Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 1 of 29 PageID #: 352
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`Case 1:17—cv—OO300—UNA Document 1-16 Filed 03/20/17 Page 1 of 29 Page|D #: 352
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`EXHIBIT 16
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`EXHIBIT 16
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`
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`Case 1:17—cv—OO300—UNA Document 1-16 Filed 03/20/17 Page 1 of 29 Page|D #: 352
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`EXHIBIT 16
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`EXHIBIT 16
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`
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`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 2 of 29 PageID #: 353
`
`U.S. Patent No. 7,067,952
`
`Claims 10 and 12
`Toyota (Lexus) / Denso Power Steering Motor
`Toyota (Lexus) P/N 89650-33640
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 3 of 29 PageID #: 354
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`10. A stator assembly,
`comprising:
`
`The Toyota (Lexus) Power Steering Motor 89650-33640 (“89650-33640”) has Toyota (Lexus) part number 89650-33640:
`
`IMG_1112.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 4 of 29 PageID #: 355
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`IMG_1117.JPG
`
`The 89650-33640 is marked with the Denso logo:
`
`IMG_1117.JPG
`
`Upon information and belief, The 89650-33640 is believed to be installed in the following 2016 Lexus models:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 5 of 29 PageID #: 356
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`(cid:120)
`
`2016 Lexus ES
`
`See, http://www.lexus.com/models/ES
`
`The 89650-33640 is made in Japan:
`
`IMG_1117.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 6 of 29 PageID #: 357
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`The 89650-33640 comprises a motor including a rotor and a stator:
`
`IMG_1124.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 7 of 29 PageID #: 358
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`The 89650-33640 further comprises a stator assembly.
`
`For example, as shown in the picture below, the 89650-33640 includes stator segments arranged in a ring:
`
`IMG_1147.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 8 of 29 PageID #: 359
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`IMG_1240.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 9 of 29 PageID #: 360
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`IMG_1248.JPG
`
`Each stator core element has a stack of metal laminations encased within a white plastic material and with copper wire
`wrapped around the encased lamination stack:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 10 of 29 PageID #: 361
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`IMG_1248.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 11 of 29 PageID #: 362
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`In the pictures below, a single stator segment has been removed from the stator assembly to demonstrate the winding of
`copper wire around each lamination stack:
`
`IMG_1296.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 12 of 29 PageID #: 363
`U.S. Patent No. 7,067,952: Claim 10
`“10. A stator assembly, comprising:”
`
`IMG_1303.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 13 of 29 PageID #: 364
`U.S. Patent No. 7,067,952: Claim 10
`“a) a plurality of discrete stator segments each at least partially encased with a phase change material,”
`
`a) a plurality of
`discrete stator
`segments each at least
`partially encased with
`a phase change
`material,
`
`The 89650-33640 stator assembly comprises a plurality of discrete stator segments each at least partially encased within a
`phase change material.
`
`The nine stacks of metal laminations are encased in white plastic sleeves and comprise a plurality of discrete stator
`segments. Upon information and belief, the white plastic material is a thermoplastic. Each encased stack of metal
`laminations is a discrete stator segment. The stator segments fit together in a ring to form the stator assembly. Seams
`between adjacent stacks are visible in the picture below:
`
`IMG_1284.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 14 of 29 PageID #: 365
`U.S. Patent No. 7,067,952: Claim 10
`“a) a plurality of discrete stator segments each at least partially encased with a phase change material,”
`Each discrete stack of metal laminations has projections and indentations as identified in the picture below that link with
`corresponding projections and indentations of adjacent stator segments:
`
`IMG_1294.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 15 of 29 PageID #: 366
`U.S. Patent No. 7,067,952: Claim 10
`“a) a plurality of discrete stator segments each at least partially encased with a phase change material,”
`
`IMG_1305.JPG
`
`Each discrete stack of metal laminations is partially encased in a white material:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 16 of 29 PageID #: 367
`U.S. Patent No. 7,067,952: Claim 10
`“a) a plurality of discrete stator segments each at least partially encased with a phase change material,”
`
`IMG_1309.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 17 of 29 PageID #: 368
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the phase change material also comprises a bridge between adjacent segments to link adjacent segments into a continuous strip,”
`
`The 89650-33640 stator assembly comprises a phase change material that comprises a bridge between adjacent segments to
`link adjacent segments into a continuous strip.
`
`The material encasing a single stack of metal laminations includes mating sections that link the stator segments of the
`89650-33640 into a continuous strip:
`
`wherein the phase
`change material also
`comprises a bridge
`between adjacent
`segments to link
`adjacent segments
`into a continuous
`strip,
`
`IMG_1281.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 18 of 29 PageID #: 369
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the phase change material also comprises a bridge between adjacent segments to link adjacent segments into a continuous strip,”
`
`IMG_1289.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 19 of 29 PageID #: 370
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the phase change material also comprises a bridge between adjacent segments to link adjacent segments into a continuous strip,”
`
`Pictured below is a display of the continuous strip of stator segments in the 89650-33640 stator assembly having bridges of
`white thermoplastic between stator segments formed by the linking of adjacent mating sections of adjacent segments:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 20 of 29 PageID #: 371
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the phase change material also comprises a bridge between adjacent segments to link adjacent segments into a continuous strip,”
`IMG_1283.JPG
`
`In the picture below, a portion of the circulator stator assembly has been “unrolled” into a linear continuous strip linked by
`the thermoplastic phase change material forming a bridge between adjacent segments:
`
`IMG_1322.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 21 of 29 PageID #: 372
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the bridge is formed by interconnecting two mating sections formed from the phase change material; and”
`
`wherein the bridge is
`formed by
`interconnecting two
`mating sections
`formed from the phase
`change material; and
`
`The 89650-33640 stator assembly comprises a plurality of discrete stator segments each at least partially encased within a
`phase change material that comprises a bridge, wherein the bridge is formed by interconnecting two mating sections formed
`from the phase change material.
`
`For example, the bridges of white thermoplastic between adjacent segments are formed by mating sections as shown below:
`
`IMG_1281.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 22 of 29 PageID #: 373
`U.S. Patent No. 7,067,952: Claim 10
`“wherein the bridge is formed by interconnecting two mating sections formed from the phase change material; and”
`
`IMG_1289.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 23 of 29 PageID #: 374
`U.S. Patent No. 7,067,952: Claim 10
`“b) the linked stator segments being arranged and secured together to form the stator assembly.”
`
`The 89650-33640 stator assembly comprises linked stator segments that are arranged and secured together to form the
`stator assembly.
`
`The plurality of discrete stator segments are linked together in a ring to form the stator assembly:
`
`b) the linked stator
`segments being
`arranged and
`secured together to
`form the stator
`assembly.
`
`IMG_1248.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 24 of 29 PageID #: 375
`U.S. Patent No. 7,067,952: Claim 10
`“b) the linked stator segments being arranged and secured together to form the stator assembly.”
`
`IMG_1240.JPG
`
`In the complete 89650-33640 the stator segments are enclosed in a metal housing that maintains the strip of discrete stator
`segments in a ring as shown in the pictures below:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 25 of 29 PageID #: 376
`U.S. Patent No. 7,067,952: Claim 10
`“b) the linked stator segments being arranged and secured together to form the stator assembly.”
`
`IMG_1144.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 26 of 29 PageID #: 377
`U.S. Patent No. 7,067,952: Claim 12
`“The stator assembly of claim 10 wherein the stator segments are held in a toroidal shape by a retaining member.”
`
`The stator
`assembly of claim
`10 wherein the
`stator segments are
`held in a toroidal
`shape by a
`retaining member.
`
`The 89650-33640 comprises a stator assembly wherein the stator segments are held in a toroidal shape by a retaining member.
`
`The stator segments of the 89650-33640 are held in a toroidal shape by the metallic canister surrounding the stator segments.
`
`Pictured below are the stator segments of the 89650-33640 and the canister retaining them in a toroidal shape:
`
`IMG_1144.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 27 of 29 PageID #: 378
`U.S. Patent No. 7,067,952: Claim 12
`“The stator assembly of claim 10 wherein the stator segments are held in a toroidal shape by a retaining member.”
`
`IMG_1147.JPG
`
`As shown by the pictures below, in which the canister has been cut away from the stator, the outer portions of the stator
`segments are in direct contact with the retaining canister:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 28 of 29 PageID #: 379
`U.S. Patent No. 7,067,952: Claim 12
`“The stator assembly of claim 10 wherein the stator segments are held in a toroidal shape by a retaining member.”
`
`IMG_1271.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-16 Filed 03/20/17 Page 29 of 29 PageID #: 380
`U.S. Patent No. 7,067,952: Claim 12
`“The stator assembly of claim 10 wherein the stator segments are held in a toroidal shape by a retaining member.”
`
`IMG_1269.JPG
`
`
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