`Case 1:17—cv—OO300—UNA Document 1-6 Filed 03/20/17 Page 1 of 20 Page|D #: 142
`
`EXHIBIT 6
`
`EXHIBIT 6
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`
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`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 2 of 20 PageID #: 143
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`U.S. Patent No. 7,067,944
`
`Claim 3
`Toyota / Aisin Large Pump
`Toyota P/N 161A0-29015
`Aisin P/N WPT-190
`
`
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`3. A motor comprising:
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 3 of 20 PageID #: 144
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`The Toyota / Aisin Water Pump (the “Aisin Pump”) has a Toyota part number 161A0-29015 and Aisin part number WPT-
`190:
`
`Aisin Cooling Catalog 2016.pdf at 145 (hereinafter “Aisin
`Cooling Catalog”), available at
`http://aisinaftermarket.com/FlipBook/CoolingCatalog/mobil
`e/index.html (downloaded Dec. 6, 2016)
`
`IMG_1696.JPG
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`
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`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 4 of 20 PageID #: 145
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`The Aisin Pump is marked with both the Toyota and Aisin logos:
`
`IMG_1695.JPG
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`The Aisin Pump is a water pump and is believed to be installed in the following 2016 Toyota models:
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`Toyota Prius C Persona Series 1.5L L4 – Electric/Gas
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`Toyota Prius C Four 1.5L L4 – Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 5 of 20 PageID #: 146
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`Toyota Prius C Two 1.5L L4 – Electric/Gas
`
`Toyota Prius C Three 1.5L L4 – Electric/Gas
`
`Toyota Prius C One 1.5L L4 – Electric/Gas
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`Toyota Prius V Five 1.8L L4 – Electric/Gas
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`Toyota Prius V Two 1.8L L4 – Electric/Gas
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`Toyota Prius V Four 1.8L L4 – Electric/Gas
`
`Toyota Prius V 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/161a039025 (accessed December 12, 2016).
`
`The Aisin Pump is made in Japan:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 6 of 20 PageID #: 147
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`IMG_1696.JPG
`
`The Aisin Pump is an electric pump assembly, as indicated on the packaging label directly above and as listed below on the
`purchase receipt.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 7 of 20 PageID #: 148
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`CCF_000055.pdf
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`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 8 of 20 PageID #: 149
`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.
`
`IMG_1747.JPG
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`
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`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 9 of 20 PageID #: 150
`U.S. Patent No. 7,067,944: Claim 3
`"3. A motor comprising:"
`
`IMG_1740.JPG
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`
`
`a) a core having poles and
`windings around said poles
`forming a pole assembly;
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 10 of 20 PageID #: 151
`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_1840.JPG
`
`
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`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 11 of 20 PageID #: 152
`U.S. Patent No. 7,067,944: Claim 3
`"a) a core having poles and windings around said poles forming a pole assembly;"
`
`IMG_1884.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 12 of 20 PageID #: 153
`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_1884.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 13 of 20 PageID #: 154
`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_1783.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 14 of 20 PageID #: 155
`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_1884.JPG
`
`
`
`c) a thermoplastic material
`secured to the shaft and
`substantially encapsulating
`the pole assembly
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 15 of 20 PageID #: 156
`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 + I – GF 30” as shown below:
`
`IMG_1711.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 16 of 20 PageID #: 157
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`IMG_1705.JPG
`
`Upon information and belief, the label “PPS + I – GF 30” refers to a blend of polyphenylene sulfide and an imide compound
`with 30% glass fiber filler, with a greater proportion of polyphenylene sulfide than of the imide compound as indicated by
`the order “PPS + I” rather than “I + PPS.” Upon information and belief, imide compounds may be thermoplastic or
`thermoset compounds and polyphenylene sulfide is a thermoplastic compound.
`
`The portion of the body composed of polyphenylene sulfide with 30% glass fiber filler, often identified with the label “PPS –
`GF 30” is a known thermoplastic. 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”).
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 17 of 20 PageID #: 158
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`http://www.matweb.com/search/DataSheet.aspx?MatGUID=c43bc743bdc0413ead2b87aca2e38a30&ckck=1
`
`PPS-GF30 is used in injection molding processes to manufacture parts.
`
`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:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 18 of 20 PageID #: 159
`U.S. Patent No. 7,067,944: Claim 3
`"c) a thermoplastic material secured to the shaft and substantially encapsulating the pole assembly,"
`
`IMG_1884.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 19 of 20 PageID #: 160
`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_1884.JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-6 Filed 03/20/17 Page 20 of 20 PageID #: 161
`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:
`
`IMG_1783.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.
`
`