`
`Case 1:17—cv—OO300—UNA Document 1-29 Filed 03/20/17 Page 1 of 34 Page|D #: 870
`
`EXHIBIT 29
`
`EXHIBIT 29
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 2 of 34 PageID #: 871
`
`U.S. Patent No. 7,928,348
`
`Claims 24, 25, 26, and 27.
`Toyota / Aisin Pump
`Toyota P/N G9040-52010
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 3 of 34 PageID #: 872
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`The Toyota / Aisin Water Pump (the “Aisin Pump”) has a Toyota part number G9040-52010:
`
`24. A fluid conveying
`mechanism comprising:
`
`IMG_1896.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 4 of 34 PageID #: 873
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`The Aisin Pump is marked with the Aisin logo:
`
`IMG_1900.JPG
`
`The Aisin Pump is a water pump and is believed to be installed in the following 2016 Toyota models:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 5 of 34 PageID #: 874
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`(cid:120) Toyota Highlander Hybrid Limited 3.5L V6 - Electric/Gas
`
`(cid:120) Toyota Highlander LE 2.7L L4 - Gas
`
`(cid:120) Toyota Highlander XLE 3.5L V6 - Gas
`
`(cid:120) Toyota Highlander LE Plus 3.5L V6 - Gas
`
`(cid:120) Toyota Highlander Limited 3.5L V6 - Gas
`
`(cid:120) Toyota Highlander LE 3.5L V6 – Gas
`
`See http://www.toyota.com/highlander/
`
`(cid:120) Toyota Prius C Four 1.5L L4 - Electric/Gas
`
`(cid:120) Toyota Prius C One 1.5L L4 - Electric/Gas
`
`(cid:120) Toyota Prius C Three 1.5L L4 - Electric/Gas
`
`(cid:120) Toyota Prius C Two 1.5L L4 - Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 6 of 34 PageID #: 875
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`(cid:120) Toyota Prius C Persona Series 1.5L L4 - Electric/Gas
`
`(cid:120) Toyota Prius V Five 1.8L L4 - Electric/Gas
`
`(cid:120) Toyota Prius V Four 1.8L L4 – Electric/Gas
`
`(cid:120) Toyota Prius V Three 1.8L L4 – Electric/Gas
`
`(cid:120) Toyota Prius V Two 1.8L L4 – Electric/Gas
`
`See http://www.toyota.com/prius/
`
`http://parts.olathetoyota.com/oe-toyota/g904052010 (accessed January 23, 2017).
`
`The Aisin Pump is made in Japan:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 7 of 34 PageID #: 876
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`52010box.jpg
`
`As shown in greater detail below, the Aisin Pump comprises a fluid conveying mechanism. For example, the Aisin pump is a
`water pump, as indicated on its packaging:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 8 of 34 PageID #: 877
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`52010box.jpg
`
`By way of further example, as shown in the images below, the Aisin Pump contains a fluid pathway to conduct fluid, in
`which fluid enters the motor via the fluid inlet, travels along the fluid pathway, and then exits the motor via the fluid outlet.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 9 of 34 PageID #: 878
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`IMG_1916.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 10 of 34 PageID #: 879
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`IMG_1946.JPG
`
`
`
`a) an electromagnetic field-
`functioning device having a
`magnetically inducible core
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 11 of 34 PageID #: 880
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`
`The Aisin Pump comprises an electromagnetic field-functioning device having a magnetically inducible core.
`
`For example, the Aisin Pump contains a stator assembly comprising poles with wire windings wrapped around said poles.
`The poles, combined with an electric input, create a rotating magnetic field containing moving polarities within the core. At
`least one (permanent) magnet is contained within a rotor, which sits in the middle of the stator assembly (i.e., the core). The
`rotor fits into a molded space in the monolithic body of the motor of the Aisin Pump, such space being located in the middle
`of the stator assembly. This location situates the magnet within the core of the stator assembly, in the center of the poles
`with copper wire windings wrapped around them. An electric input provides a charge to these windings (conductors), which
`then allows the polarity of the poles to change. The magnet then rotates with the changing polarities of the poles.
`
`Pictured below is a cross section of the rotor showing the magnet within:
`
`IM IMG_1990.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 12 of 34 PageID #: 881
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`Also pictured below are conductors (wire windings) situated around the molded space in which the rotor, containing the at
`least one magnet, sits:
`
`IMG_2007.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 13 of 34 PageID #: 882
`U.S. Patent No. 7,928,348: Claim 24
`"and at least one electrical conductor that creates a magnetic field in the core when electrical current is conducted through the conductor;"
`
`and at least one electrical
`conductor that creates a
`magnetic field in the core
`when electrical current is
`conducted through the
`conductor;
`
`The Aisin Pump comprises at least one electrical conductor that creates a magnetic field in the core when electrical current is
`conducted through the conductor.
`
`For example, as explained above, the Aisin Pump comprises a stator assembly with copper wires wrapped around the poles
`of the stator assembly. These wires are conductors.
`
`IMG_2010.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 14 of 34 PageID #: 883
`U.S. Patent No. 7,928,348: Claim 24
`"and at least one electrical conductor that creates a magnetic field in the core when electrical current is conducted through the conductor;"
`These conductors create a magnetic field in the core when electrical current is conducted through the conductor.
`
`https://www.nde-ed.org/EducationResources/HighSchool/Electricity/electrostaticfield.htm
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 15 of 34 PageID #: 884
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`b) a monolithic body of
`injection molded
`thermoplastic material
`
`The Aisin Pump comprises a monolithic body of injection molded thermoplastic material.
`
`The monolithic body of the Aisin Pump includes a “PPS – GF 30” label:
`
`IMG_2043.JPG
`
`“PPS – GF 30” refers to polyphenylene sulfide with 30% glass fiber filler (“PPS-GF30”). See, e.g., U.S. Patent Publication
`2009/0173903 (application No. 12/295,565), at ¶ 0114 (“The abbreviations of the resin names in the tables above are as
`follows. PPS-GF30: Polyphenylene sulfide resin containing 30 wt % of glass fibers”).
`
`PPS-GF30 is a thermoplastic – the excerpt pictured below is a summary of its properties (including the categories of which it
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 16 of 34 PageID #: 885
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`is a member, which includes “thermoplastic”) from the MatWeb material property database.
`
`http://www.matweb.com/search/DataSheet.aspx?MatGUID=c43bc743bdc0413ead2b87aca2e38a30&ckck=1 (downloaded
`Dec. 9, 2016).
`
`The “PPS – GF 30” label on the Aisin Pump denotes that the plastic body of the Aisin Pump is made of this type of
`thermoplastic material.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 17 of 34 PageID #: 886
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`IMG_1910.JPG
`
`PPS-GF30 is commonly used in injection molding processes to manufacture parts:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 18 of 34 PageID #: 887
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`https://plastics.ulprospector.com/generics/41/polyphenylene-sulfide-pps (downloaded Dec. 15, 2016).
`
`The monolithically formed body of the motor of the Aisin Pump contains markings that indicate it as manufactured using
`injection molding. For example, as shown in the images below, the monolithically formed body of the Aisin Pump shows
`signs of gates and knockout pins, such markings being associated only with injection molded manufacturing.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 19 of 34 PageID #: 888
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`IMG_1916.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 20 of 34 PageID #: 889
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`IMG_1900.JPG
`
`The body of the Aisin pump is visibly fused into a single monolithic piece:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 21 of 34 PageID #: 890
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`IMG_1918.JPG
`
`IMG_1920.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 22 of 34 PageID #: 891
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`IMG_2040.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 23 of 34 PageID #: 892
`U.S. Patent No. 7,928,348: Claim 24
`"substantially encapsulating the at least one conductor;"
`
`substantially encapsulating
`the at least one conductor;
`
`The thermoplastic, injection molded, monolithic body of the Aisin Pump substantially encapsulates the at least one
`conductor.
`
`As explained above, the Aisin Pump comprises a stator assembly with copper wires wrapped around the poles of the stator
`assembly. These wires are conductors.
`
`The conductors are substantially encapsulated within the body of PPS – GF 30. For example, the photo below shows the
`conductors substantially encapsulated within the body of PPS – GF 30.
`
`IMG_2037.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 24 of 34 PageID #: 893
`U.S. Patent No. 7,928,348: Claim 24
`"and c) a fluid pathway at least partially embedded in and integral with the monolithic body,"
`
`and c) a fluid pathway at
`least partially embedded in
`and integral with the
`monolithic body,
`
`The Aisin Pump comprises a fluid pathway at least partially embedded in and integral with the monolithic body.
`
`The Aisin Pump comprises a fluid pathway contained within the monolithic body, with fluid inlets and outlets. As shown in
`the images below, the fluid pathway is molded within the thermoplastic material of the monolithic body, and is contained
`inside the body itself.
`
`The photo below shows the fluid inlet and fluid outlet into the fluid pathway of the Aisin Pump.
`
`IMG_1916.JPG
`
`A horizontal cross-section of the Aisin Pump shows the fluid pathway molded and located within the monolithic body of the
`Aisin Pump.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 25 of 34 PageID #: 894
`U.S. Patent No. 7,928,348: Claim 24
`"and c) a fluid pathway at least partially embedded in and integral with the monolithic body,"
`
`IMG_1946.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 26 of 34 PageID #: 895
`U.S. Patent No. 7,928,348: Claim 24
`"with at least one of a fluid inlet into the pathway and a fluid outlet from the pathway being formed in the body of injection molded thermoplastic,"
`
`with at least one of a fluid
`inlet into the pathway and a
`fluid outlet from the
`pathway being formed in the
`body of injection molded
`thermoplastic,
`
`The fluid pathway of the Aisin Pump contains at least one of a fluid inlet into the pathway and a fluid outlet from the
`pathway being formed in the body of injection molded thermoplastic.
`
`As shown in the below images, the Aisin Pump comprises a fluid inlet and a fluid outlet, shaped from the thermoplastic
`material and attached to the monolithic body. The fluid inlet and the fluid outlet allow fluid (e.g., water) to enter and exit the
`fluid pathway, respectively.
`
`IMG_1916.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 27 of 34 PageID #: 896
`U.S. Patent No. 7,928,348: Claim 24
`"and the pathway through the body being confined within the body."
`
`and the pathway through the
`body being confined within
`the body.
`
`The fluid pathway through the body of the Aisin Pump is confined within the body.
`
`As shown in the image below, the fluid pathway is located within the monolithic body of the Aisin Pump:
`
`IMG_1916.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 28 of 34 PageID #: 897
`U.S. Patent No. 7,928,348: Claim 24
`"and the pathway through the body being confined within the body."
`
`IMG_1917.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 29 of 34 PageID #: 898
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`25. The fluid conveying
`mechanism of claim 24
`wherein the device is
`operable to power fluid
`conveyance through the
`mechanism and at least a
`portion of the fluid
`conveyed by the mechanism
`passes through the fluid
`pathway in the monolithic
`body.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein the device is operable to power fluid
`conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes through the fluid
`pathway in the monolithic body.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. See the chart of claim 24, supra.
`
`The rotor of the motor of the Aisin Pump spins during motor operation due to a magnet located within the rotor. The rotation
`of the rotor spins an impeller attached to the top of the rotor. See chart of claim 24, supra.
`
`The rotor powers fluid conveyance through the mechanism in the fluid pathway confined in the body. Pictured below is the
`fluid impeller, a part of the rotor for moving fluid through the fluid pathway:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 30 of 34 PageID #: 899
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`IMG_1953.JPG
`
`The pictures below show the placement of the impeller relative to the main rotor body. In the first image, the rotor has been
`partially cut-through, and the second image is a cross-section of the rotor and impeller:
`
`IMG_1980.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 31 of 34 PageID #: 900
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`IMG_1999.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 32 of 34 PageID #: 901
`U.S. Patent No. 7,928,348: Claim 26
`"wherein the mechanism is selected from the group consisting of valves, pumps and blowers."
`
`26. The fluid conveying
`mechanism of claim 24
`wherein the mechanism is
`selected from the group
`consisting of valves, pumps
`and blowers.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein the mechanism is selected from the group
`consisting of valves, pumps and blowers.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. See chart of claim 24, supra.
`
`The Aisin Pump is selected from the group consisting of valves, pumps and blowers. Specifically, the Aisin Pump is a
`pump.
`
`For example, the Aisin Pump is referred to as a water pump on the packaging of the product, as seem in the images below.
`
`IMG_2003.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 33 of 34 PageID #: 902
`
`27. The fluid conveying
`mechanism of claim 24
`wherein said at least one of
`a fluid inlet and a fluid
`outlet is in the form of a
`plumbing fitting.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein said at least one of a fluid inlet and a fluid
`outlet is in the form of a plumbing fitting.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. See chart of claim 24, supra.
`
`At least one of a fluid inlet and a fluid outlet of the Aisin Pump is in the form of a plumbing fitting. Specifically, the fluid
`inlet is in the form of a plumbing fitting. As shown in the images below, the fluid inlet connects the Aisin Pump to tubing
`within the engine.
`
`IMG_1917.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-29 Filed 03/20/17 Page 34 of 34 PageID #: 903
`A diagram that shows the placement of this part in relation to other parts in a vehicle shows a piece of tubing or piping being
`connected to the fluid inlet of this Aisin Pump:
`
`http://www.oempartworld.com/oe-toyota/g904052010 (accessed January 25, 2017)
`
`