CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Bates Number BROSE-00364391 discloses that platform E70 includes a window lift motor:
`
`
`
`
`
`
`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;
`
`
`
`3
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 1
`
`
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Bates Number BROSE-00364391 discloses that platform E70 includes a window lift motor:
`
`
`
`
`
`
`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;
`
`
`
`3
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 1
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Bates Number BROSE-00364393 indicates the motor as 1BB26 motor:
`
`
`
`
`
`Bates Number BROSE-00371664 discloses that platform E70 includes a 1BB26 motor with part number
`927613 and 927614:
`
`
`
`4
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 2
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`
`
`
`Bates Number BROSE-00220300 discloses the motor for platforms E70 and E71. Specifically, platforms
`E70 and E71 includes motors with part number 927611, 927612, 927613, and 927314:
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`5
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 3
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`
`
`
`
`
`6
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 4
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Bates Number BROSE-00364391 discloses the motor driven element that moves over a range of motion.
`Specifically platform E70 includes a vehicle with four windows:
`
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`7
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 5
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Bates Numbers BROSE-00244011 – BROSE-00244012 disclose 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 platform E70 includes a hall sensor:
`
`
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`
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`8
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 6
`
`
`
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`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`
`
`
`
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`9
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
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`
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`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 7
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`Further, during the deposition of 30(b)(6) witness David Brink, Mr. Brink confirmed that the BMW E70
`includes a hall sensor. Mr. Brink stated that the E70 is a sensoric motor which is defined as a motor and
`an attached hall sensor, as described in Bates Number BROSE-00013642. See Deposition Transcript for
`David Brink, 113:4-114:9:
`
`
`
`
`
`
`
`Bates Number BROSE-00013642 illustrates the E70 motor having a sensor and being coupled to a motor
`driven element. The motor driven elements, or windows are moved by the window regulator:
`
`
`
`10
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 8
`
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`CLAIMS
`
`
`
`
`
`Bates Number BROSE-00450231 discloses that the hall sensor detects 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:
`
`
`
`
`
`11
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 9
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`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.
`
`Source code referenced herein was made available for inspection and found in a subdirectory labeled
`D:\Antitrap_software_Gen2\E71\brose_eks_lib\\. 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
`based on immediate past measurements
`
`Bates Number BROSE-00450219 discloses a block diagram of a window lifter provided by Brose. The
`window lifter includes a memory for storing a number of measurement values from the sensor.
`Specifically, the controller includes memory to store the anti trap algorithm, ROM memory, and
`
`
`
`12
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`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 10
`
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
` 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-004500121, 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.
`
`
`
`
`33
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 11
`
`
`
`
`CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`E70
`
`
`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-00364391 discloses that platform E70 includes a window lift motor:
`
`
`
`
`
`
`34
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 12
`
`
`
`
`INDEPENDENT CLAIMS
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`
`
`
`a) a sensor for measuring a parameter of
`a motor coupled to the motor driven
`element that varies in response to a
`
`Bates Number BROSE-00188897 indicates that platform U502 is the Ford Explorer, and discloses that
`the Ford Explorer includes a motor driven element. Specifically, the Ford Explorer includes windows,
`which are supplied by another:
`
`
`
`6
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 13
`
`
`
`U.S. PATENT NO. 7,579,802
`
`U502
`
`
`INDEPENDENT CLAIMS
`
`resistance to motion during all or part of
`a range of motion of the motor driven
`element;
`
`
`
`
`Bates Number BROSE-00188900 discloses that platform U502 includes a window regulator and
`electronics. Specifically, platform U502 includes GM Lambda style window regulators which are single
`rail regulator with two pulleys:
`
`
`
`
`
`7
`
`HIGHLY CONFIDENTIAL SOURCE CODE – OUTSIDE COUNSEL ONLY
`
`BNA/Brose Exhibit 1059
`IPR2014-00417
`Page 14
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