Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 1 of 21 PageID #: 225
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`Case 1:17—cv—00300—UNA Document 1-10 Filed 03/20/17 Page 1 of 21 Page|D #: 225
`
`EXHIBIT 10
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`EXHIBIT 10
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`
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`Case 1:17—cv—00300—UNA Document 1-10 Filed 03/20/17 Page 1 of 21 Page|D #: 225
`
`EXHIBIT 10
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`EXHIBIT 10
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`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 2 of 21 PageID #: 226
`
`U.S. Patent No. 7,067,944
`
`Claim 3
`Toyota / Aisin Large Pump
`Toyota P/N 161A0-39035
`
`
`
`3. A motor comprising:
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 3 of 21 PageID #: 227
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Toyota / Aisin Water Pump (the “Aisin Pump”) has Toyota part number 161A0-39035:
`
`20160808_101959.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 4 of 21 PageID #: 228
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Aisin Pump is marked with the Aisin logo.
`
`20160808_102609.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 5 of 21 PageID #: 229
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Aisin Pump is a water pump and is believed to be installed in the following 2016 Toyota models:
`
`(cid:131)
`
`2016 Toyota Prius Four Touring 1.8L L4 - Electric/Gas
`
`http://st.automobilemag.com/uploads/sites/11/2015/11/2016-Toyota-Prius-Four-Touring-front-three-quarter-01.jpg
`2016 Toyota Prius Three Touring 1.8L L4 - Electric/Gas
`(cid:131)
`
`http://o.aolcdn.com/dims-
`global/dims3/GLOB/resize/708x398/quality/60/http://o.aolcdn.com/commerce/autodata/images/USC60TOC161D022000.jpg
`
`(cid:131)
`
`2016 Toyota Prius Two Eco 1.8L L4 - Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 6 of 21 PageID #: 230
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`http://media.caranddriver.com/images/media/51/2016-toyota-prius-two-eco-inline5-photo-666564-s-original.jpg
`
`(cid:131)
`
`2016 Toyota Prius Two 1.8L L4 - Electric/Gas
`
`http://media.caranddriver.com/images/media/51/2016-toyota-prius-two-eco-inline5-photo-666564-s-original.jpg
`
`(cid:131)
`
`2016 Toyota Prius Four 1.8L L4 - Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 7 of 21 PageID #: 231
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`http://st.automobilemag.com/uploads/sites/11/2015/11/2016-Toyota-Prius-Four-Touring-front-three-quarter-01.jpg
`
`(cid:131)
`
`2016 Toyota Prius Three 1.8L L4 - Electric/Gas
`
`http://o.aolcdn.com/dims-
`global/dims3/GLOB/resize/708x398/quality/60/http://o.aolcdn.com/commerce/autodata/images/USC60TOC161D022000.jpg
`See also http://parts.olathetoyota.com/oe-toyota/161a039035 (accessed December 12, 2016).
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 8 of 21 PageID #: 232
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`The Aisin pump is made in Japan:
`
`20160808_101959.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 9 of 21 PageID #: 233
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Aisin Pump is an electric pump assembly, as indicated on the packaging label directly above and as listed below on the
`purchase receipt.
`
`20160808_084505.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 10 of 21 PageID #: 234
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`As shown in greater below with respect to the other limitations of claim 1, the Aisin Pump is an electric motor having a
`stator and a rotor, where the stator is designed to cause the rotor to rotate during operation.
`
`20160808_102536.jpg
`
`
`
`a) a core having poles and
`windings around said poles
`forming a pole assembly;
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 11 of 21 PageID #: 235
`U.S. Patent No. 7,067,944: Claim 3
`"a) a core having poles and windings around said poles forming a pole assembly;"
`The Pump comprises a core having poles and windings around said poles forming a pole assembly.
`
`For example, as shown in the photo below, the motor of the Pump has a plurality of poles that are formed by laminations and
`arranged together in a circular shape to form a core. Each pole is wrapped with copper wire windings.
`
`20160811_130736.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 12 of 21 PageID #: 236
`U.S. Patent No. 7,067,944: Claim 3
`"a) a core having poles and windings around said poles forming a pole assembly;"
`
`PC124758.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 13 of 21 PageID #: 237
`U.S. Patent No. 7,067,944: Claim 3
`"a) a core having poles and windings around said poles forming a pole assembly;"
`For example, the Pump’s poles and windings around said poles form a pole assembly:
`
`20160811_125705.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 14 of 21 PageID #: 238
`U.S. Patent No. 7,067,944: Claim 3
`"b) a shaft, the shaft and pole assembly not being in direct contact with one another, but rather the shaft being spaced from the pole assembly; and"
`The Pump comprises a shaft, the shaft and pole assembly not being in direct contact with one another, but rather the shaft
`b) a shaft, the shaft and pole
`being spaced from the pole assembly.
`assembly not being in direct
`contact with one another,
`but rather the shaft being
`spaced from the pole
`assembly; and
`
`For example, as shown in the picture below, the motor of the Pump contains a shaft:
`
`20160808_093422.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 15 of 21 PageID #: 239
`U.S. Patent No. 7,067,944: Claim 3
`"b) a shaft, the shaft and pole assembly not being in direct contact with one another, but rather the shaft being spaced from the pole assembly; and"
`The shaft does not directly contact the core or the windings of the pole assembly. The shaft is positioned within and spaced
`from the pole assembly:
`
`20160811_134035.jpg
`
`
`
`c) a thermoplastic material
`secured to the shaft and
`substantially encapsulating
`the pole assembly
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 16 of 21 PageID #: 240
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`The Pump comprises a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly.
`
`For example, the motor of the Pump includes a thermoplastic body that is formed from a material identified on the Pump as
`“PPS – GF 30” as shown below:
`
`20160808_085341.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 17 of 21 PageID #: 241
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`20160808_101659.jpg
`
`This label indicates that the body is made from polyphenylene sulfide with 30% glass fiber filler (“PPS-GF30”). PPS-GF30
`is a known thermoplastic.
`
`http://www.matweb.com/search/DataSheet.aspx?MatGUID=c43bc743bdc0413ead2b87aca2e38a30&ckck=1
`
`PPS-GF30 is used in injection molding processes to manufacture parts.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 18 of 21 PageID #: 242
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`https://plastics.ulprospector.com/generics/41/polyphenylene-sulfide-pps
`
`The thermoplastic body contains a portion that surrounds and secures to a rigid shaft assembly comprising the shaft rigidly
`fixed to an annular metal insert:
`
`20160808_093422.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 19 of 21 PageID #: 243
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`20160811_134035.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 20 of 21 PageID #: 244
`U.S. Patent No. 7,067,944: Claim 3
`"c) the thermoplastic material joining the pole assembly to the shaft in the space between the pole assembly and the shaft, filling in the space between them
`such that the windings, core and shaft are rigidly fixed together."
`The pump comprises thermoplastic material joining the pole assembly to the shaft in the space between the pole assembly
`and the shaft, filling in the space between them such that the windings, core and shaft are rigidly fixed together.
`
`c) the thermoplastic material
`joining the pole assembly to
`the shaft in the space
`between the pole assembly
`and the shaft, filling in the
`space between them such
`that the windings, core and
`shaft are rigidly fixed
`together.
`
`For example, thermoplastic material encapsulates and rigidly fixes the shaft into the same body of material that encapsulates
`the copper wire, as shown in the picture below:
`
`20160811_134035.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-10 Filed 03/20/17 Page 21 of 21 PageID #: 245
`U.S. Patent No. 7,067,944: Claim 3
`"c) the thermoplastic material joining the pole assembly to the shaft in the space between the pole assembly and the shaft, filling in the space between them
`such that the windings, core and shaft are rigidly fixed together."
`The picture directly below shows the Pump from the reverse side, with the shaft extending outward to receive the rotor:
`
`20160808_093429.jpg
`
`The thermoplastic body substantially encapsulates the pole assembly and also contains a portion that surrounds and secures
`to the shaft. The pole assembly and shaft are separated by a visible distance that is filled with the thermoplastic material, as
`shown above. The thermoplastic material rigidly fixes the core, copper wire and shaft together.
`
`
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