UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`Filed:
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`May 12, 1999
`
`Issued:
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`November 27, 2001
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`Inventor: C. Kumar N. Patel
`
`Assignee: Cruise Control Technologies LLC
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`Title:
`
`CRUISE CONTROL INDICATOR
`
`____________
`
`DECLARATION OF DANIEL A. CRAWFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 6,324,463 UNDER 37 C.F.R. § 42.100
`
`I, Daniel A. Crawford, hereby declare, affirm and state the following:
`
`Introduction
`1.
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`I am over the age of eighteen and otherwise competent to make this
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`
`
`
`
`I.
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`declaration.
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`2.
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`The facts set forth below are known to me personally, and I have
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`firsthand knowledge of them.
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`
`
`1
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`Filed:
`
`May 12, 1999
`
`Issued:
`
`November 27, 2001
`
`Inventor: C. Kumar N. Patel
`
`Assignee: Cruise Control Technologies LLC
`
`Title:
`
`CRUISE CONTROL INDICATOR
`
`____________
`
`DECLARATION OF DANIEL A. CRAWFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 6,324,463 UNDER 37 C.F.R. § 42.100
`
`I, Daniel A. Crawford, hereby declare, affirm and state the following:
`
`Introduction
`1.
`
`I am over the age of eighteen and otherwise competent to make this
`
`
`
`
`
`I.
`
`declaration.
`
`2.
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`The facts set forth below are known to me personally, and I have
`
`firsthand knowledge of them.
`
`
`
`1
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`3.
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`I make this Declaration in support of the above-captioned petition for
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`Inter Partes Review (“IPR”) of U.S. Patent No. 6,324,463 ( “the ’463 patent”).
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`The ’463 patent resulted from U.S. Provisional Application No. 60/085,185, filed
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`on May 12, 1998, naming C. Kumar N. Patel as the inventor. The '463 patent
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`issued on November, 27, 2001. I further understand that the ‘463 patent is
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`currently assigned to Cruise Control Technologies LLC (“the patentee”).
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`4.
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`I have been retained by Latham & Watkins LLP on behalf of Ford
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`Motor Company, Jaguar Land Rover North America LLC, and Volvo Cars of
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`North America LLC.
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`5.
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`I have been asked to provide my technical review, analysis, insights,
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`and opinions regarding the above-noted references that form the basis for the
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`grounds of rejection set forth in the Petition for Inter Partes Review of the ’463
`
`Patent (“Petition”).
`
`II. Qualifications and Compensation
`6.
`I received my B.E.E. in Electrical Engineering from the General
`
`Motors Institute in 1975 and my M.S.E.E. (Electrical Engineering) with a focus on
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`control systems from the University of Colorado in 1974.
`
`7.
`
`Since 1975, I have acquired extensive experience in electronic and
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`mechanical product design (and validation, implementation), microcontroller-
`
`
`
`2
`
`Ford Motor Company et al.
`Ex. 1011
`
`
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`based instrument design, component testing electromechanical products, computer
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`simulations of engine management systems, and system design. I gained this
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`experience through working in the automotive industry in various roles, including
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`as a Product Engineer and Manager.
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`8.
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`Since 1979, I have acquired extensive experience in automotive
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`displays and cruise control systems, specifically in the areas of: system design,
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`electronic product design, electronic throttle control and components, fuel pump
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`controllers. In particular, while I worked at Delphi Automotive I developed and
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`tested cruise control systems and components, including the Cruisemaster, Custom
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`Cruise, Custom Cruise III, and Stepper Motor Cruise Control systems. Over 100
`
`million of these cruise control systems were sold and they were incorporated into
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`General Motors, Honda, SAAB, OPEL, and Kia vehicles.
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`9.
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`I have been awarded 12 U.S. Patents relating to electronics, and
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`mechanical and pneumatic systems. Four of them specifically relate to cruise
`
`control: US 4,380,418; US 5,680,024; US 6,278,931; and US 6,384,640. I have
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`also authored five publications concerning cruise control.
`
`10.
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`I have been awarded two Boss Kettering Awards for my work with
`
`the Stepper Motor Cruise Control systems and Electronic Throttle Control. The
`
`
`
`3
`
`Ford Motor Company et al.
`Ex. 1011
`
`
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`Boss Kettering Award is General Motors’ highest internal recognition for technical
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`innovation.
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`11. A more fulsome list of my experience and credentials is included in
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`the copy of my CV included at the end of this Declaration.
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`12.
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`I am being compensated at my standard rate of $325 per hour for my
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`work in connection with this matter. My compensation in this matter is not
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`dependent in any way on the contents of this Declaration, the substance of any
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`further opinions or testimony that I may provide, or the ultimate outcome of this
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`matter.
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`III. Materials Considered
`13.
`I have carefully reviewed the ’463 Patent and its file history and
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`considered each of the documents cited herein, in light of general knowledge in the
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`art. In formulating my opinions, I have relied upon my experience in the relevant
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`art. In formulating my opinions, I have also considered the viewpoint of a person
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`of ordinary skill in the art (i.e. a person who would have had a Bachelor’s degree
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`in engineering or equivalent coursework and at least two years of experience in the
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`automotive control systems and user interfaces for vehicles) as of May 12, 1998.
`
`14. Below is a list of documents I have considered in formulating my
`
`opinion:
`
`
`
`4
`
`Ford Motor Company et al.
`Ex. 1011
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`
`
`Ford
`Exhibit
`No.
`1001
`
`Document
`
`U.S. Patent No. 6,324,463 (“the ’463 Patent”)
`
`1002
`1004
`
`1006
`1007
`
`File History for the ’463 Patent
`Certified English Translation of Japanese Patent Publication No.
`S60-174329 by Narita et al. (“Narita”).
`U.S. Patent No. 5,381,388 by Beiswenger et al. (“Beiswenger”).
`U.S. Department of Transportation, National Highway Traffic
`Safety Administration 1989 Report, “An Examination of Sudden
`Acceleration” by Pollard et al. (“NHTSA 1989 Report”)
`Certified English Translation of Japanese Published Utility
`Application No. H4-102059 to Nagashima et al. (“Nagashima”)
`IV. Description of the Relevant Field and the Relevant Timeframe
`15. Based upon my review of these materials, I believe that the relevant
`
`1009
`
`field for purposes of the ’463 Patent is basic user interface systems in vehicles and,
`
`specifically, user interface systems that relay information related to cruise control
`
`systems.
`
`16.
`
`I have been informed that relevant time period of the alleged
`
`invention is on or before May 12, 1998. Well before May 12, 1998, the cruise
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`control systems of the type described in the ’463 Patent were known. Moreover,
`
`many aspects of which the ’463 Patent acknowledges in the BACKGROUND OF
`
`THE INVENTION section. I agree with the statement in the BACKGROUND OF
`
`THE INVENTION section that the features discussed were known in the prior art.
`
`
`
`5
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`Ford Motor Company et al.
`Ex. 1011
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`
`
`17. The majority of the claim limitations in the ’463 Patent are drawn to
`
`admittedly prior art concepts. In my opinion, the remaining claim limitations are
`
`drawn to specific variations of user interface systems that were known.
`
`V. Description of the Relevant Industry
`18. From long before May 12, 1998 —and to this day—the automotive
`
`industry has been a large (both in terms of number of competitors and their market
`
`caps), highly sophisticated, competitive, and international in scope. As a result,
`
`research and development was well-funded, and design and engineering of all
`
`aspects of vehicles were highly sophisticated and comprised of cutting edge
`
`technology. Design choices for systems associated with vehicles were plentiful
`
`and well scrutinized, and each was well understood as a variant that could be used
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`interchangeably with slight modifications as necessary in various automotive
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`systems; this included user interfaces and their use with cruise control systems.
`
`VI. Level of Ordinary Skill in the Art
`19. As discussed above, in my opinion, based upon a review of the prior
`
`art, ’463 Patent, and prosecution history of the ’463 Patent that a person of
`
`ordinary skill in the art at issue here would have been someone with a bachelor’s
`
`degree in engineering or equivalent coursework and at least two years of
`
`experience in automotive control systems and user interfaces for vehicles. I have
`
`
`
`6
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`an understanding of the capabilities of a person of ordinary skill in the relevant
`
`field. I have supervised and directed many such persons over the course of my
`
`career. Further, I had the capabilities of at least a person of ordinary skill in the art
`
`at the relevant time.
`
`VII. The ’463 Patent
`20. The ’463 patent contains a section entitled “Background of the
`
`Invention,” which describes the state of the art prior to the purported invention
`
`(“Admitted Prior Art”). Aspects of the Admitted Prior Art systems include:
`
`i.
`
`a cruise control system for a vehicle having a human operator
`
`(Ex. 1001, ’463 patent at 1:13-14);
`
`ii.
`
`a speed controller that automatically maintains the vehicle at a
`
`preset speed (id. at 1:15-16);
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`iii.
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`an enable switch associated with the controller for enabling the
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`system (id. at 1:18-21);
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`iv.
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`a set speed input in communication with the controller for
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`manually setting the preset speed (id. at 1:23-25);
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`v.
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`a memory that stores the preset speed (id. at 1:26-28); and
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`vi.
`
`a visual feedback indicating whether the cruise control system
`
`is enabled (id. at 1:63-64).
`
`7
`
`
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`The Background section also describes Admitted Prior Art methods of using the
`
`cruise control systems as including:
`
`vii.
`
`setting the cruise control speed at a desired cruise speed (id. at
`
`1:19-25);
`
`viii.
`
`braking the vehicle to discontinue the maintenance of the preset
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`speed while maintaining preset speed in memory (id. at 1:27-
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`32); and
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`ix.
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`accelerating the vehicle above the preset speed while
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`maintaining the preset speed in memory (id. at 1:32-34).
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`21.
`
`In my role as a design engineer/product manager of cruise control
`
`systems for over 20 years since 1978, I have personal knowledge that the above
`
`aspects of the Admitted Prior Art (numbered i. to ix.) were commonly known and
`
`used in the cruise control industry before 1998. Therefore, I agree with that
`
`portion of the ’463 patents description of the state of the prior art.
`
`22.
`
`In my opinion, prior art references disclose the exact same methods
`
`and systems claimed in the ‘463 patent, including Japanese Patent Pub. No. S60-
`
`174329 by Narita et al. (“Narita”) and Japanese Published Application No. H4-
`
`102059 to Nagashima et al. (“Nagashima”).
`
`
`
`8
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`23. Additionally, prior art references help show that various claims and/or
`
`claim elements would have been obvious to a person of ordinary skill in the art.
`
`These include U.S. Patent No. 5,381,388 by Beiswenger et al. (“Beiswenger”) and
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`U.S. Department of Transportation, National Highway Traffic Safety
`
`Administration 1989 Report, “An Examination of Sudden Acceleration” by
`
`Pollard et al. (“NHTSA 1989 Report”).
`
`24.
`
`I have reviewed the inter partes review petition that my declaration
`
`supports in detail and agree with its statements, positions, and arguments.
`
`VIII. Grounds of Invalidity
`Ground 1: Claims 1-5, 12-16, 18-19, 21, 25-28 and 34-36 are anticipated
`
`by Japanese Patent Publication No. S60-174329 by Narita
`
`25. Narita discloses the use of digital displays that show not only the
`
`actual speed of a vehicle, but also the set speed that is stored in the controller’s
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`memory. Narita at pg. 3 (“the stored vehicle speed is indicated on the stored
`
`vehicle speed indicator portion in the driver side meter.”). This is shown in
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`Figures 6 and 4 of Narita.
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`
`
`9
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`
`
`Ford Motor Company et al.
`Ex. 1011
`
`
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`26. Like the Admitted Prior Art, Narita also discloses all basic cruise
`
`control functionalities and components. Figure 1 in Narita discloses controller 7
`
`that “operates as the automatic speed controlling device.”
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`27. One of ordinary skill in the art would have understood Narita to
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`disclose a “main switch” that turns controller 7 on or off, i.e. enable it or disable it.
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`Id. at pg. 3 (“first the operation of the vehicle speed automatic control device
`
`begins with turning on the main switch.”); see also id. at Figure 3; id. at 5 (“FIG. 5
`
`is a diagram illustrating display changes in the speedometer 35 according to
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`operation of the command to switch after turning on power ....”).
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`28. One of ordinary skill in the art would have understood that an ignition
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`switch is inherent to any vehicle. One of ordinary skill in the art would further
`
`have understood that such an ignition switch would operate to turn Narita
`
`controller 7 on and off.
`
`29. After a driver has enabled controller 7 the driver is then able to
`
`engage Narita’s cruise control system by pressing set switch 2 (see above, Figure
`
`1) to set a cruise control speed. Id. at pg. 2.
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`30. One of ordinary skill in the art would have understood that the set
`
`speed is stored in memory by microcomputer 9 inside the controller. Id. at pg. 2
`
`
`
`10
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`(“A vehicle speed storage part that stores the vehicle speed when the set switch 2 is
`
`operated is embedded in the microcomputer 9.”).
`
`31. Narita also discloses how feedback (through displays units 36 and 37,
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`and cruise lamp 17) is provided through various states of operation, which are
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`diagramed in Figures 3, 4, 5, 6, and 7.
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`32. A person of ordinary skill in the art would have understood the “set
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`indicator in meter” symbols in Figures 5, 6, and 7 to represent cruise lamp 17.
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`Such cruise lamps were common in the prior art and a person of ordinary skill in
`
`the art would have understood such a lamp to indicate whether the cruise control
`
`system was controlling the speed of the vehicle.
`
`33.
`
`In reading Narita, one of ordinary skill in the art would have reviewed
`
`Figures 5, 6, and 7 and understood that dashes were shown in display unit 37, and
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`would have understood that the dashes indicate the state of the controller. When
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`the dash is shown after the controller is initially turned on, enabled or activated,
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`one of ordinary skill in the art would have understood the dash to be a
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`predetermined signal from the controller to indicate the state of the controller, i.e.
`
`the cruise control speed is not set. Dashes in digital displays were well known to
`
`persons of ordinary skill in the art to mean an unset status or null value, and the use
`
`
`
`11
`
`Ford Motor Company et al.
`Ex. 1011
`
`
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`of such dashes was commonplace, found in items such as digital clocks and remote
`
`controllers.
`
`Ground 2: Claims 17, 20, 22-24 and 27 Would Have Been Obvious
`
`Over Narita
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`34. A person of ordinary skill in the art would have found the use of
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`blinking, for an indicator or a numerical digital display such as Narita’s display
`
`unit 37, to highlight a different or particular status of a system to be obvious
`
`because such use was long known in the prior art and continuing it would be
`
`intuitive and familiar for drivers. One example of blinking indicators long known
`
`in the art of motor vehicles are turn signals indicators that are found on the
`
`instrument cluster or dashboard of cars. It was common and well known for turn
`
`signal indicators to blink to indicate and remind the driver of the status of the car’s
`
`turning lights, i.e. whether or not they are currently signaling a turn.
`
`35. Another example of blinking indicators long known in the art of
`
`motor vehicles are hazard light indicators that are also found on the instrument
`
`cluster or dashboard of cars. It was common and well known for hazard light
`
`indicators to blink to indicate and remind the driver of the status of the car’s lights,
`
`i.e. whether they are currently flashing, signaling to other drivers a potential hazard
`
`condition.
`
`
`
`12
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`36. Another example of blinking indicators long known in the art of
`
`motor vehicles are traction control indicators. It was common and well known for
`
`traction control indicators to blink to indicate to the driver the status of the traction
`
`control system, e.g. that the traction control system is engaged.
`
`37. Another example of blinking indicators long known in the art of
`
`motor vehicles are anti-lock braking indicators. It was common and well known
`
`for anti-lock braking indicators to blink to indicate to the driver the status of the
`
`anti-lock braking system, e.g. that the anti-lock braking system is engaged.
`
`38. Another example of blinking indicators long known in the art of
`
`motor vehicles are digital clock displays. It was common and well known for
`
`digital clocks to be installed in vehicles and have displays that blink to indicate a
`
`status of the digital clock, e.g. that the time has not yet been set.
`
`39. Another example of blinking indicators long known in the art of
`
`motor vehicles are digital displays for vehicle audio systems. It was common and
`
`well known for digital displays for vehicle audio systems to blink to indicate a
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`status of the audio system, e.g. that the radio is scanning across different radio
`
`stations.
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`40. A person of ordinary skill in the art would have found the use of the
`
`particular number “0” (including the use of a blinking “0”), for an indicator or a
`
`
`
`13
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`numerical digital display such as Narita’s display unit 37, to indicate the unset
`
`status of a system to be obvious because such use was long known in the prior art
`
`and continuing it would be intuitive and familiar for drivers. One example of such
`
`use of “0” long known in the art of motor vehicles is found in digital clock
`
`displays. Digital clocks, including ones installed in vehicles, had displays that
`
`show or blink “0s” to indicate the unset status of the digital clock, i.e. that no time
`
`has been set. Further, the use of “0” to show a null value was commonly used in
`
`mathematics and in common practice for at least decades, and one of ordinary skill
`
`in the art would have found it obvious to apply the use of “0” in the automotive
`
`arts, including in Narita’s display unit 37 to show an unset speed.
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`Ground 3: Claims 17, 20 22-24 and 27 Would Have Been Obvious Over
`
`Narita In View Of Beiswenger
`
`41. As discussed above, the use of a “0” or blinking indicators such as a
`
`blinking “0” was long known in the art of motor vehicles, and one example is
`
`digital clock displays. It was common and well known for digital clocks to be
`
`installed in vehicles and have displays that blink and/or show zeros to indicate a
`
`status of the digital clock, e.g. that the time has not yet been set. This is reflected
`
`in U.S. Patent No. 5,381,388 to Beiswenger et al. (“Beiswenger”), which issued on
`
`January 10, 1995. Beiswenger discloses a digital clock that may be installed in an
`
`
`
`14
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`automobile. Beiswenger’s clock indicates an unset state by showing blinking
`
`numerals, preferably blinking zeros. Beiswenger at 1:40 (“By this invention, a
`
`digital clock is provided…”); id at 5:14-17 (“To set the time on the energized
`
`device, the numerals 26 initially blink and display preferably 0:00. The user can
`
`then point to the displayed command box area 60 entitled ‘SET’.”); id. at 1:5-7
`
`(“Electronic digital clocks have become extremely common, being found as …
`
`clocks for automobiles…”).
`
`42. Narita discloses the use of numbers and also a dash symbol in display
`
`unit 37 to indicate different information and status of the cruise control system,
`
`such as set speed and the unset status of the system. In my opinion, for a person of
`
`ordinary skill in the art, it would have been obvious for display unit 37 to blink or
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`show “0” as disclosed in Beiswenger in order to indicate a particular state or a
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`changed state in Narita’s cruise control system. As discussed previously, the use
`
`of blinking to highlight a particular or changed state was well known to a person of
`
`ordinary skill in the art. And the use of a zero to highlight a particular state, e.g. an
`
`unset state, was also well known to a person of ordinary skill in the art. Because
`
`the use of blinking and zeros was long known and common in the prior art, a
`
`person of ordinary skill in the art would have been motived to continue such use
`
`because it would have been intuitive and familiar for drivers.
`
`
`
`15
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`Ford Motor Company et al.
`Ex. 1011
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`
`
`Ground 4: Claims 1-5, 12, 15, 34 Would Have Been Obvious Over
`
`Narita In View Of The Admitted Prior Art
`
`43. As discussed above, the Admitted Prior Art was commonly known
`
`and used in the cruise control industry before 1998. In particular, as admitted in
`
`the ‘463 patent, cruise control systems conventionally required a driver to press an
`
`enable switch to turn on the system before the driver could select a set cruising
`
`speed. See ’463 patent at 1:17-21.
`
`44. To the extent that it is determined that Narita does not disclose an
`
`enable switch for turning on and off Narita’s cruise control system, a person of
`
`ordinary skill in the art would have found it obvious to include an enable switch, as
`
`described in the Admitted Prior Art, for at least two reasons: first, it was
`
`conventional for cruise control systems to have an enable switch, and drivers were
`
`familiar with such a switch and would expect inclusion of this switch; and second,
`
`an enable switch provides an important safety function. To elaborate on the safety
`
`function, an enable switch means that a driver must press two separate switches –
`
`first the enable switch and then the set switch – before cruise control is engaged.
`
`This lowers the likelihood of an inadvertent engagement of the cruise control
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`system.
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`
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`16
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`Ford Motor Company et al.
`Ex. 1011
`
`
`
`Ground 5: Claims 1-5, 12, 15, 34 Would Have Been Obvious Over
`
`Narita In View Of The NHTSA 1989 Report
`
`45. As discussed above, a person of ordinary skill in the art would have
`
`known that cruise control systems conventionally had an enable switch to turn the
`
`cruise control system on and off. This is also described in the U.S. Department of
`
`Transportation, National Highway Traffic Safety Administration 1989 Report, “An
`
`Examination of Sudden Acceleration” (“NHTSA 1989 Report”), which was
`
`published in January 1989 and calls the enable switch a “master switch” or an
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`“operating switch.” See Ex. 1007, p.8 (disclosing a “cruise control master
`
`switch”); Ex. 1007, Appendix H at 4-1 (“The power to the cruise control system is
`
`supplied through the neutral safety switch and the operating switch.… If either the
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`neutral safety or operating switch is off, there is no power to the control unit.”);
`
`Ex. 1007, Appendix H at Figure 4-3 (showing the “Operating Switch”).
`
`46. To the extent that it is determined that Narita does not disclose an
`
`enable switch for turning on and off Narita’s cruise control system, a person of
`
`ordinary skill in the art would have found it obvious to include the enable switch
`
`(“master switch” or “operating switch”) from the NHTSA 1989 Report. The
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`NHTSA 1989 Report itself explains why one of ordinary skill in the art would
`
`have found this obvious – it is the safety benefit that two components would need
`
`
`
`17
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`Ford Motor Company et al.
`Ex. 1011
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`
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`to fail before inadvertent engagement could occur. (Ex. 1007, pgs. 8-9 (“In
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`virtually all … cruise controls, where digital circuitry is now the norm, two or
`
`more component failures are required to cause an unintended throttle opening.”).
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`A person of ordinary skill in the art would have known of this safety benefit, and
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`other reasons to include an enable switch, as described in ¶ 44, above.
`
`Grounds 6 and 7: claims 18-19, 26 and 29-31 are anticipated by
`
`Japanese Published Utility Application No. H4-102059 to Nagashima
`
`and Claims 17, 20, 23-24 and 27 Would Have Been Obvious Over Narita
`
`In View Of Nagashima
`
`47. As discussed above, the use of blinking indicators or blinking
`
`numbers was long known in the art of motor vehicles to indicate a state of a
`
`system. This is reflected in Japanese Published Utility Application No. H4-102059
`
`to Nagashima et al. (“Nagashima”) (Exhibits 1008 - 1010), which was published
`
`September 3, 1992. Nagashima discloses in Figure 1, a persistent speed indicator
`
`integrated into an analog speedometer.
`
`48. Nagashima discloses a first visual display in conventional analog
`
`speed indicator 11b, which indicates the actual speed of the vehicle. Nagashima at
`
`7, Fig. 1. A second visual display is provided by plurality of indicator lights 31,
`
`which are “arranged in dots respectively at 5 km speed per hour increments.” Id. at
`
`
`
`18
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`8. When the driver presses the set switch, the speed is calculated and stored.
`
`Nagashima at 8, 9. Further, the set speed is indicated to the driver by illuminating
`
`an indicator 31 corresponding to the set speed on the speedometer dial. Id.
`
`49. Nagashima discloses the use of blinking to indicate a state of a cruise
`
`control system. Nagashima discloses that indicators 31 are normally solidly
`
`illuminated when the cruise control system is operating to maintain the vehicle at
`
`the set speed, but that upon braking, indicators 31 blink to show that the system is
`
`no longer maintaining the vehicle at the set speed. See, e.g., id. at ¶ 24 (“in the case
`
`brake SW 9 is in ON mode … the cruise control is temporally released, and
`
`indicators (31) blink.”); id. at ¶ 29 (“… Moreover, in the case the cruise control is
`
`temporarily released by deceleration of more than the set amount by brake
`
`operation, etc., the difference large or small is determined between the actual speed
`
`and the display of the setting speed by the blinking of indicators (31) of setting
`
`speed display readout 3, and when the difference is large, the cruise control can be
`
`performed by ON operation of resume SW 20 after approximating both speeds,
`
`which improves safety.”).
`
`50. Narita discloses the use of numbers and also a dash symbol in display
`
`unit 37 to indicate different information and status of the cruise control system,
`
`such as set speed and the unset status of the system. For a person of ordinary skill
`
`
`
`19
`
`Ford Motor Company et al.
`Ex. 1011
`
`
`
`in the art, it would have been obvious for display unit 37 to blink as the indicators
`
`31 in Nagashima blink. Nagashima’s indicators 31 show the set speed and blink to
`
`draw attention to the driver of a changed state in the cruise control system, i.e. that
`
`the system is no longer maintaining the vehicle at the set speed. Narita’s display
`
`unit 37 is similar in that it also shows the set speed so it would have been obvious
`
`to also have display unit 37 blink to draw attention to a driver of a changed state in
`
`Narita’s cruise control system. Further, the use of blinking as described in
`
`Nagashima was long known and common in the prior art, and a person of ordinary
`
`skill in the art would have been motived to use such blinking in Narita’s display
`
`unit 37 because it would have been intuitive and familiar for drivers to indicate a
`
`changed or particular state.
`
`IX. Conclusion.
`51.
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`
`
`20
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`Ford Motor Company et al.
`Ex. 1011
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`
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`12/19/2013 19:22
`
`810-715-1723
`
`STAPLES BURTON , ~1I
`
`PAGE 02/02
`
`Executed on December 19, 2013 in f5tAl<-f?IJ , Michigan .
`
`. :??~La_ c~~
`
`Daniel A Crawford
`
`21
`
`Ford Motor Company et al.
`Ex. 1011-021
`
`
`
`CURRICULUM VITAE
`
`DANIEL A. CRAWFORD
`
`
`
`EDUCATION
`• Southwestern High School, Flint, MI (1969, top 1%)
`• General Motors Institute (BEE. 1973, Co-op program at AC Spark Plug; Top 10%,
`Graduate School Fellowship)
`• University of Colorado (M.S.-E.E. 1974; Control Systems)
`• Continuing Education courses in Modern Control Theory and Electromagnetic
`Compatibility
`
`WORK EXPERIENCE (AC Spark Plug/AC Rochester/AC Delco Systems/Delphi)
`• 1975-1976 – Engineering Test Lab (Test Engineer)
`̵ Test instrumentation design and build
`̵ Component testing (electromechanical products)
`functional (performance and safety)
`̵
`̵
`environmental (temperature, vibration, electromagnetic compatibility)
`̵
`durability
`• 1977-1978 – Advanced Development Engineering (Project Engineer)
`̵ Engine Management System Computer Simulation
`̵ Microcontroller-based Instrument Design (Gages)
`• 1979-1994 – Control Systems Engineering (Project Engineer, Sr. Project Engineer,
`Development Engineer; Engineering Manager)
`
`̵
`
`System design, electronic and mechanical product design, validation,
`implementation and application
`̵ Cruisemaster, Custom Cruise III and Stepper Motor Cruise Control Systems and
`Electronic Throttle Control systems and components
`• 1995 – present; Engineering Manager of Electronic Center of Technology
`System design, electronic product design, validation and implementation
`̵
`̵ Cruise control, electronic throttle control, fuel pump controllers, and
`miscellaneous other electronic products
`
`
`
`
`
`
`
`1
`
`Ford Motor Company et al.
`Ex. 1011-022
`
`
`
`
`
`AWARDS / ACCOMPLISHMENTS
`• 12 U.S. Patents (Electrical/electronics, mechanical, pneumatic, system)
`• 10 Defensive Publications
`• 1 Trade Secret
`• 2 Boss Kettering Awards (Stepper Motor Cruise Control, Electronic Throttle Control;
`prestigious award for outstanding innovation)
`• Numerous suggestion awards (improved engineering and manufacturing methods,
`building safety, etc.)
`
`CRUISE CONTROL HISTORY / BACKGROUND
`• Delphi has been manufacturing cruise controls since 1963.
`̵ Electro-Cruise (relay controller, brush motor actuator)
`̵ Cruisemaster (electromechanical controller, pneumatic actuator)
`̵ Customer Cruise (electronic controller, pneumatic actuator)
`̵ Customer Cruise III (electronic controller, low vacuum pneumatic actuator)
`Stepper Motor Cruise Control (electronic controller, brushless motor actuator)
`̵
`̵ Electronic Throttle Control cruise (electronic controller, motorized throttle body)
`• Delphi currently manufactures approximately 3 million cruise controls per year.
`• Delphi’s customer base includes General Motors North America, Holdens, OPEL,
`SAAB, Harley-Davidson, Honda, BMW motorcycle and Kia.
`• Delphi has manufactured over 100 million cruise control systems since 1963.
`
`
`
`2
`
`Ford Motor Company et al.
`Ex. 1011-023
`
`
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