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Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 1 of 23 PageID #: 329
`
`Case 1:17—cv—OO300—UNA Document 1-15 Filed 03/20/17 Page 1 of 23 Page|D #: 329
`
`EXHIBIT 15
`
`EXHIBIT 15
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 2 of 23 PageID #: 330
`
`U.S. Patent No. 7,067,944
`
`Claims 9
`2017 Toyota Hybrid Transaxle Assembly
`
`

`

`9. A motor comprising:
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 3 of 23 PageID #: 331
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`The 2017 Toyota Hybrid Transaxle Assembly (“Transaxle Assembly”) comprises a motor.
`
`The Transaxle Assembly comprises an electric motor containing a rotor and a stator:
`
`IMG_0903.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 4 of 23 PageID #: 332
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`
`IMG_1189.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 5 of 23 PageID #: 333
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`
`IMG_1046.JPG
`
`Upon information and belief, the Transaxle Assembly is installed in the following 2017 Toyota models:
`
`(cid:120) Avalon Hybrid Limited, XLE Plus and XLE Premium
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 6 of 23 PageID #: 334
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`
`http://www.toyota.com/configurator/#!/build/step/model/year/2017/series/avalon/model/3506
`
`(cid:120) Camry Hybrid LE, SE and XLE
`
`http://www.toyota.com/configurator/#!/build/step/model/year/2017/series/camry/model/2559
`
`(cid:120) Highlander Hybrid Limited
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 7 of 23 PageID #: 335
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`
`http://www.toyota.com/configurator/#!/build/step/model/year/2017/series/highlanderhybrid/model/6966
`
`(cid:120) Prius Four, Four Touring, Three, Three Touring, Two and Two Eco
`
`http://www.toyota.com/configurator/#!/build/step/model/year/2017/series/prius/model/1227
`
`(cid:120) Prius C Four, One, Persona Series, Three, Two
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 8 of 23 PageID #: 336
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`
`http://www.toyota.com/priusc/
`
`(cid:120) Prius V Five, Four, Three, Two
`
`http://www.toyota.com/priusv/
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 9 of 23 PageID #: 337
`U.S. Patent No. 7,067,944: Claim 9
`"9. A motor comprising:"
`(cid:120) RAV4 Hybrid Limited and XLE
`
`http://www.toyota.com/configurator/#!/build/step/model/year/2017/series/rav4/model/4444
`
`Upon information and belief, the Transaxle Assembly is made by Aisin in Japan.
`
`

`

`a) a core;
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 10 of 23 PageID #: 338
`U.S. Patent No. 7,067,944: Claim 9
`"a) a core;"
`The Transaxle Assembly comprises a core.
`
`The motor of the Transaxle Assembly has metal laminations that surround the rotor, which are arranged together in a circular
`shape to form a core, as shown below.
`
`IMG_1047.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 11 of 23 PageID #: 339
`U.S. Patent No. 7,067,944: Claim 9
`"a) a core;"
`
`IMG_1201.JPG
`
`

`

`b) at least one magnet
`spaced from the core; and
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 12 of 23 PageID #: 340
`U.S. Patent No. 7,067,944: Claim 9
`"b) at least one magnet spaced from the core; and"
`The Transaxle Assembly comprises at least one magnet spaced from the core.
`
`For example, the Transaxle Assembly includes a core, which is comprised of circular metal laminations:
`
`IMG_1047.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 13 of 23 PageID #: 341
`U.S. Patent No. 7,067,944: Claim 9
`"b) at least one magnet spaced from the core; and"
`
`IMG_1201.JPG
`
`The core contains various magnets. Each magnet is spaced from the core:
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 14 of 23 PageID #: 342
`U.S. Patent No. 7,067,944: Claim 9
`"b) at least one magnet spaced from the core; and"
`
`IMG_1046.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 15 of 23 PageID #: 343
`U.S. Patent No. 7,067,944: Claim 9
`"b) at least one magnet spaced from the core; and"
`
`IMG_6395.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 16 of 23 PageID #: 344
`U.S. Patent No. 7,067,944: Claim 9
`"c) a thermoplastic material substantially encapsulating the at least one magnet and filling in the space between the at least one magnet and the core such
`that the at least one magnet and the core are rigidly fixed together."
`The Transaxle Assembly comprises a thermoplastic material substantially encapsulating the at least one magnet and filling in
`the space between the at least one magnet and the core such that the at least one magnet and the core are rigidly fixed
`together.
`
`c) a thermoplastic material
`substantially encapsulating
`the at least one magnet and
`filling in the space between
`the at least one magnet and
`the core such that the at
`least one magnet and the
`core are rigidly fixed
`together.
`
`IMG_1047.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 17 of 23 PageID #: 345
`U.S. Patent No. 7,067,944: Claim 9
`"c) a thermoplastic material substantially encapsulating the at least one magnet and filling in the space between the at least one magnet and the core such
`that the at least one magnet and the core are rigidly fixed together."
`
`IMG_1201.JPG
`
`The Transaxle Assembly includes a plastic material substantially encapsulating at least one magnet and filling the space
`between the at least one magnet and the core such that the at least one magnet and the core are rigidly fixed together, as
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 18 of 23 PageID #: 346
`U.S. Patent No. 7,067,944: Claim 9
`"c) a thermoplastic material substantially encapsulating the at least one magnet and filling in the space between the at least one magnet and the core such
`that the at least one magnet and the core are rigidly fixed together."
`shown below. Upon information and belief, this plastic material is a thermoplastic:
`
`IMG_6395.JPG
`
`

`

`11. A motor comprising:
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 19 of 23 PageID #: 347
`U.S. Patent No. 7,067,944: Claim 11
`"11. A motor comprising:"
`The Transaxle Assembly comprises a motor.
`
`See Claim 9, supra.
`
`

`

`a) at least one conductor;
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 20 of 23 PageID #: 348
`U.S. Patent No. 7,067,944: Claim 11
`"a) at least one conductor;"
`The Transaxle Assembly comprises at least one conductor.
`
`The stator of the Transaxle Assembly contains wire windings around the stator poles. These wire windings serve as
`conductors:
`
`IMG_1189.JPG
`
`

`

`b) at least one magnet
`forming at least one pole;
`and
`
`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 21 of 23 PageID #: 349
`U.S. Patent No. 7,067,944: Claim 11
`"b) at least one magnet forming at least one pole; and"
`The Transaxle Assembly comprises at least one magnet forming at least one pole.
`
`For example, the Transaxle Assembly includes at least one permanent magnet. The magnet, as a magnetic dipole, forms both
`a North and a South magnetic pole.
`
`IMG_6395.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 22 of 23 PageID #: 350
`U.S. Patent No. 7,067,944: Claim 11
`"11. A motor comprising:"
`The Transaxle Assembly comprises a thermoplastic material substantially encapsulating the at least one magnet and locating
`and precisely positioning the at least one magnet with respect to the at least one conductor during motor operation.
`
`c) a thermoplastic material
`substantially encapsulating
`the at least one magnet and
`locating and precisely
`positioning the at least one
`magnet with respect to the at
`least one conductor during
`motor operation.
`
`For example, the Transaxle Assembly includes a plastic material substantially encapsulating the at least one magnet and
`locating and precisely positioning the at least one magnet with respect to the at least one conductor during motor operation,
`as shown below. Upon information and belief, this plastic material is a thermoplastic:
`
`IMG_6395.JPG
`
`

`

`Case 1:17-cv-00300-UNA Document 1-15 Filed 03/20/17 Page 23 of 23 PageID #: 351
`
`Case 1:17—cv—OO300—UNA Document 1-15 Filed 03/20/17 Page 23 of 23 Page|D #: 351
`
`

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