`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`
`
`
`During the deposition of 30(b)(6) representative David Brink, Mr. Brink stated that a window regulator,
`which is installed in a door, includes rails which provide a travel path along which the window travels.
`Please see Deposition Transcript of David Brink, Page 29, Lines 12-15 and page 66 lines 9-16:
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`8
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 15
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`
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`Bates Number BROSE-00373578 discloses that platform U502 includes a motor for the front doors.
`Specifically, platform U502 includes motor with part numbers 930956 and 930957:
`
`
`
`
`
`
`
`
`
`During the deposition of 30(b)(6) representative David Brink, Mr. Brink stated that a motor is a an
`electric motor that is attached to a window lift mechanism, such as the window regulator. Please see
`
`
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`9
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 16
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`
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`U.S. PATENT NO. 7,579,802
`
`
`INDEPENDENT CLAIMS
`
`
`Deposition Transcript of David Brink, Page 29, Lines 9-11:
`
`U502
`
`
`Bates Number BROSE-00266722 discloses that the electronics for platform U502 is the same as platform
`D385:
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`10
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 17
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`Bates Number BROSE-00193763 discloses that platform D385 includes a sensor for measuring a
`parameter of the motor coupled to the motor driven element. Specifically, platform D385 includes a hall
`sensor:
`
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`11
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 18
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`Bates Number BROSE-00191683 discloses a bill of material for platforms D385 and U502. The bill of
`material identifies a sensor with part number HAL730SF-K:
`
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`12
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 19
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`INDEPENDENT CLAIMS
`
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`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`The datasheet for HAL730SF-K indicates that the sensor, as part of the HAL 730 family, is a hall-effect
`sensor:
`
`
`
`
`
`Bates Number BROSE-00189691 discloses that the sensor measures a parameter of the motor.
`Specifically, the hall sensor measures a position and a speed of the motor:
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`13
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 20
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`
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`Bates Number BROSE-00450231 discloses that the hall sensor detects a change of north and south poles
`of a magnet which is attached to the motor. Furthermore, between each change of the north and south
`poles, the hall sensor detects and outputs a digital signal at each change:
`
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`14
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 21
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`Pinch detection is based on the change in motor speed as detected by Hall effect sensors. Motor speed is
`derived from the time between pulses received from Hall effect sensors, for example see Bates no.
`BROSE-00450247 and BROSE-00450248. Specifically, motor speed is calculated by calling
`DrehzahlUmrechnung function (see wl_perconv.c file).
`
`Source code referenced herein was made available for inspection and found in a subdirectory labeled
`D:\wr_at_sources\at_gen3b\at_3_1_2\. Correspondence of these source code files to the named vehicle
`program was provided by a letter from Craig Leavell dated February 7, 2014.
`
`
`
`
`
`b) a memory for storing a number of
`measurement values from the sensor
`
`Bates Number BROSE-00266722 discloses that the electronics for platform U502 is the same as platform
`D385:
`
`
`
`15
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 22
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`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
` 20 the motor to reverse?
` 21 A If this command is requested, or created, then
` 22 the -- the application software switches --
` 23 switches off the -- the -- the software
` 24 reverses it the driving direction of the motor
` 25 immediately.
`
`
`Motor speed is determined by measuring the time between edges of pulses received from Hall effect
`sensors. With references to Bates no. BROSE-00450121, pulses widths are on the order of 20
`milliseconds as shown in the diagram below. Accordingly, signals received from the Hall effect sensors
`are processed within a forty millisecond time interval.
`
`
`
`Claim 6. The apparatus of
`claim 1 wherein the
`immediate past
`measurements of said
`parameter were taken
`within a forty millisecond
`interval prior to the most
`recent sensor measurement
`
`27
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`
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 23
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`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`a) a sensor for measuring a parameter of
`a motor coupled to the motor driven
`element that varies in response to a
`resistance to motion during all or part of
`a range of motion of the motor driven
`element;
`
`
`
`
`Bates Number BROSE-00188907 discloses that vehicle platform GM P1LL includes front door window
`regulators having a Snap Fit plastic slider which couples to a motor driven element, or window.
`Furthermore, platform GM P1LL further includes a rear window regulator having stamped guide rails
`and Snap Fit plastic slider which couples to a motor driven element, or window:
`
`
`
`12
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 24
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Bates Number BROSE-00188907 discloses the front window regulator as including stamped guided rails,
`a Snap Fit plastic slider and a FPG2 motor. In addition, the GM P1LL platform further includes a rear
`window regulator having a single guided rail, Snap Fit plastic slider and a FPG2 motor:
`
`
`
`
`
`
`13
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 25
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Bates Number BROSE-00188904 indicates that platform GM P1LL has four doors with motor driven
`elements, or windows:
`
`
`
`
`
`
`14
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 26
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Bates Number BROSE-00188905 indicates that the GM P1LL platform includes the electronics of the
`standard GM Epsilon II electronics:
`
`
`
`
`
`
`
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`15
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`
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 27
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`Bates Number BROSE-00273636 discloses a Power Window Electronics for Epsilon II platforms
`vehicles having a sensor for measuring a parameter of a motor coupled to the motor driven element that
`varies in response to a resistance to motion during all or part of a range of motion of the motor driven
`element. Specifically, the Power Window Electronics includes a hall sensor:
`
`
`
`During the deposition of 30(b)(6) representative David Brink, Mr. Brink verified that the block diagram
`is accurate for products sold today. Mr. Brink also indicated that the terms “Global Epsilon II” and
`“Global A” are synonymous. See Dep. Trans. of David Brink, 134:21 – 135:23:
`
`
`
`
`16
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 28
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`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Further, during the deposition of Mr. Brink, Mr. Brink indicated that the block diagram on Bates Number
`BROSE-00268165 may be the accurate representation of the P1LL. See Dep. Trans. of David Brink,
`143:23 – 144:18:
`
`
`
`
`
`
`17
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 29
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`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`In the alternative, Bates Number BROSE-00268165 identifies the electronics for the Epsilon II and
`platform P1LL. The electronics include a sensor for measuring a parameter of a motor coupled to the
`motor driven element that varies in response to a resistance to motion during all or part of a range of
`motion of the motor driven element. Specifically, the P1LL includes a hall sensor:
`
`
`
`
`
`18
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 30
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`
`
`
`Bates Number BROSE-00268163 discloses that the motor is coupled to the motor driven element and the
`Power Window Electronics detects the speed of the motor. Specifically, the motor has a ring magnet
`mounted on the rotor and via the hall sensors the Power Window Electronics receives an electrical
`impulse:
`
`
`
`19
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 31
`
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`CLAIMS
`
`
`
`
`
`Bates Number BROSE-00450231 discloses the hall sensors detecting a change of north and south poles
`of a magnet. Furthermore, between each change of the north and south poles, the hall sensor detects and
`outputs a digital signal at each change:
`
`
`
`
`
`
`20
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 32
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Pinch detection is based on the change in motor speed as detected by Hall effect sensors. Motor speed is
`derived from the time between pulses received from Hall effect sensors and is calculated by calling
`AT_CDiv function at line 189 of the At_Calc routine as follows:
` lu16_temp = At_CDiv(At_gu16_Period)
`where At_gu16_Period is a time period between pulses (see At_Calc.c file).
`
`Source code referenced herein was made available for inspection and found in a subdirectory labeled
`D:\wr_at_sources\at_gen4\at_4_0_draft_006\. Correspondence of these source code files to the named
`vehicle program was provided by a letter from Craig Leavell dated February 7, 2014.
`
`Bates Number BROSE-00188905 indicates that the GM P1LL platform includes the electronics of the
`standard GM Epsilon II electronics:
`
`b) a memory for storing a number of
`measurement values from the sensor
`based on immediate past measurements
`
`
`
`21
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 33
`
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
` 16 Q So you had stated a bit ago that if the
` 17 condition is satisfied, the motor would be
` 18 reversed. So I'd like to know what does the
` 19 controller output to form the signal to cause
` 20 the motor to reverse?
` 21 A If this command is requested, or created, then
` 22 the -- the application software switches --
` 23 switches off the -- the -- the software
` 24 reverses it the driving direction of the motor
` 25 immediately.
`
`
`
`
`CLAIMS
`
`
`
`Claim 6. The apparatus of claim 1
`wherein the immediate past
`measurements of said parameter were
`taken within a forty millisecond interval
`prior to the most recent sensor
`measurement.
`
`
`Motor speed is determined by measuring the time between edges of pulses received from Hall effect
`sensors. With references to Bates no. BROSE-00450121, pulses widths are on the order of 20
`milliseconds as shown in the diagram below. Accordingly, signals received from the Hall effect sensors
`are processed within a forty millisecond time interval.
`
`
`
`
`43
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 34
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`P1LL
`
`
`Claim 7. Apparatus for controlling
`activation of a motor for moving an
`object along a travel path and de-
`activating the motor if an obstacle is
`encountered by the object comprising:
`
`
`
`Bates Number BROSE-00188907 discloses that platform GM P1LL is the Cadillac XTS. The platform
`includes a front dual rail anti-pitch window regulator and a rear single rail anti-pitch window regulator.
`An object, or window, is engaged with the rails and slides along a travel path from a closed position to an
`open position and vice versa:
`
`
`
`
`
`44
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 35