical Engineering and in the Department of Aeronautics and
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`Astronautics at the Massachusetts Institute of Technology. My CV is attached to this declaration
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`as Exhibit 1.
`
`2.
`
`I submit this declaration in connection with Robert Bosch LLC (“Bosch”)’s
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`responsive claim-construction brief and its opposition to Costco Wholesale Corporation
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`(“Costco”)’s motion for summary judgment as to the Goodyear Hybrid wiper product. I have
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`personal knowledge of the matters stated herein and would be competent to testify to them if
`
`required.
`
`3.
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`In providing my opinions, I have considered the patents-in-suit discussed below
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`as they would be understood by one of ordinary skill in the art. To put myself in the position of
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`one of ordinary skill in the art during the relevant time period, I relied on my education and
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`industrial experience as a mechanical engineer, including my experience in the automotive
`
`ROBERT BOSCH LLC,
`
`
`Plaintiff,
`
`
`ALBEREE PRODUCTS, INC., API KOREA
`CO., LTD., SAVER AUTOMOTIVE
`PRODUCTS, INC., and COSTCO
`WHOLESALE CORPORATION,
`
`
`Defendants.
`
`v.
`
`
`
`
`
`

`
`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 2 of 15 PageID #: 5766
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`industry and with the design of mechanical systems and mechanical mechanisms, particularly
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`those containing linkages and joints, and experience in fluid mechanics and aerodynamics.
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`Further, I have been working as an expert in this field since 2009, when I was first retained for a
`
`case concerning the infringement of Bosch’s beam-blade patents by Pylon. I was accepted as an
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`expert in that case and testified at the jury trial. I also reviewed the materials submitted by
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`Costco in support of its motion for summary judgment as to the Goodyear Hybrid wiper product
`
`and regarding claim construction including the report of Eric H. Maslen (“Maslen Rep.”), the
`
`declaration of Daniel H. Kruger, and the video titled “Tutorial History of Windshield Wiper
`
`Development” and the accompanying transcript (“Costco Tutorial.”)
`
`4.
`
`In the Costco Tutorial, Dr. Maslen states that while “the external appearance of
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`hybrid wiper supports approximates that of beam-style wiper supports, they are composed of
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`several articulated support components that, collectively, constitute a conventional bracket
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`structure,” and offers U.S. Patent No. 6,000,093 (“the ’093 patent”) to Charng as an example of
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`such hybrid wiper blade. (Costco Tutorial at 13.) I disagree. The word “hybrid” does not
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`appear in the ’093 patent. See Exhibit 2. The ’093 patent discloses a conventional “whiffle-tree”
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`(shown in blue) wiper blade with a spoiler (shown in green); the blade does not include a pre-
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`curved, spring-elastic support element. (Ex. 2, ’093 patent at, e.g., 1:9-12, 1:33-49, Figs. 1, 3, 4.)
`
`For at least these reasons, it is my opinion that the Goodyear Hybrid blade is not an example of
`
`the type of wiper blade assembly disclosed in Charng.
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`
`
`2
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 3 of 15 PageID #: 5767
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`1.
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`CLAIM CONSTRUCTION
`A.
`
`Constructions for U.S. Patent No. 6,553,607
`
`5.
`
`Dr. Maslen opines that the claimed “securing means” and “means for securing”
`
`have different meaning, and that the “claimed ‘means for securing the wiper blade on the joint
`
`pin’ … include a structure (30) which is identical to the ’988 patent claimed ‘coupling part (20)’
`
`and is ‘capable of swinging about the joint axis (55).’” (Maslen Rep. at 10.) I disagree.
`
`6.
`
`It is my opinion that the terms “means for securing” and “securing means” are
`
`used interchangeably in the ’607 patent. Further, it is my understanding that in determining the
`
`construction of a “means-plus-function” claim term, the claimed function is first identified, and
`
`then the corresponding structure for that function as disclosed in the specification is identified.
`
`7.
`
`It is my opinion that in claim 1, the function of the “means for securing” and
`
`“securing means” is to secure the wiper blade on the joint pin, and the corresponding structure as
`
`disclosed in the specification is an L-shaped shoulder. (’607 patent at 4:58–5:15, 6:45–56, 7:15–
`
`21, Figs. 3 and 5.)
`
`B.
`
`8.
`
`Constructions for U.S. Patent No. 6,611,988
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`Dr. Maslen opines that the term “hinge half” of the ’988 patent means “a bearing
`
`recess (36) into which the pin of the wiper arm is inserted to complete the hinge.” (Maslen Rep.
`
`at 10). The claim is not so limiting.
`
`9.
`
`In my opinion, “hinge half” is defined by the language of claim 11 as the portion
`
`of the coupling part formed by the bearing recess. (’988 patent at 7:22-24). This construction is
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`further supported by the specification, which describes the hinge as the connection between the
`
`wiper arm and wiper blade (see ’988 patent at 1:20–25; 1:41–46; 4:13–15 (“The connection
`
`device is therefore simultaneously embodied as a hinge connection between the wiper blade 10
`
`3
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 4 of 15 PageID #: 5768
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`and the wiper arm 30”)). The hinge half includes a hinge axis oriented transversely to the length
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`of the wiper blade. (’988 patent at 7:20-22).
`
`10.
`
`It is therefore my opinion that this limitation should be construed as the “portion
`
`of the coupling part formed by the bearing recess,” as proposed by Bosch.
`
`C.
`
`11.
`
`Constructions for U.S. Patent No. 6,668,419
`
`Dr. Maslen opines that the structures for the “means for maintaining the
`
`clearance” “include simple pegs installed between the two stiffeners, (70) or (170) in Figures 4, 5,
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`6, and 7 of ’419, springs (256) driving the two stiffeners onto outer stops (248) as indicated in
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`Figures 9, 10, and 11, or screws (354) and (356) passing through the stiffeners as indicated in
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`Figures 12 and 13.” (Maslen Rep. at 14.)
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`12.
`
`As stated in paragraph 6 above, it is my understanding that in determining the
`
`construction of a “means-plus-function” claim term, the claimed function is first identified, and
`
`then the corresponding structure for that function as disclosed in the specification is identified.
`
`Dr. Maslen does not identify the function for the “means for maintaining the clearance” term.
`
`13.
`
`It is my opinion that in claims 1, 2 and 6, the function of the “means for
`
`maintaining the clearance” is to maintain the clearance between the facing longitudinal edges of
`
`the springs of the carrier element and the wiper strip bridge, and the corresponding structures
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`disclosed in the specification are a peg situated on the base plate of a bridge-shaped component,
`
`or finger-like projections of the end cap wall that can be moved against spring force, or
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`components held on the connecting device that penetrate springs in recesses. (’419 patent at
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`1:28–62, 2:1–35, 2:40–46, 3:57–4:3, 4:37–52, 4:63–5:20, 5:28–42, 6:34–55, 7:20–8:34, and Figs.
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`3–12.)
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`4
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 5 of 15 PageID #: 5769
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`D.
`
`14.
`
`Constructions for U.S. Patent No. 6,836,926
`
`I understand that Dr. Maslen states that the second moment of inertia, Izz, should
`
`be calculated as
`
`. (Maslen Rep. at 6.) I disagree.
`
`15.
`
`As set forth in paragraphs 4-11 in my opening declaration dated April 22, 2015, it
`
`is my opinion that Izz is properly calculated as
`
`I
`
`3bd
`
`12
`
`
`
`zz
`
`. Such formula finds support in the
`
`specification of the ’926 patent, which expressly teaches using this formula to calculate Izz for
`
`the support element “of a rectangular profile.” (’926 patent at 6:58–7:1.)
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`16.
`
`Dr. Maslen’s proposed construction is contradicted by the express disclosure in
`
`the ’926 patent. His own report confirms that a person of ordinary skill in the art would
`
`understand that the ’926 patent relates to a lateral deflection angle of a wiper blade in a plane of
`
`the windshield (Maslen Rep. at 4, 6-7). Accordingly, to calculate the relevant moment of inertia
`
`“Izz” one would use the equation from the specification,
`
`I
`
`3bd
`
`12
`
`
`
`zz
`
`. It is my opinion that one
`
`of skill in the art would not calculate “Izz“ based on the axes’ positions on Figures 4, 5, and 7, as
`
`that value would not be useful in estimating the lateral deflection of a beam in the plane of the
`
`window.
`
`E.
`
`17.
`
`Constructions for U.S. Patent No. 6,973,698
`
`Dr. Maslen opines regarding the term a “spherically curved window.” He states
`
`without reference that: “‘spherically curved’ is often used to denote curved surfaces that are
`
`curved in any of two perpendicular directions at any given point on the surface.” Further, he
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`states that “a spherically curved surface has, at any given point, no direction along which the
`
`surface is straight” and that “it would not be correct to say that a spherically curved surface has
`
`5
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 6 of 15 PageID #: 5770
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`‘at least one radius of curvature’ as is asserted in Bosch’s proposed claim constructions.”
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`(Maslen Rep. at 14.) I disagree.
`
`18.
`
`In my opinion, the term “spherically curved window” when read in light of the
`
`surrounding claim language and the specification, is easily understood. One of skill in the art
`
`designing a wiper blade on or about April 1, 1998 (the filing date of the German priority
`
`application for the ’698 patent) would have known that cars have spherically curved windows
`
`with variable curvature; therefore; “spherically curved window” as applied to car windows
`
`means a window with one or more radii of curvature, as proposed by Bosch.
`
`19.
`
`Bosch’s construction—“a window having at least one radius of curvature”—
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`encompasses the construction proposed by the defendants—“a window that is curved in three
`
`dimensions.” (See Joint Claim Construction Chart, D.I. 142, Ex. 1 at 3.) Further, Bosch’s
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`construction captures the ’698 patent’s distinction between “spherically curved windows” and
`
`“flat windows” (’698 patent at 1:34-39). The patent does not distinguish between a “spherically
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`curved” window and “the more generally ‘curved’ vehicle window,” as Dr. Maslen incorrectly
`
`asserts. (Maslen Rep. at 14.)
`
`20.
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`Therefore, it is my opinion that the disputed limitation “spherically curved
`
`window” should be construed as “a window having at least one radius of curvature,” as proposed
`
`by Bosch.
`
`F.
`
`21.
`
`Constructions for U.S. Patent Nos. 7,228,588, 7,484,264, and 8,099,823
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`Dr. Maslen opines that the “support means (58, 144)” is the “third side of a
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`triangular section” of the wind deflection strip that “forms the base of the triangular section
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`which abuts either a region of harder material ‘longitudinal area (62)’ or ‘base strip (130).’”
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`(Maslen Rep. at 15.) I disagree.
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`6
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`

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`22.
`
`As stated in paragraph 6 above, it is my understanding that in determining the
`
`construction of a “means-plus-function” claim term, the claimed function is first identified, and
`
`then the corresponding structure for that function as disclosed in the specification is identified.
`
`23.
`
`It is my opinion that in claims 1 and 14 of the ’588 patent, claims 1 and 2 of
`
`the ’264 patent, and claim 1 of the ’823 patent, the function of the “at least one support means
`
`(58, 144)” is to stabilize the sides of the wind deflection strip, and the corresponding structure as
`
`disclosed in the specification is a wall connected to both sides of the wind deflection strip, or the
`
`channel wall facing the upper belt surface of the support element. (’588 patent at 2:17–41; 3:1–
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`20; 5:35–45; 5:53–67; 6:25–45; 7:13–21; 7:40–59; 8:50–62; 10:2–18; Figs. 2, 3; ’264 patent at
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`2:16-40; 2:66–3:16; 5:27–34; 6:59–7:7; 7:32–8:7; 8:8-15; ’823 patent at 2:18–42; 3:1–12; 5:23–
`
`30; 6:53–67; 7:14–17; 7:30-33; 7:38-44; 8:12-15; 8:29-32; 8:37-39; 8:48–51).
`
`II.
`
`INFRINGEMENT
`
`24.
`
`I understand that to determine infringement, the claims, as construed, are
`
`compared to the accused products; an accused product directly infringes a patent claim when all
`
`of the limitations of the claim are literally present in the accused product. I understand that even
`
`if one or more claim elements are not literally present, an accused product can still infringe a
`
`patent claim under the doctrine of equivalents, if an equivalent of each of those elements is
`
`present in the accused product. I understand that a structure is equivalent if it performs
`
`substantially the same function, in substantially the same way to obtain substantially the same
`
`result as the corresponding structure disclosed in the specification. I am informed that under the
`
`doctrine of equivalents analysis, equivalency should be considered as of the time of infringement.
`
`25.
`
`I reviewed and analyzed a sample 18-inch Goodyear Hybrid windshield wiper
`
`blade. This wiper blade has a steel, spring-elastic element of a substantially rectangular cross-
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`7
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 8 of 15 PageID #: 5772
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`sectional profile, which is curved in its free state. All other wiper blade components are attached
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`to it (either directly or indirectly). In my opinion, the pre-curved, steel, spring-elastic element
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`meets the “support element” limitation, as claimed in the asserted patents, including
`
`the ’988, ’926, and ’096 patents. An exploded view of the Goodyear Hybrid blade is shown
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`below.
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`support element
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`connecting device
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`wiper strip
`
`
`
`26.
`
`Dr. Maslen states: “Both the drawings and specification of ’926 clearly indicate
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`that the claimed ‘support element (12)’ is a pre-curved spring that is substantially rectangular in
`
`cross sectional profile and that is ‘attached’ to both the claimed ‘connecting device (16)’ and the
`
`claimed ‘wiper strip (14).’” (Maslen Rep. at 4.) His opinion supports my determination that the
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`Goodyear Hybrid blade has a support element (see picture above).
`
`27.
`
`Dr. Maslen states that the element he identifies as a “stiffener” in conventional
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`wiper blades (e.g., U.S. Patent No. 2,596,063 to Anderson) is “very flexible in the direction
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`perpendicular to the windshield, … [which] enabled the wiper blade to more readily conform to
`
`the curved surface of the windshield but necessitated the more complex bracket-style support
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`structure.” (Costco Tutorial at 6.) This is consistent with my understanding of the properties and
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`function of such flexible strips in conventional wiper blades. Dr. Maslen further explains that in
`
`8
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 9 of 15 PageID #: 5773
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`a beam-style wiper blade the beam is much stiffer such that it can “distribute the force applied by
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`the sweep arm across the length of the wiper blade more or less uniformly even when wiping a
`
`curved windshield.” (Costco Tutorial at 9, 13.) This is also consistent with my understanding of
`
`how the beam-style wiper blades work.
`
`28.
`
`Unlike the flexible strips in conventional blades, the spring-elastic element in a
`
`Goodyear Hybrid blade is stiff in the direction perpendicular to the windshield. In my opinion,
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`the stiff, pre-curved, spring-elastic steel element in the Goodyear Hybrid blades acts as the
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`support element of a beam blade, distributing the force from the wiper arm along the length of
`
`the wiper strip.
`
`29.
`
`Dr. Maslen opines that in the Goodyear Hybrid wiper blade the steel, spring-
`
`elastic element together with the plastic structure on top (he calls the entire structure a “support
`
`bracket system”) “accomplishes distribution of the wiper arm load,” and that all “of these co-
`
`acting elements are crucial to accomplishing relatively uniform distribution of the wiper arm
`
`force across the length of the wiper strip.” (Maslen Rep. at 4). He further states that the
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`“mechanics of the Goodyear Hybrid wiper support system are the same, in principle, as the wiper
`
`support system disclosed in” a patent on a conventional wiper blade (U.S. Patent No. 3,418,679
`
`to Barth). (Id.) I disagree.
`
`30.
`
`In my opinion, the plastic structure on top of the Goodyear Hybrid wiper blade is
`
`not a conventional “support bracket design.” The plastic structure does not distribute the force
`
`from the wiper arm over the wiper blade’s length by itself; the Goodyear Hybrid blade requires
`
`the use of the stiff, pre-curved, spring-elastic steel support element, to which the plastic structure
`
`is attached. The plastic structure serves to transfer the force from the wiper arm to the support
`
`element, which then distributes the force along the length of the Goodyear Hybrid blade.
`
`9
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 10 of 15 PageID #: 5774
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`Accordingly, the Goodyear Hybrid wiper blade includes the support element as claimed in
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`Bosch’s ’988, ’926 and ’096 patents, either literally or under the doctrine of equivalents.
`
`A.
`
`The Goodyear Hybrid Blade Meets the Limitations of Asserted Claim 1 of
`U.S. Patent No. 6,553,607
`
`31.
`
`Dr. Maslen opines, without an explanation, that the Goodyear Hybrid blade does
`
`not include “structure that corresponds to the ’607 patent claimed ‘means for securing the wiper
`
`blade on the joint pin.’” (Maslen Rep. at 10.) I disagree.
`
`32.
`
`It is my understanding that one of the intended uses of a Goodyear Hybrid blade
`
`is to be connected to a side-lock wiper arm, which includes an L-shaped shoulder. It is my
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`opinion that the L-shaped shoulder is the claimed “means for securing the wiper blade on the
`
`joint pin.” (See paragraphs 6-7 above). Therefore, a wiper apparatus consisting of a Goodyear
`
`Hybrid blade attached to a side lock wiper arm includes this element. See picture below; see also
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`installation instructions for the Goodyear Hybrid blade, attached as Exhibit 3.
`
`securing means
`(means for securing)
`
`
`
`I understand that Costco proposes that “‘means for securing’ denotes both the coupling part (30)
`
`and the L-shaped shoulder (60) depicted and described in the ‘607 patent specification and
`
`drawings, and equivalents thereof.” Under Costco’s proposed construction, this limitation is
`
`present in the Goodyear Hybrid blade assembly at least under the doctrine of equivalents.
`
`10
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 11 of 15 PageID #: 5775
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`B.
`
`The Goodyear Hybrid Blade Meets the Limitations of Asserted Claim 11 of
`U.S. Patent No. 6,611,988
`
`33.
`
`Dr. Maslen opines that the Goodyear Hybrid blade lacks the following limitations
`
`of claim 11: “support element,” “a coupling part (20) … seated on another band face (18) of the
`
`support element,” and “hinge half.” (Maslen Rep. at 8, 10.) I disagree.
`
`34.
`
`First, it is my opinion that the Goodyear Hybrid blade includes a support element
`
`for the reasons discussed in paragraphs 25-30 above.
`
`35.
`
`Second, it is my opinion that the coupling part of a Goodyear Hybrid blade is
`
`“seated on another band face of the support element.” Indeed, in operation, the coupling part is
`
`seated on the central plastic component, which in turn is seated on the upper band face of the
`
`support element. Thus, this limitation is met either literally or under the doctrine of equivalents.
`
`36.
`
`Third, it is my opinion that the Goodyear Hybrid blade includes a “hinge half.”
`
`The “hinge half” is properly construed as a “portion of the coupling part formed by the bearing
`
`recess.” See paragraphs 8-10 above. The hinge half of the Goodyear Hybrid blade is formed by
`
`the bearing recess (cutout) on the coupling part. See picture below.
`
`hinge half
`
`
`
`37.
`
`The wiper blade, adaptor, and wiper arm together form a complete hinge, where
`
`the wiper blade can rotate relative to the wiper arm, swinging about a hinge axis (see pictures
`
`below). Thus, the limitation is met either literally or under the doctrine of equivalents. Dr.
`
`Maslen’s contrary opinion (Maslen Rep. at 10) is incorrect.
`
`11
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 12 of 15 PageID #: 5776
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`
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`wiper arm
`
`
`wiper blade
`
`
`
`38.
`
`It is therefore my opinion that the Goodyear Hybrid blade meets each of the
`
`disputed limitations of the asserted claim 11 of the ’988 patent.
`
`C.
`
`The Goodyear Hybrid Blade Meets the Limitations of Asserted Claims 1 and
`2 of U.S. Patent No. 6,836,926
`
`39.
`
`Dr. Maslen opines that the Goodyear Hybrid blade does not meet the limitation of
`
`claim 1 that “the support element is an elongated, flat bar to which the wiper strip and the
`
`connecting device are attached,” and “does not remotely satisfy the formula stated in the claim.”
`
`(Maslen Rep. at 4, 7.) I disagree.
`
`40.
`
`First, as discussed above in paragraphs 25-30 above, the Goodyear Hybrid blade
`
`includes the claimed support element.
`
`41.
`
`Second, the connecting device of the Goodyear Hybrid blade is attached to the
`
`support element via the plastic structure, thus meeting this element either literally or under the
`
`doctrine of equivalents. See picture below.
`
`
`plastic structure
`
`connecting device
`
`support element
`
`
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`12
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 13 of 15 PageID #: 5777
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`42.
`
`Third, calculating Izz, based on the patent disclosure, as
`
`I
`
`3bd
`
`12
`
`
`
`zz
`
` (see
`
`paragraphs 15-16 above), and based on information I reviewed regarding the force exerted on the
`
`wiper blade by the wiper arm, the modulus of elasticity of steel, and the dimensions of the
`
`Goodyear Hybrid wiper blade’s support element, it is my opinion that the support element of the
`
`Goodyear Hybrid blade meets the claimed inequalities in claims 1 and 2 of the ’926 patent,
`
` and
`
` , respectively.
`
`43.
`
`Dr. Maslen opines that the metal support element “does not, by itself, provide any
`
`basis for calculating the extent to which the Goodyear Hybrid support system bends or deflects
`
`when it is pushed or pulled by a wiper arm in the z-axis direction generally parallel to a
`
`windshield.” (Maslen Rep. at 6). However, claims 1 and 2 of the ’926 patent do not require the
`
`calculation of the extent to which the Goodyear Hybrid blade bends or deflects when it is pushed
`
`or pulled by a wiper arm in the plane of a windshield. The claims only require that the support
`
`element of a wiper blade meets the claimed inequality (see paragraph 42 above).
`
`44.
`
`The formula
`
`
`
`does not purport to calculate the exact lateral deflection
`
`of a wiper blade. The inequality in the asserted claims of the ’926 patent only provides a useful
`
`approximation for a wiper blade lateral deflection angle. If a wiper blade support element meets
`
`the inequality, then the lateral deflection is within the range where slip-stick effect is minimal
`
`and wiper performance is better. The plastic structure on top of the Goodyear Hybrid blade
`
`could only increase its lateral stiffness, therefore the corresponding lateral deflection angle
`
`would decrease, and the inequality would still be met.
`
`13
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 14 of 15 PageID #: 5778
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`45.
`
`It is therefore my opinion that the Goodyear Hybrid blade meets each of the
`
`disputed limitations of the asserted claims 1 and 2 of the ’926 patent.
`
`D.
`
`The Goodyear Hybrid Blade Meets the Limitations of Asserted Claims 1, 18,
`and 21 of U.S. Patent No. 8,272,096
`
`46.
`
`Dr. Maslen opines that the Goodyear Hybrid blade lacks the “at least one support
`
`element,” the “covering cap (16),” and the “connection element (22) fastened to the wiper arm”
`
`limitations claimed in the asserted independent claims of the ’096 patent. (Maslen Rep. at 11, 12,
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`13.) I disagree.
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`47.
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`First, as discussed above in paragraphs 25-30, it is my opinion that the Goodyear
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`Hybrid blade includes a support element.
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`48.
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`Further, it is my opinion that the Goodyear Hybrid blade has a “covering cap,” as
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`shown in the picture below. Under Costco’s proposed construction, this limitation is present at
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`least under the doctrine of equivalents.
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`covering cap
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`49.
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`Finally, when the Goodyear Hybrid blade is attached to a side lock wiper arm—
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`one of its intended uses, it includes the “connection element fastened to the wiper arm.” See
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`picture below; see also installation instructions for the Goodyear Hybrid blade, attached as
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`
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`Exhibit 3.
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`connection
`element
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`
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`14
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`

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`Case 1:12-cv-00574-LPS Document 175 Filed 05/19/15 Page 15 of 15 PageID #: 5779
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`50.
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`It is therefore my opinion that Costco’s Goodyear Hybrid blade meets each of the
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`disputed limitations of the asserted claims 1, 18, and 21 of the ’096 patent.
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` declare under penalty of perjury that the foregoing is true and correct.
`
` I
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`
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`Executed on: May 19, 2015
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`
`___
`___
`Steven Dubowsky, Sc.D.
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`15