`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`FORD MOTOR COMPANY, AMERICAN HONDA MOTOR CO. INC., BMW
`OF NORTH AMERICA LLC, AND NISSAN NORTH AMERICA INC.,
`Petitioners
`
`v.
`
`VEHICLE OPERATION TECHNOLOGIES, LLC
`Patent Owner
`
`____________
`
`Case No. 2014IPR-00600
`Patent No. 7,145,442
` ____________
`
`
`
`
`
` PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,145,442
`
`
`
`
`
`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 7,145,442
`
`
`
`TABLE OF CONTENTS
`
`TABLE OF CONTENTS  ....................................................................................................................................  1  
`I.  
`INTRODUCTION  ........................................................................................................................................  1  
`II.   REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R. § 42.104  ......................  1  
`A.   GROUNDS FOR STANDING UNDER 37 C.F.R. § 42.104(A)  .................................................................................  1  
`B.  
`IDENTIFICATION OF CHALLENGE UNDER 37 C.F.R. § 42.104(B) AND RELIEF REQUESTED  .................  1  
`1.   The Grounds For Challenge .............................................................................................. 1  
`2.   Claim Construction Under 37 C.F.R. § 42.104(b)(3) .......................................................... 2  
`(a)   “display” (claim 36) ...................................................................................................... 3  
`(b)   “power consumption of a vehicle component” (claim 36) ........................................... 5  
`(c)   “An item comprising a medium storing instructions that, if executed, enable a
`system to perform steps comprising:” (claim 36) ............................................................... 6  
`3.   Level of Skill of a Person Having Ordinary Skill in the Art ................................................ 6  
`III.   SUMMARY OF THE ‘442 PATENT  ......................................................................................................  7  
`IV.   THERE IS A REASONABLE LIKELIHOOD THAT THE CHALLENGED CLAIMS OF
`THE ‘442 PATENT ARE UNPATENTABLE  ...............................................................................................  8  
`ISHIKAWA ANTICIPATES CLAIMS 36-40 UNDER 35 U.S.C. § 102(B)  ................................................................  8  
`A.  
`B.   KROPP ANTICIPATES CLAIMS 36-40 UNDER 35 U.S.C. § 102(A)  .....................................................................  23  
`C.   EVANS ANTICIPATES CLAIMS 36-40 UNDER 35 U.S.C. § 102(B), OR IN THE ALTERNATIVE, RENDERS
`CLAIMS 36-40 OBVIOUS UNDER 35 U.S.C. §103(A)  ....................................................................................................  35  
`D.  
`ISHIKAWA ALONE RENDERS CLAIMS 36-40 OBVIOUS UNDER 35 U.S.C. § 103(A)  .................................  44  
`E.   KROPP ALONE RENDERS CLAIMS 36-40 OBVIOUS UNDER 35 U.S.C. § 103(A)  .........................................  46  
`F.   KROPP IN VIEW OF ISHIKAWA RENDERS CLAIMS 36-40 OBVIOUS UNDER 35 U.S.C. § 103(A)  .............  48  
`G.   KROPP IN VIEW OF CROMBEZ RENDERS CLAIMS 36-40 OBVIOUS UNDER 35 U.S.C. § 103(A)  .............  51  
`V.   STATEMENT REGARDING NON-REDUNDANCY  ...................................................................  57  
`VI.   MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1)  ...........................................................  58  
`A.   REAL PARTY-IN-INTEREST AND RELATED MATTERS  .....................................................................................  58  
`B.   LEAD AND BACK-UP COUNSEL UNDER 37 C.F.R. § 42.8(B)(3)  .....................................................................  59  
`C.   PAYMENT OF FEES UNDER 37 C.F.R. § 42.103  ..................................................................................................  60  
`VII.   CONCLUSION  .......................................................................................................................................  60  
`
`
`
`
`
`
`
`

`

`
`
`I.
`
`INTRODUCTION
`
`Petitioners Ford Motor Company, American Honda Motor Co., Inc., BMW of
`
`North America LLC, and Nissan North America Inc. (“Petitioners”) request an Inter
`
`Partes Review (“IPR”) of claims 36-40 (collectively, the “Challenged Claims”) of U.S.
`
`Patent No. 7,145,442 (“the ‘442 Patent”) issued on December 5, 2006 to Yu Hei
`
`Sunny Wai (“Applicant”). Exhibit 1001, ‘442 Patent.
`
`II. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37
`C.F.R. § 42.104
`
`Each requirement for IPR of the ‘442 Patent is satisfied under §42.104.
`
`A. Grounds for Standing Under 37 C.F.R. § 42.104(a)
`
`Petitioners certify that the ‘442 Patent is available for IPR and that the
`
`Petitioners are not barred or estopped from requesting IPR challenging the claims of
`
`the ‘442 Patent. Specifically, Petitioners state: (1) Petitioners are not the owner of the
`
`‘442 Patent; (2) Petitioners have not filed a civil action challenging the validity of any
`
`claim of the ‘442 Patent; and (3) this Petition is filed less than one year after any
`
`Petitioner was served with a complaint alleging infringement of the ‘442 Patent.
`
`B.
`
`Identification of Challenge Under 37 C.F.R. § 42.104(b) and Relief
`Requested
`
`In view of the prior art, evidence, and claims charts, claims 36-40 of the ‘442
`
`Patent are unpatentable and should be cancelled. 37 C.F.R. § 42.104(b)(1).
`
`1.
`
`The Grounds For Challenge
`
`Based on the prior art references identified below, IPR of the Challenged
`
`
`
`
`1
`
`
`

`

`Claims should be granted. 37 C.F.R. § 42.104(b)(2).
`
`Proposed Statutory Rejections for the ‘442 Patent
`
`Claims 36-40 are anticipated under §102(b) by Japanese Patent
`Appl. Pub. No. H5-227369 (“Ishikawa”).
`
`Claims 36-40 are anticipated under §102(a) by German Patent Pub.
`No. DE 101 38 750 A (“Kropp”).
`Claims 36-40 are anticipated under §102(b), or in the alternative,
`rendered obvious by U.S. Patent. No. 5,534,759 to Evans, et al.
`(“Evans”)
`
`Claims 36-40 are obvious under § 103(a) over Ishikawa alone.
`
`Claims 36-40 are obvious under § 103(a) over Kropp alone.
`
`
`
`Reference
`Exhibit No.
`
`1002
`
`1003
`
`1006
`
`1002
`
`1003
`
`Claims 36-40 are obvious under § 103(a) over Kropp in view of
`Ishikawa.
`
`1002, 1003
`
`Claims 36-40 are obvious under § 103(a) over Kropp in view of U.S.
`Patent No. 6,480,106 to Crombez et al. (“Crombez”).
`
`1003, 1004
`
`
`Section IV identifies where each element of the Challenged Claims is found in the
`
`prior art patents. 37 C.F.R. § 42.104(b)(4). The exhibit numbers of the supporting
`
`evidence relied upon to support the challenges are provided above and the relevance
`
`of the evidence to the challenges raised are provided in Section IV. 37 C.F.R.
`
`§ 42.104(b)(5). Exhibits 1001 – 1011 are also attached.
`
`2.
`
`Claim Construction Under 37 C.F.R. § 42.104(b)(3)
`
`
`
`A claim subject to IPR receives the “broadest reasonable construction in light
`
`of the specification of the patent in which it appears.” 37 C.F.R. § 42.100(b). Unless
`
`otherwise noted below, Petitioners propose, for purposes of IPR only, that the claim
`
`
`
`
`2
`
`
`

`

`
`
`terms of the ‘442 Patent are presumed to take on their ordinary and customary
`
`meaning that the term would have to one of ordinary skill in the art. The claim
`
`construction analysis is not, and should not be viewed as, a concession by Petitioners
`
`as to the proper scope of any claim term in any litigation. These assumptions are not a
`
`waiver of any argument in any litigation that claim terms in the ‘442 Patent are
`
`indefinite or otherwise invalid.
`
`(a)
`
`“display” (claim 36)
`
`Challenged Claim 36 recites a “display.” Petitioners submit that the term
`
`“display” should be construed to mean: “a dedicated display in which the claimed
`
`information is presented at all times.”1
`
`If a term is expressly and clearly disclaimed or defined in the specification, it
`
`limits the scope of the broadest reasonable interpretation in IPR. See, e.g., Intellectual
`
`Ventures Mgmt. LLC, v. Xilinx, Inc., IPR2012–00018 & –19, Paper 13 (Feb. 12, 2013)
`
`(requiring “an explicit definition of the claim language or an express and clear
`
`disclaimer of a broader definition”) (citing In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir.
`
`2004) (“The PTO should only limit the claim based on . . . prosecution history when
`
`those sources expressly disclaim the broader definition.”)).
`
`
`1 Petitioners note that this construction is the same as that set forth for the other “display”
`
`terms required by each of the challenged independent claims in the other three petitions
`
`regarding the ‘442 Patent being filed concurrently by Petitioners.
`
`
`
`
`3
`
`
`

`

`
`
`The specification requires the display system to be “dedicated.” See, e.g., id. at
`
`2:21-23, 7:15, 12:21, and Figs. 2 and 5A. More importantly, the proposed construction
`
`is required by the Applicant’s own repeated clear and unequivocal statements
`
`describing his “present invention” during the prosecution of U.S. Patent Application
`
`No. 10/684,031, from which the ‘442 patent issued.
`
`During prosecution and in response to a rejection, Applicant amended his
`
`specification to include a description of the prior art and its lack of a dedicated
`
`display. Ex. 1001, ‘442 Patent, at 2:21-33 (“[Prior art reference] discloses a system
`
`based upon a computer program without the utilization of a dedicated display.”); Ex.
`
`1007, ‘442 File History (March 6, 2006 Amendment to Specification), at 299.
`
`In an earlier filing, Applicant presented the PTO with a discussion of the prior
`
`art and repeatedly characterized his invention as a “dedicated display,” as opposed to
`
`a multi-functional display in which various screens could be selected by a driver from
`
`among various options. Ex. 1007, ‘442 File History (Nov. 14, 2005 Office Action
`
`Response), at 219 (“The disclosed ‘freely programmable instrument cluster’ [of the
`
`Hauler reference] is intended to provide the driver with a variety of options for the
`
`review of operational parameters. The [Hauler] patent thus does not disclose or teach
`
`the present invention.”), 220 (“the device and method disclosed [in the Jaberi
`
`reference] are not dedicated display means and utilize a filtering process whose logic
`
`determines what is to be presented. This is remote from and does not teach the
`
`present invention.”), 221 (“the disclosure in [the Haubner reference] is of a complex
`
`
`
`
`4
`
`
`

`

`
`
`display means having multiple presentations … and are not independent dedicated
`
`displays.”) and 221 (“[t]he system disclosed [in the Berkert reference] utilizes a
`
`standard computer oriented selection method for access to display information. It is
`
`not a dedicated system which always presents specific types of information at
`
`all times as is done with the present invention.”).
`
`(b) “power consumption of a vehicle component” (claim 36)
`
`To the extent that construction of “power consumption of a vehicle
`
`component” is deemed necessary, this term should be construed to include displaying
`
`“the absolute or relative power consumption, usage, or power consumption rate of
`
`one or more vehicle components.” This construction is consistent with the
`
`specification and the understanding of a person of ordinary skill in the art. See, e.g.,
`
`Ex. 1001, ‘442 Patent at 6:58-60 (“symbolic display of the relative or absolute power
`
`usage by the vehicle’s power consuming components”), 11:42 (“associated power
`
`consumption rates”), 12:59-60 (“the amount of absolute or relative power
`
`consumption by vehicle components in bar charts”); 12:63-65 (“for all components or
`
`for only those components in use”). While the claim language itself is not limited to
`
`any particular vehicle component or components, the specification provides
`
`numerous examples of various vehicle components that would necessarily fall within
`
`the scope of this term, including power consumption of a vehicle’s stereo system, air
`
`conditioning system, cruise control system, heating system, lighting system, and
`
`others. Ex. 1001, ‘442 Patent at 11:36-40.
`
`
`
`
`5
`
`
`

`

`
`
`(c) “An item comprising a medium storing instructions that, if
`executed, enable a system to perform steps comprising:” (claim 36)
`
`Petitioners submit that this preamble, which is in Beauregard format, be
`
`construed as not requiring a medium storing executable instructions to enable a
`
`system to perform steps, but instead as merely requiring the performance of a method
`
`in which the claimed steps are performed, as required by the law. See Digital-Vending
`
`Servs. Int’l, LLC v. The University of Phoenix, Inc., 672 F.3d 1270, 1275, n.1 (Fed. Cir.
`
`2012) (holding that Beauregard claims that recite a medium storing instructions that,
`
`when executed, perform the steps of a method should be construed as methods, not
`
`apparatuses). Alternatively, the preamble should be construed as being non-limiting
`
`because the body of claim 36 does not rely on it for antecedent basis, the preamble
`
`does not recite “essential structure or steps,” and the preamble is not “necessary to
`
`give life, meaning, and vitality to the claim.” See, e.g., Symantec Corp. v. Computer
`
`Associates Intern., Inc., 522 F.3d 1279, 1288 (Fed. Cir. 2008).
`
`3.
`
`Level of Skill of a Person Having Ordinary Skill in the Art
`
`A person having ordinary skill in the art at the time of the ‘442 Patent would
`
`have a B.S. in electrical engineering or related engineering discipline and at least two
`
`years industry experience in the field of automotive electronics, or equivalent
`
`experience and/or education. The person would also have some knowledge or
`
`familiarity with in-vehicle displays. See Ex. 1005, Wilhelm Declaration, at ¶¶28-29.
`
`
`
`
`6
`
`
`

`

`
`
`III. SUMMARY OF THE ‘442 PATENT
`
`The ‘442 Patent generally describes apparatuses, methods, and systems for
`
`visually displaying real-time data relating to operating parameters of a vehicle to a
`
`driver of the vehicle. Ex. 1001, ‘442 Patent at Abstract. The operating parameters
`
`depicted by the display can relate to various parameters, including, for example,
`
`U.S. Patent
`Dec. 5, 2006
`Sheet 2 or 10
`US 1,145,442 B1
`torque and/or braking forces delivered to the wheels and power consumed by vehicle
`
`components. Id. at 2:41-46. An exemplary display for torque and/or braking forces is
`
`found in Figure 5A and an exemplary display for power consumption of vehicle
`
`components is found in Figure 17A:
`Vehicle Operation Display System
`Yu Hei Sunny Wai
`11,49,11
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`
`7 s 14
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
`Figure 5A
`
`Id. at 8:33-40, 11:34-40.
`
`44
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`m/_ 1638
`3° 75
`1'“ ’
`
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`J- 78
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`16,40 ’‘§\\\ \
`11,49,11
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`Flgure 56
`
`
`
`
`
`
`
`
`
`
`Generally speaking, the described systems utilize a similar architecture for
`
`41,4243,“
`17
`
`1177
`
`“'77 41,42,4s,44 /
`»’
`11
`
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`
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`
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`
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`
`41,42,43,44
`
`11
`
`

`

`
`
`collecting and displaying the specified information. For example, sensors collect
`
`information from relevant places in the vehicle and transmit signals to a vehicle CPU
`
`or display CPU. See generally id. at 2:47-52, 9:11-10:10. The vehicle CPU or display
`
`CPU then generates a display signal that is transmitted to a display device to visualize
`
`the collected information. Id. In addition to the system claims, the ‘442 Patent
`
`includes one claim set directed to a method for displaying torque and/or braking
`
`force information based on signals collected from a sensor that are subsequently
`
`processed and displayed. See e.g., claims 21-28. Importantly, as noted by the
`
`Applicant, the alleged invention of the ‘442 patent is merely a “new, useful
`
`application[] of existing technologies” and “the required technologies are old.” Id. at
`
`3:16-19, 3:30-32.
`
`IV. THERE IS A REASONABLE LIKELIHOOD THAT THE
`CHALLENGED CLAIMS OF THE ‘442 PATENT ARE
`UNPATENTABLE
`
`Systems and methods for displaying operating conditions of a vehicle, including
`
`torque, distributed driving force, braking force, and power consumption of vehicle
`
`components—including such systems that utilized dedicated displays—were prevalent
`
`well before October 14, 2003. The following prior art references disclose each
`
`limitation of the Challenged Claims either alone or in combination with another
`
`reference. As such, the Challenged Claims are unpatentable. Included in the claim
`
`charts below are exemplary citations to the prior art references.
`
`A.
`
`Ishikawa Anticipates Claims 36-40 Under 35 U.S.C. § 102(b)
`
`
`
`
`8
`
`
`

`

`
`
`Ishikawa was not cited or considered during prosecution and generally discloses a
`
`system for displaying the power consumption of an air conditioner within an automobile.
`
`Ex. 1002, Ishikawa at Abstract. In particular, Ishikawa describes an air conditioner power
`
`consumption calculating device for calculating power consumption based on an input
`
`electric current and an input voltage of air conditioner inverter and a dedicated displaying
`
`device for displaying the calculated value based on a calculation by the air conditioner
`
`power consumption calculating device. Id. As shown below, Ishikawa discloses every
`
`limitation of claims 36-40. Thus, there is a reasonable likelihood that Petitioners will
`
`prevail and these claims should be canceled as anticipated under § 102(b) as being
`
`anticipated by Ishikawa.
`
`
`36pre. An item
`comprising a medium
`storing instructions that, if
`executed, enable a system
`to perform steps
`comprising:
`
`Anticipated by Ishikawa (Ex. 1002)
`Ishikawa discloses a system for displaying the power
`consumption of an air conditioner in a vehicle and the
`system includes a processor with instructions for
`performing steps for displaying the power consumption
`information. See Ex. 1005, Wilhelm Declaration, at ¶¶ 32,
`33, 35, 38.
`
`“[A]ir conditioner power consumption calculating
`device for calculating power consumption based on an
`input electric current and an input voltage of air
`conditioner inverter (402), and displaying device (301)
`for displaying the calculated value based on a calculation
`by the air conditioner power consumption calculating
`device.” Ex. 1002, Ishikawa at [Abstract] [Structure].
`
`“[F]irst power consumption calculating device for
`calculating a power consumption based on an input
`electric current and an input voltage of the first inverter;
`and first displaying device for displaying a calculated
`
`
`
`
`9
`
`
`

`

`
`
`36a. receiving a data
`signal comprised of
`information regarding at
`least one operating
`parameter;
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`value based on a calculation by the first power
`consumption calculating device.” Id. at [0005] [Means for
`Solving the Problem]
`
` “[T]he power consumption by the electric compressor
`for the air conditioner is calculated by the power
`consumption calculating device and the power
`consumption is displayed by the displaying device
`based on the calculated value.” Id. at [0007] [Operation
`and Effects of the Present Invention].
`
`“A program for calculating the power consumption
`is installed in air conditioner ECU (300), to calculate the
`power consumption of the air conditioner based on the
`input electric current and the input voltage that are
`inputted into air conditioner ECU (300). The result of
`calculating the power consumption is displayed in
`power consumption displaying portion (305) of
`control panel (301), described below (referencing FIG.
`3). Note that an ECU is a calculation/controlling circuit
`that is structured from an input signal processing circuit,
`a calculating circuit, an output signal circuit (a driving
`circuit), a power supply circuit, and the like, where air
`conditioner ECU (300) is of the same type as driving
`ECU (500) and battery charging ECU (600), described
`below.” Id. at [0016].
`
`Id. at [0006] [Means for Solving the Problem], [0008]
`[Operation and Effects of the Present Invention], [0019];
`[0020].
`Ishikawa discloses that an air conditioner ECU receives a
`data signal from an air conditioner inverter relating to the
`amount of power being used by the air conditioner
`through the values of an input current and input voltage.
`
`“[A]ir conditioner power consumption calculating
`device for calculating power consumption based on an
`input electric current and an input voltage of air
`conditioner inverter (402).” Id. at [Abstract] [Structure].
`
`
`
`
`10
`
`
`

`

`
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`
`
`“[F]irst power consumption calculating device for
`calculating a power consumption based on an input
`electric current and an input voltage of the first
`inverter.” Id. at [0005] [Means for Solving the Problem].
`
`“Moreover, the value of the electric current and the
`value of the voltage that are outputted from air
`conditioner inverter (402) are inputted into air
`conditioner ECU (300).” Id. at [0015], [0019].
`
`“A program for calculating the power consumption is
`installed in air conditioner ECU (300), to calculate the
`power consumption of the air conditioner based on
`the input electric current and the input voltage that
`are inputted into air conditioner ECU (300).” Id. at
`[0016].
`
`[FIG. 1]
`
`
`
`155: Blowing Air
`100: Air Duct
`200: Cooling Cycle
`
`11
`
`
`
`
`
`

`

`
`
`36b. generating from said
`data signal a command;
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`201: Compressor
`207: Evaporator
`300: Air Conditioner ECU
`301: Control Panel
`400: Battery
`402: Air Conditioner Inverter
`
`
`
`
`Id. at [0018].
`Ishikawa discloses generating a command based on the
`data signal from the air conditioner inverter. See Ex.
`1005, Wilhelm Declaration, at ¶¶ 32, 33.
`
`“[A]ir conditioner power consumption calculating
`device for calculating power consumption based on
`an input electric current and an input voltage of air
`conditioner inverter (402), and displaying device (301) for
`displaying the calculated value based on a calculation by
`the air conditioner power consumption calculating
`device.” Ex. 1002 at [Abstract] [Structure].
`
`“[F]irst power consumption calculating device for
`calculating a power consumption based on an input
`electric current and an input voltage of the first
`inverter; and first displaying device for displaying a
`calculated value based on a calculation by the first power
`consumption calculating device.” Id. at [0005] [Means for
`Solving the Problem].
`
`“[T]he power consumption by the electric compressor
`for the air conditioner is calculated by the power
`consumption calculating device and the power
`consumption is displayed by the displaying device based
`on the calculated value.” Id. at [0007] [Operation and
`Effects of the Present Invention].
`
`“A program for calculating the power consumption
`is installed in air conditioner ECU (300), to calculate
`the power consumption of the air conditioner based on
`the input electric current and the input voltage that
`
`
`
`
`12
`
`
`

`

`
`
`said
`transforming
`36c.
`data signal based on the
`command
`into display
`information;
`and
`displaying
`said display
`information on a display
`for
`the operator of a
`motor vehicle; whereby
`said at least one operating
`parameter comprises the
`power consumption of a
`vehicle component.
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`are inputted into air conditioner ECU (300).” Id. at
`[0016], [0019].
`
`“[T]he power consumption by air conditioner electric
`compressor (201) is calculated by air conditioner ECU
`(300) based on the value of the electric current in the
`value of the voltage that are outputted by air
`conditioner inverter (402).” Id. at [0018].
`
`
`Id. at [0006] [Means for Solving the Problem], 0008]
`[Operation and Effects of the Present Invention], [0020].
`Ishikawa discloses transforming a data signal based on a
`command into display information that is sent to the
`power consumption displaying portion. See, Ex. 1005,
`Wilhelm Declaration, at ¶¶ 32, 33.
`
`Ishikawa further discloses a dedicated display for
`displaying the power consumption of the vehicle air
`conditioner and/or electric motor. See Ex. 1005, Wilhelm
`Declaration, at ¶ 34.
`
`“To enable the display of electric power consumption
`used by an air conditioner.” Ex. 1002, Ishikawa at
`[Abstract] [Objective].
`
`“[A]ir conditioner power consumption calculating device
`for calculating power consumption based on an
`input electric current and an input voltage of air
`conditioner inverter (402), and displaying device (301)
`for displaying the calculated value based on a
`calculation by the air conditioner power consumption
`calculating device.” Id. at [Abstract] [Structure].
`
`“The present invention relates to an electric automobile
`air-conditioning device, and in particular, relates to a
`vehicle air-conditioning device able to display the
`consumption of power used by the air-conditioning
`device.” Id. at [0001] [Industrial field of application].
`
`
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`13
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`
`
`Anticipated by Ishikawa (Ex. 1002)
`“[F]irst power consumption calculating device for
`calculating a power consumption based on an input
`electric current and an input voltage of the first
`inverter; and first displaying device for displaying a
`calculated value based on a calculation by the first
`power consumption calculating device.” Id. at [0005]
`[Means for Solving the Problem]
`
`“A program for calculating the power consumption
`is installed in air conditioner ECU (300), to calculate
`the power consumption of the air conditioner based
`on the input electric current and the input voltage
`that are inputted into air conditioner ECU (300). The
`result of calculating the power consumption is
`displayed in power consumption displaying portion
`(305) of control panel (301), described below
`(referencing FIG. 3).” Id. at [0016].
`
`“The result of the calculation of the power consumed
`by the air-conditioner, from air conditioner ECU (300),
`and the result of the calculation of the power
`consumed by driving, from driving ECU (500), are
`both displayed in power consumption displaying
`portion (305) of control panel (301).” Id. at [0021].
`
`“FIG. 4 shows an example display of power
`consumption displaying portion (305), where FIG. 4
`(a) shows the power consumption ratio, which displays
`the proportion, relative to the remaining battery
`power, that is used for air-conditioning (the A portion
`in FIG. 4 (a)), and the proportion that is used for
`driving (the B portion in FIG. 4 (a)). FIG. 4 (b) shows
`the proportion of the power consumption of the
`battery that is currently being used for the air
`conditioner (the A portion of FIG. 4 (b)), and the
`proportion that is used for driving (the B portion in
`FIG. 4 (b)). Moreover, FIG. 4 (c) shows a case wherein
`FIG. 4 (b) is displayed in a circular arc shape. FIG. 4 (d)
`shows a case wherein the proportion with which the
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`14
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`
`
`Anticipated by Ishikawa (Ex. 1002)
`travel distance is reduced is displayed, showing, as a rate
`of reduction, how much the travel distance is reduced
`through the use of the air-conditioner. Here the
`maximum travel distance is reduced by 30% when the air
`conditioner is used at full power.” Id. at [0022]
`
`
`
`
`Id. at Fig. 4.
`
`“[T]he power consumption by the electric motor for
`driving is calculated by the second power consumption
`calculating device, and displaying device for displaying
`the power consumption by the electric motor for
`driving, based on the calculated value, are further
`added to the invention set forth in Claim 1. This enables
`the vehicle occupant to ascertain simultaneously both the
`consumption of power used by the electric compressor
`for the air conditioner and the consumption of power by
`the electric motor for driving.” Id. at [0023].
`
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`15
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`
`Anticipated by Ishikawa (Ex. 1002)
`
`
`
`37. The item of claim 36,
`comprising
`a medium
`storing instructions that, if
`executed, enable a system
`to perform
`steps
`to
`transform said data signal
`by using a vehicle CPU or
`a display CPU.
`
`
`Id. at FIG. 3; see also id. at Id. at [0006] [Means for Solving
`the Problem], [0008] [Operation and Effects of the
`Present Invention], [0018], [0019], [0020].
`Ishikawa discloses a program installed on an air
`conditioner ECU that receives a data signal from the air
`conditioner inverter and calculates the power
`consumption of the air conditioner, thereby transforming
`that data signal to display information. See Ex. 1005,
`Wilhelm Declaration, at ¶¶ 32, 33, 35.
`
`The air conditioner ECU is a vehicle CPU or a display
`CPU. See Ex. 1005, Wilhelm Declaration, at ¶ 35.
`
`“[A]ir conditioner power consumption calculating
`device for calculating power consumption based on an
`input electric current and an input voltage of air
`conditioner inverter (402), and displaying device (301) for
`displaying the calculated value based on a calculation by
`the air conditioner power consumption calculating
`device.” Ex. 1002, Ishikawa at [Abstract] [Structure].
`
`“[F]irst power consumption calculating device for
`calculating a power consumption based on an input
`electric current and an input voltage of the first inverter;
`and first displaying device for displaying a calculated
`value based on a calculation by the first power
`consumption calculating device.” Id. at [0005] [Means for
`Solving the Problem].
`
` “A program for calculating the power consumption
`
`
`
`
`16
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`38. The item of claim 36,
`comprising
`a medium
`storing instructions that, if
`executed, enable a system
`to display said display
`information on a LED,
`LCD, vacuum fluorescent
`means, GPS
`display
`and/or
`trip
`computer,
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`is installed in air conditioner ECU (300), to calculate
`the power consumption of the air conditioner based on
`the input electric current and the input voltage that are
`inputted into air conditioner ECU (300). The result of
`calculating the power consumption is displayed in power
`consumption displaying portion (305) of control panel
`(301), described below (referencing FIG. 3). Note that
`an ECU is a calculation/controlling circuit that is
`structured from an input signal processing circuit, a
`calculating circuit, an output signal circuit (a driving
`circuit), a power supply circuit, and the like, where
`air conditioner ECU (300) is of the same type as
`driving ECU (500) and battery charging ECU (600),
`described below. ” Id. at [0016].
`
`“Explaining the effects of the first embodiment, above,
`the power consumption by air conditioner electric
`compressor (201) is calculated by air conditioner ECU
`(300) based on the value of the electric current in the
`value of the voltage that are outputted by air conditioner
`inverter (402). The result of the calculation of the power
`consumption is displayed on power consumption
`displaying portion (305) of control panel (301), thus
`enabling the vehicle occupant to ascertain, and based on
`the display by control panel (301), the consumption of
`power used by air conditioner electric compressor (201).
`” Id. at [0018].
`
`See also [0006], [0007, [0008], [Means for Solving the
`Problem], Figure 3.
`Ishikawa discloses a screen for displaying power
`consumption information related to an air conditioner
`and/or electric motor on a display, including through a
`numerical display or meter. Ex. 1005, Wilhelm Declaration,
`at ¶¶ 34, 36, 37.
`
`“[T]he power consumption is displayed by the
`displaying device based on the calculated value, this
`enables the vehicle occupants to ascertain the
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`numerical display, gauge,
`meter and/or PDA.
`
`
`
`Anticipated by Ishikawa (Ex. 1002)
`consumption of power used by the electric compressor
`for the air-conditioner, based on the display by the
`displaying device.” Id. at [0007] [Operation and Effects of
`the Present Invention].
`
`“FIG. 3 illustrates an example display of control panel
`(301), where control panel (301) is installed in a location
`that is easily seen by a vehicle occupant within the vehicle
`cabin. (302) is temperature adjusting lever, where
`temperature adjusting lever (302) is operated to control
`the firing angle of air conditioner inverter (402), or to
`control the ope