Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 1 of 20 PageID #: 309
`Case 1:17—cv—OO300—UNA Document 1-14 Filed 03/20/17 Page 1 of 20 Page|D #: 309
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`EXHIBIT 14
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`EXHIBIT 14
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`Case 1:17—cv—OO300—UNA Document 1-14 Filed 03/20/17 Page 1 of 20 Page|D #: 309
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`EXHIBIT 14
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`EXHIBIT 14
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`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 2 of 20 PageID #: 310
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`U.S. Patent No. 7,067,944
`
`Claim 3
`Aisin Small Pump
`Toyota / Aisin Water Pump G9040-47040
`
`
`
`3. A motor comprising:
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 3 of 20 PageID #: 311
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Toyota / Aisin Water Pump G9040-47040 (“Pump”) includes a motor.
`The Pump has Aisin part number WQT-001.
`
`Aisin Cooling Catalog 2016.pdf at 145 (hereinafter “Aisin Cooling Catalog”), available at
`https://www.aisinaftermarket.com/FlipBook/CoolingCatalog/index.html.
`
`The Aisin Cooling Catalog indicates that the Pump is used in the following Toyota vehicles:
`
` Toyota Prius Two 1.8L L4 – Electric/Gas
`
` Toyota Prius Two Eco 1.8L L4 – Electric/Gas
`
` Toyota Prius Three 1.8L L4 – Electric/Gas
`
` Toyota Prius Three Touring 1.8L L4 – Electric/Gas
`
` Toyota Prius Four 1.8L L4 – Electric/Gas
`
` Toyota Prius Four Touring 1.8L L4 – Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 4 of 20 PageID #: 312
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`global/dims3/GLOB/resize/708x398/quality/60/http://o.aolcdn.com/commerce/autodata/images/USC60TOC161D022000.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 5 of 20 PageID #: 313
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`Aisin Cooling Catalog 2016.pdf at 34, 43, 44.
`
`The Pump’s packaging is marked with the Toyota logo:
`
`IMG_2003.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 6 of 20 PageID #: 314
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Pump itself is marked with the Aisin logo:
`
`IMG_2006.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 7 of 20 PageID #: 315
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Pump includes an electric motor. For example, as shown below on the purchase receipt, the Pump is referred to as a
`pump:
`
`CCF_000055.pdf
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 8 of 20 PageID #: 316
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`As shown in greater detail below, 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.
`
`IMG_2069.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 9 of 20 PageID #: 317
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`IMG_1905.JPG
`
`
`
`a) a core having poles and
`windings around said poles
`forming a pole assembly;
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 10 of 20 PageID #: 318
`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.
`
`IMG_2027.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 11 of 20 PageID #: 319
`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:
`
`IMG_2027.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 12 of 20 PageID #: 320
`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:
`
`IMG_1976.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 13 of 20 PageID #: 321
`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:
`
`IMG_2027.JPG
`
`
`
`c) a thermoplastic material
`secured to the shaft and
`substantially encapsulating
`the pole assembly
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 14 of 20 PageID #: 322
`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:
`
`IMG_2065.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 15 of 20 PageID #: 323
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`IMG_2042.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
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 16 of 20 PageID #: 324
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`PPS-GF30 is used in injection molding processes to manufacture parts.
`
`https://plastics.ulprospector.com/generics/41/polyphenylene-sulfide-pps
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 17 of 20 PageID #: 325
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`The thermoplastic body contains a portion that surrounds and secures to the shaft:
`
`IMG_2013.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 18 of 20 PageID #: 326
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`The thermoplastic material secured to the shaft also substantially encapsulates the pole assembly. For example, as shown in
`the picture below the thermoplastic material of the Pump encapsulates all of the core and the pole assembly.
`
`IMG_2027.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 19 of 20 PageID #: 327
`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:
`
`IMG_2013.JPG
`
`The picture directly below shows the Pump from the reverse side, with the shaft extending outward to receive the rotor:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-14 Filed 03/20/17 Page 20 of 20 PageID #: 328
`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."
`
`IMG_2036.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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