`TOYOTA MOTOR CORP.,
`Petitioner,
`
`
`v.
`
`
`LEROY G. HAGENBUCH,
`Patent Owner.
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`
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`
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`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`
`
`Case IPR2013-00638
`Patent 8,014,917
`
`Administrative Patent Judges
`JAMESON LEE, MICHAEL W. KIM and ADAM V. FLOYD
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`
`
`
`
`
`
`DECLARATION OF MICHAEL NRANIAN
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`
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`1.
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`I, Michael Nranian, make this declaration in connection with a Decision
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`instituting Inter Partes Review of U.S. Patent No. 8,014,917 in Case IPR2013-00638.
`2.
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`All statements herein made of my own knowledge are true, and all statements
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`herein made based on information and belief are believed to be true. I am over 21
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`years of age and otherwise competent to make this declaration.
`3.
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`Although I am being compensated for time in preparing this declaration, the
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`opinions herein are my own, and I have no stake in the outcome of this inter partes
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`review proceeding.
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`1
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`OWNER Ex. 2060 p. 1
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`4.
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`I have been asked to review evidence and other submissions presented by the
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`Petitioner in these inter partes review proceedings, and provide my opinions and
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`observations on factual issues. I have also reviewed materials specifically referenced
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`below.
`5.
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`Although I have a law degree, I have not been asked to opine on any legal
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`issues.
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`Background and Qualifications
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`A copy of my curriculum vitae is attached hereto.
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`Among my degrees, I possess a Bachelor of Science in Electrical and Computer
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`6.
`7.
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`Engineering, a Master of Science in Electrical Engineering, and a Bachelor of Science
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`in Chemical Engineering. I also am a licensed Professional Engineer, Certified
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`Project Management Professional, as well as a Lean Six Sigma Black Belt certified
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`through the American Society for Quality and the International Quality Federation.
`8.
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`I currently work as a contractor for the U.S. Army, for the Chief Scientist’s
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`Office, in the Tank and Automotive Research, Development and Engineering Center
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`(TARDEC) in Warren, Michigan.
`9.
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`Prior to my employment with the Army, I worked as a design engineer and
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`engineering manager in the automotive industry from 1985 to 2007. This includes
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`experience at Ford, General Motors and Allied Signal. I worked at Allied Signal from
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`1992 to 1993, General Motors from 1993 to 1995, and Ford Motor Company from
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`1985 to 1992, and from 1995 to 2007.
`10. While at Allied Signal and General Motors I worked as a Senior Project
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`Engineer, where my work included the design and development of automotive vehicle
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`2
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`OWNER Ex. 2060 p. 2
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`
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`electrical systems and architectures, electrical and data communication protocols,
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`vehicle system diagnostics and fault codes, warnings, safety and airbag system sensing
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`and electrical systems, sensor algorithm development, sensor fusion technologies and
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`assessments, supplemental
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`inflatable restraints, sensing and airbag strategy,
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`seatbelt/restraint systems and components, pretensioners, vision systems, airbag
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`modules, hybrid inflators, airbag suppression systems, occupant and infant/child seat
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`sensing and detection systems, out of position occupant detection, safety component
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`and system diagnostics, occupant ergonomic evaluations, user and occupant audio and
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`visual
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`interfaces and displays, vehicle crashworthiness, vehicular structural
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`modifications, occupant
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`injury mitigation, crash and
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`rollover protection,
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`electromechanical/transducer and accelerometer based sensing systems, infrared,
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`vision, camera, sonar, acoustic, radar sensing/detection technologies and systems. I
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`conducted numerous system and component evaluations, laboratory tests, supplier
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`and technology assessments, quality and reliability evaluations, as well as barrier and
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`sled tests, and developed design validation plans and reports and failure modes and
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`effects analyses to design and develop automotive safety systems, including those
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`involving crash pulse storage and/or diagnostics retrieval from vehicle modules,
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`systems parameter information retrieval from vehicle modules, and those for
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`supplemental inflatable restraints, sensing and electrical systems, sensor algorithm
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`development, sensor fusion technologies and assessments, sensing and airbag strategy,
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`seatbelt/restraint systems and components, warning systems, electrical interface
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`architectures, and automotive electrical system communication protocols, and safety
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`systems for occupant protection and injury mitigation. My responsibilities also
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`3
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`OWNER Ex. 2060 p. 3
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`
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`included ensuring compliance with Federal Motor Vehicle Safety Standards, ECE
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`regulations, Industry Standards, Corporate Standards, and Due-Care Requirements.
`11. While at Ford, my experience included working as a Product Design Engineer,
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`a Technical Specialist, a Design Analysis Engineer, and an Engineering Manager. My
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`work included the design and development of automotive vehicle electrical systems
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`and architectures, electrical and data communication protocols, vehicle system
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`diagnostics and fault codes, crash pulse storage and/or diagnostics retrieval system
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`from vehicle modules, systems parameter information retrieval from vehicle modules,
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`supplemental inflatable restraints, sensing and electrical systems, sensor algorithm
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`development, sensor fusion technologies and assessments, sensing and airbag strategy,
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`seatbelt/restraint systems and components, frontal and side impact systems and
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`components, inflatable curtain and side airbag systems, rollover systems, rollover
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`protection and avoidance, vision systems, airbag modules, hybrid inflators, airbag
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`suppression systems, occupant and infant/child seat sensing systems, occupant and
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`out of position occupant sensing and detection, diagnostics of safety components and
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`systems, critical parameter storage and retrieval, warnings, occupant ergonomic
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`evaluations, user and occupant audio and visual interfaces and displays, vehicular
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`compatibility analyses and assessments, seat belt and seating systems, pretensioners
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`and tensioning systems, vehicular structural design and development, storage of fault
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`codes and critical parameter information related to automotive vehicle systems as well
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`as collision parameter and crash pulse storage and retrieval for automotive safety
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`systems and the communication and retrieval of this information. This includes
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`communication of information through automotive vehicle electrical systems and
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`
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`4
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`OWNER Ex. 2060 p. 4
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`
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`architectures, electrical and data communication protocols and interfaces, vehicle
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`electrical networks and network interfaces. My work included the design and
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`development of these systems to meet vehicle crashworthiness and crash performance
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`requirements and occupant injury mitigation. My work also involved systems utilizing
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`infrared, vision, camera, sonar, acoustic, radar sensing, monitoring, and detection
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`technologies and systems, as well as electromechanical/transducer and accelerometer
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`based sensing systems. I conducted numerous system and component evaluations,
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`laboratory tests, supplier and technology assessments, quality and reliability
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`evaluations, as well as barrier and sled tests, and I developed design validation plans
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`and reports and failure modes and effects analyses, corporate standards and
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`specifications, and design guidelines, to design and develop electrical networks, data
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`storage and retrieval, data communication and critical parameter storage, collision
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`parameter storage and retrieval for automotive safety systems for occupant protection
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`and injury mitigation. My responsibilities also included ensuring compliance with
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`Federal Motor Vehicle Safety Standards, ECE regulations, Corporate Standards,
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`Industry Standards, and Due-Care Requirements. I also conducted extensive field
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`event analyses, forensic investigations, vehicle inspections, accident reconstructions,
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`and determined causation and root cause analyses for hundreds of automotive
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`accidents to provide information for improvement of designs for automotive safety
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`systems.
`12.
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`Subsequent to my employment at Ford, I worked as a Systems Engineer for
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`Raytheon and General Dynamics, where I developed defense systems for military
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`vehicles.
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`5
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`OWNER Ex. 2060 p. 5
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`13.
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`In my current position as a contractor for the US Army, I possess an Active
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`Secret Security Clearance. My responsibilities in my current position, as well as my
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`positions with General Dynamics and Raytheon, include working with internal
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`scientists, researchers and technical staff, as well as outside collaborators and
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`universities, to develop technologies, innovation, and inventions for the protection of
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`our soldiers and the enhancement of our soldiers’ survivability in military vehicles.
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`This includes the development and assessment of vehicle and robotic data
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`communication and electrical system architectures, critical parameter diagnostics and
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`storage, camera and vision systems, human interface displays, acoustic, ultrasonic, IR,
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`radar, night vision, and electromagnetic sensing, sensor fusion, algorithm, and pattern
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`recognition development, robotic systems, Improvised Explosive Device (IED)
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`detection and
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`injury mitigation systems, armor and electromagnetic armor
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`development, electromagnetic wave sensing and frequency determination, Command,
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`Control, Communications, Computers, Intelligence, Surveillance and Reconnaissance
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`(C4ISR) systems development, 360 degree surveillance, active and passive safety
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`system development and occupant injury mitigation.
`14. During the course of my career in automotive research, development and
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`testing, I have designed, tested, and developed numerous vehicle electrical and sensing
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`systems, conducted numerous crash and collision tests, and have developed and
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`designed collision parameter and crash pulse storage and critical parameter retrieval
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`systems for vehicle collision safety systems, airbag systems, seatbelt systems, and
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`sensing systems, for use in automobiles. I am thoroughly familiar with the operation
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`and functionality of crash data recording and diagnostic systems and vehicular systems
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`6
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`OWNER Ex. 2060 p. 6
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`critical parameter and information storage and retrieval. This includes those related to
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`crash and impact detection and reaction systems involving accelerometers and
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`electromechanical sensors/transducers and other technologies, as well as occupant
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`safety systems. This includes the testing, design, and development work related to
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`occupant injury causation, and injury mitigation in vehicles, and field analyses of
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`product performance to improve designs and improve system performance. In short,
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`I have years of experience working with event data recorders and specifying the
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`design characteristics they need to possess, including which parameters are to be
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`monitored and recorded.
`15.
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`I have been qualified to testify as an expert in over 20 cases involving
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`automotive safety and electrical systems, and the retrieval of collision parameter
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`information and critical vehicle system parameter information in automotive crash
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`events.
`16.
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`I am a member of the Project Management Institute, American Society for
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`Quality, International Quality Federation, and the Forensic Expert Witness
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`Association.
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`17.
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`In preparing this Declaration, I reviewed the materials specifically identified
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`Materials Considered
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`herein.
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`Overview of the Claimed Inventions
`18. The ‘917 Patent describes a comprehensive system for securely storing and/or
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`transmitting information permitting accident reconstruction, evaluation of driver
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`behavior, analysis of component and system diagnostic information and critical
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`7
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`OWNER Ex. 2060 p. 7
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`vehicle system and component parameters for potential determination of component
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`and system design and/or manufacturing defects, and enhancements to emergency
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`responses to a collision.
`19. The specification of the ‘917 Patent is generally drawn to two types of sensors:
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`“production-related” and “vital signs.”
`20.
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`Production-related sensors generally monitor a vehicle’s performance.
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`“Production performance of the vehicle is generally evaluated in the amount of work
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`done by the vehicle in a unit of time—e.g., miles per hour, tons per hour and the
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`like.” Ex. 1101 at col. 1, ll. 56-59. Examples of production parameters include engine
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`RPM, throttle position, distance travelled, ground speed and brake status. Id. at col. 6,
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`ll. 30-42.
`21.
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`“Vital signs” refer to the “health” of the vehicle, and indicate whether a
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`“component or subassembly is operating in a … ‘critical’ state—i.e., a state that if
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`maintained will cause the component or subassembly to fail.” Ex. 1101, col. 1, ll. 33-
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`44. Examples of vital signs include engine oil temperature, engine oil pressure, and
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`tire pressure. Vital signs sensors also monitor whether the vehicle is involved in a
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`collision. Ex. 1101 at col. 6, ll. 43-65; Figs. 1B and 1C.
`22. Data provided by each type of sensor are acquired by an “electronic processor
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`on-board the vehicle,” while “[a] memory … stores the vital sign and work data
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`acquired by the processor in a format that allows the data to be retrieved from the
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`memory in a manner that correlates the vital sign and work data.” Id. at col. 2, ll. 61 –
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`col. 3, ll. 7.
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`8
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`OWNER Ex. 2060 p. 8
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`23. The specification of the ‘917 Patent further states that, “[w]hen taken as
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`disparate items, tracking either vital signs or production parameters [but not both]
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`gives only a partial picture of a vehicle’s operation.” Id. at col. 2, ll. 11-13. By
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`correlating these two categories of sensor data in a memory, such as data surrounding
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`detection of a collision, more complete analyses of the vehicle’s “state of health” can
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`be achieved. Id. at col. 2, ll. 43-46.
`24. Values of production-related parameters are continuously captured into a
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`memory, wherein the oldest data are overwritten by the newest data. See, e.g., id. at
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`Figs. 5A, 5B, col. 10, line 7 – col. 11, line 30 (listing “production-related parameters
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`exemplify[ing] the type of vehicle parameters that are monitored, temporarily stored in
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`memory and then permanently stored with vital sign data when a failed mode is
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`detected”), col. 11, lines 31-56 (describing data capture and decreasing resolution for
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`older data), col. 12, ll. 54-58 (“As the data ages, the chronology memory 83 retains
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`smaller fractions of the originally sampled data. When the data is approximately 606
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`minutes old (as measured by vehicle operation time), it is no longer stored.”).
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`Therefore, chronological records of the most current critical vehicle parameters are
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`continuously stored in a first memory and overwrite older vehicle information with
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`updated information, and when a failure mode is detected or when a collision event
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`occurs, the chronological records of the latest updated critical parameter information
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`is permanently stored in a second memory. Also, chronological records of the critical
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`vehicle parameter information can continue to be permanently stored in a second
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`even after a collision event or other failure mode occurs. These critical vehicle
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`parameters can later be retrieved for analysis.
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`9
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`OWNER Ex. 2060 p. 9
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`25. The specification notes that the “[t]he production-related parameters that
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`provide useful chronologic[al] information for diagnosing the cause of a failure mode
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`are in three categories—i.e., engine, position and relative speed of the vehicle, and
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`load.” Ex. 1101, col. 9, ll. 57-61. I note that a crash would be considered a failure
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`mode of the vehicle. Further, in regards to the first category of “useful
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`chronologic[al] information,” i.e., “engine,” the specification further identifies “Engine
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`RPM” and “Engine throttle position” as two of three enumerated types engine
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`information to be monitored and stored when a failure mode occurs. Id. at col. 10, ll.
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`1-11.
`26.
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`In the event that the failure mode of the vehicle is a crash, the specification
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`notes that braking “information can be particularly useful in connection with
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`diagnosing a crash condition. For example, if the brakes are applied, what was the
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`vehicle speed on brake application? … Over what distance were the brakes applied,
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`and what was vehicle speed on release or [sic, of] brakes?” Ex. 1101, col. 10, ll. 43-57.
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`Accordingly, the specification teaches the importance of capturing data for a
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`combination of both pre-crash vehicle speed and brake usage, and the skilled artisan
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`would understand the value of collecting such information at least for the purpose of
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`evaluating driver behavior. The skilled artisan also would see that throttle position
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`data could provide similarly useful information, e.g., did the driver open the throttle
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`(as opposed to depressing the brake pedal) during the time preceding a crash of the
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`vehicle?
`27.
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`In further regards to braking data, the specification states that “[t]wo types of
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`sensors can be employed. One is a simply on/off status sensor. The other type of
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`10
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`OWNER Ex. 2060 p. 10
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`sensor senses the degree of braking by sensing the pressure of the fluid in the
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`hydraulic brake lines.” Ex. 1101, col. 10, ll. 43-47. The on/off brake sensor would
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`generally indicate whether or not the driver applied pressure to the service brake. A
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`brake pressure sensor would generally indicate the relative degree to which the driver
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`engaged the brake, at least over a period of time of relatively constant temperature
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`(the temperature issue being discussed further below).
`28. Additionally, in the context of a crash scenario, the specification states that
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`“[t]he status of the operator’s seat belt is also a particularly useful parameter….” Ex.
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`1101, col. 10, ll. 63-67. The safety belt status of an occupant in a vehicle involved in a
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`collision generally will bear on the extent of an injury to the occupant.
`29.
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`In view of the foregoing, the specification focuses in on the types of vehicle
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`production-related parameter data that Mr. Hagenbuch believed to be important (and
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`I agree with Mr. Hagenbuch) to capture and/or monitor in the event of a collision,
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`which parameters include, at least, braking, velocity, throttle position and seat belt
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`status.
`30. The specification further addresses the importance of “continuing to gather
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`data and store data to the memories … so long as the value of the vital sign parameter
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`exceeds a critical value,” and, in the event of a crash event, the specification
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`recognizes that “all data that is collected during a crash event may be useful in
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`diagnosing the cause,” and, thus, “data would continue to be transferred to the
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`memory … until the vehicle cam [sic, came] to a standstill (i.e., the data from the
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`accelerometer … goes to zero).” Ex. 1101, col. 25, ll. 15-30. By continuing to gather
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`11
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`OWNER Ex. 2060 p. 11
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`data during the crash event following detection of a collision, important information
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`relating to, inter alia, the severity of the collision, can be acquired.
`31.
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`In further regards to the memory structures disclosed by the ‘917 Patent, the
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`specification teaches the use of a data compression scheme and a dual memory. As
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`taught by the specification, in one embodiment, “inputs from the sensors for the
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`production-related parameters … are recorded in the RAM 47 that is continually
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`updated. The reading interval for these inputs is a minimum four times a second,
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`with the amount of data then stored to memory diminishing with time from when the
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`reading was taken. In other words, readings taken most recently in the memory 83,
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`and readings taken some time ago are gradually deleted from memory.” Ex. 1101, col.
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`11, ll. 16-23. Put another way, “[a]s the data ages, the chronology memory 83 retains
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`smaller fractions of the originally sampled data.” Id. at col. 12, ll. 47-49.
`32.
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`In regards to the second memory concept, “[v]ehicle default modes which
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`could result in vehicle production work related inputs being recorded to the separate
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`default mode memory [include a] [v]ehicle crash as detected by the on-board
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`accelerometer…. If a crash of the vehicle … is detected then readings [stored in
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`memory 83] are recorded to the memory 85, along with vehicle deceleration
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`measurements in gravity units.” Id. at col. 11, ll. 50-63; accord id. at col. 25, ll. 10-14.
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`To the extent that the terms “capturing” or “recording” (or variants thereof) are used
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`in the claims of the ‘917 Patent, I understand that the Board has construed those
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`terms to be synonymous with one another, and, that both terms “mean ‘to store data
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`into memory.’” Decision at 16. In my opinion, the person having ordinary skill in the
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`art, at the time of the invention, would have understood the terms “capturing” and
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`12
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`OWNER Ex. 2060 p. 12
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`“recording” to have a more specific definition. Generally, any microprocessor that
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`receives data from a sensor will hold that data element in a memory, if only until the
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`next sampling of the sensor, in which case the date element may be immediately
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`overwritten. However, in contrast to this momentary placement of data in memory,
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`the skill artisan would understand that an event data recorder stores data for later use,
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`as opposed to a data sample being placed in memory for mere instantaneous
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`comparison to some reference point and if criteria for data storage are not met,
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`otherwise not preserved for some substantial period of time. A skilled artisan
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`understands that event data recorders deliberately protect data deemed important
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`from being immediately overwritten. While captured data may be eventually
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`overwritten (e.g., as in a circular buffer), the skilled artisan would understand the
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`importance of preserving such data for some period of time such that a “snap shot”
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`of the data may be taken in the event that a collision is detected and the data may be
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`preserved by some means (be it by disabling the overwrite or by transferring the data
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`to a separate memory address that where it will not be overwritten, and, thus,
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`preserved for analysis). Consistent with the foregoing is the “Dictionary of Computer
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`and Internet Words,” which defines “storage” as “[t]he places that hold computer
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`information for subsequent use or retrieval.” Ex. 2063 at 259 (emphasis added).
`33. Claims 4, 9-17, 21, and 26-38 of the ‘917 Patent are at issue in these inter partes
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`review proceedings. Dependent claims 4 and 21 (which depend from independent
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`claims 1 and 18), along with independent claims 9 and 26, and additional claims
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`depending therefrom. All of those claims require monitoring and capturing some
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`combination of vital sign and production-related parameters, including monitoring at
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`13
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`OWNER Ex. 2060 p. 13
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`least the following three types of production-related parameters: ground speed;
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`certain brake data (depending on the claim1); and throttle position. These parameters
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`are important to diagnosing the cause of a collision. Claims 4 and 21 also require
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`monitoring and capturing a “load on the engine.”
`34. With respect to vital signs, independent claims 9 and 26 each require sensors
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`for monitoring vital sign parameters, including a collision of the vehicle. Dependent
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`claims 11 and 28 more narrowly require that the vital sign sensors include an
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`accelerometer. Claims 4 and 21, on the other hand, require “detecting a collision …
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`in response to a sudden change in the velocity of the vehicle.”
`35.
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`In accordance with independent claims 9 and 26, three actions are required by
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`the claimed apparatus in response to detecting a collision: (1) “transferring into the
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`second memory the information captured by the first memory”; (2) “transferring into
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`the second memory … data from one or more of the vital sign parameters after
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`detection of the collision”; and (3) “automatically transmitting a distress signal…..” In
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`further regards to the second memory, dependent claims 10 and 27 require that the
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`second memory be a “permanent memory,” which the Board has construed to mean a
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`“memory that is not overwritten continuously (i.e., non-buffered).” Decision at 18
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`(emphasis original).
`36. Claims 1 and 18 (and thus dependent claims 4 and 21, respectively) both
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`require “monitoring vital sign parameters of the vehicle, including information
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`1 Regarding the brake data, claims 4, 9-17 and 30 each require sensors for monitoring
`“a degree of braking” of the vehicle. Claims 13, 21 and 26-34 each require sensors for
`monitoring brake “on/off status.” Notably, dependent claims 13 and 30 each require
`an apparatus having sensors for monitoring both braking degree and brake on/off
`status. See Ex. 2057 at ¶¶ 40, 41.
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`14
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`OWNER Ex. 2060 p. 14
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`indicative of a change in velocity of the vehicle” and further require “detecting a
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`collision of the vehicle in response to a sudden change in velocity of the vehicle.”
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`Independent claims 9 and 26 require “sensors for monitoring vital signs of the
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`vehicle, where the vital signs include a collision of the vehicle.” Dependent claims 11
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`and 28 more narrowly require that at least one of the vital signs sensors be an
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`accelerometer.
`37.
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`I note that the collection and/or monitoring of pre-collision-detection data
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`required by claims 1, 9, 18 and 26 can have a number of benefits. For example, the
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`pre-collision production-related data may be used for purposes of accident
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`reconstruction, driver behavior, culpability assessment, analysis of component and
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`system diagnostic information and vehicle system and component parameters for
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`evaluation of system and component performance and also for potential
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`determination of component and system design and/or manufacturing defects which
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`may or may not be related to the cause of the accident. Further, data such as pre-
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`collision ground speed and whether the driver engaged the brake may be informative
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`on the issue of driver culpability. Data such as vehicle critical parameters related to
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`component and system diagnostic information can provide information related to
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`design or manufacturing defects and can be used to inform the public and/or recall
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`and repair vehicles that may pose a potential safety risk.
`38. As for data captured after detection of a collision as required by the claims, as
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`noted, the capture of vital sign parameters after detection of a collision, including data
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`related to the change in the velocity of the vehicle, provides a measure of the severity
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`of the collision, and the potential assessment of occupant injury based on collision
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`15
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`OWNER Ex. 2060 p. 15
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`severity. Generally, a collision in which the change in velocity occurs over a shorter
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`time period is more severe than a collision in which the same change in velocity
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`occurs over a longer time period. Similarly, measuring acceleration following
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`detection of a collision will provide an indication of collision severity. And, in
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`general, data which provides the basis for discriminating the occurrence of a collision,
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`if continued to be monitored and captured following detection of a collision, will also
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`provide an indication of the severity of a collision.
`39.
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`In addition, once a vehicle crash is detected, the retention of data related to
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`collision discrimination is generally useful in understanding automotive safety system
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`performance, and provides real world feed-back for assessment of vehicle safety
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`system performance and the potential
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`improvements of current and future
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`automotive safety system designs. While the claims at issue do not expressly require
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`the transmission of data indicating the severity of a collision, in my opinion, the
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`claims inherently enable the benefit that would be obtained by transmitting collision
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`severity information such that first responders and other medical personnel would
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`have a more complete set of information in order to enhance the quality of an
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`emergency response.
`40. Claims 10-17 all depend from claim 9, and I understand that those dependent
`
`claims incorporate all limitations recited by claim 9. For example, claim 13 recites
`
`“[t]he apparatus of claim 9 wherein the sensors for monitoring production-related
`
`parameters includes [sic] a sensor for detecting on/off status of the braking system.”
`
`Accordingly, claim 13 requires, inter alia, sensors for monitoring both “a degree of
`
`braking” (required by claim 9) and “an on/off status of a braking a system.”
`
`
`
`16
`
`OWNER Ex. 2060 p. 16
`
`
`
`41. Claims 27-34 all depend from claim 26. Similar to claim 13, claim 30 requires
`
`sensors for monitoring both “an on/off status of a braking system” and “a degree of
`
`braking of the braking system.”
`
`Level of Ordinary Skill and the Relevant Art
`42. Mr. McNamara appears to contend that the patentability of the inventions
`
`claimed by the ‘917 Patent should be evaluated from the perspective of a person
`
`having ordinary skill in the art of “automotive electronics.” (Ex. 1111 at ¶ 16). In my
`
`opinion, the field of “automotive electronics” is an overly broad characterization of
`
`the field of endeavor of the claimed inventions, such that it is unlikely that a given
`
`person could have “ordinary skill” in every facet of automotive electronics. It is
`
`further my opinion that the field of endeavor of the claimed inventions relates more
`
`specifically to processing vehicle dynamics data and critical important information
`
`pertinent to accident events and taking actions in response to the detection of
`
`circumstances indicating a collision (e.g., storing data for later retrieval and
`
`automatically transmitting information that the vehicle has been involved in a collision
`
`as well as the real-time monitoring of, continuous collection of, and permanent
`
`storage of critical vehicle parameter information relating to the crash event).
`43. The broad field of automotive electronics embraces a wide array of distinct
`
`sub-disciplines and can refer to virtually any electronic component or system of an
`
`automobile, including, but not limited to:
`a.
`
`Engine control units, which, inter alia, include control systems for
`
`air/fuel ratio, ignition timing, idle speed, valve timing (combustion chamber
`
`intake and exhaust), engine cooling system, fuel injection and lubrication;
`
`
`
`17
`
`OWNER Ex. 2060 p. 17
`
`
`
`b.
`c.
`
`Transmission electronics;
`
`Chassis electronics, which include, inter alia, anti-lock braking systems,
`
`traction control systems, brake distribution systems and brake stability control,
`
`rollover prevention and electronic stability control;
`d.
`
`Safety electronics, which include, inter alia, front and side impact sensing,
`
`detection and discrimination, as well as roll-over sensing, detection and
`
`discrimination, air bag, seat belt load variable load limiting, seat belt
`
`pretensioning and tensioning, inflatable curtain deployment systems, occupant
`
`sensing, child and infant seat sensing, and occupant position and occupant out-
`
`of-position sensing systems, emergency brake assist, collision avoidance
`
`systems and automatic collision notification systems;
`e.
`
`Electronic driver assistance systems, which include, inter alia, cruise
`
`control, lane assist, blind spot detection and parking assistance systems;
`f.
`
`Electronic passenger comfort systems, which include, inter alia, climate
`
`control;
`g.
`
`Electronic “infotainment systems,” which include, inter alia, navigation
`
`and multimedia systems;
`h.
`i.
`
`Electronic module diagnostic and parameter recording systems;
`
`Electronic vehicular system architectures and data communication
`
`interfaces;
`j.
`k.
`l.
`
`Safety system algorithm development and strategy;
`
`System diagnostics, fault code detection, and warnings; and
`
`Electronic event data recording systems.
`
`
`
`18
`
`OWNER Ex. 2060 p. 18
`
`
`
`44. The field of automotive electronics is one having within it a fairly broad array
`
`of sub-specializations. For example, a person having ordinary skill in the art of
`
`infotainment systems is not necessarily going to have ordinary skill in the art of safety
`
`system development and design and event data recording systems.
`45.
`
`In my opinion, a person having ordinary skill in the art pertinent to the claimed
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