throbber
Case 1:13-cv-00539-SLR Document 1 Filed 04/05/13 Page 1 of 5 PageID #: 1
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VEHICLE OPERATION TECHNOLOGIES, LLC,
`
`
`Plaintiff,
`
`
`v.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`
`C.A. No. __________
`
`JURY TRIAL DEMANDED
`
`
`
`FORD MOTOR COMPANY,
`
`
`Defendant.
`
`This is an action for patent infringement in which Plaintiff Vehicle Operation
`
`Technologies, LLC makes the following allegations against Defendant Ford Motor Company:
`
`BACKGROUND
`
`1.
`
`Yu Hei Sunny Wai is the inventor of United States Patent No. 7,145,442 (the
`
`“Wai Patent”). Mr. Wai is an accomplished electronics and computer engineer with more than
`
`30 years of experience, including design, manufacturing and test engineering and management.
`
`His expertise spans a large swath of electronics and computer technologies, including consumer
`
`electronics, audio and video signal processing, power amplifiers, x-ray inspection systems,
`
`microwave communications, industrial robotics, and networking. Among other technical
`
`accomplishments, Mr. Wai, while working for Caspian Networks, developed the manufacturing
`
`and test standards for Caspian’s “carrier class” networking equipment - extremely reliable
`
`electronics that typically exceed 99.999% availability.
`
`2.
`
`Mr. Wai purchased a Honda Pilot in 2002 with Variable Torque Management
`
`4WD (VTM-4). While driving the Pilot in the snow, Mr. Wai discovered a problem: the vehicle
`
`failed to provide the driver with important operating information, for example, when and how the
`
`vehicle varied torque output to the drive wheels. Mr. Wai investigated how the vehicle drive
`
`
`
`HONDA601 EX. 1017
`
`AHM601_000844
`
`

`

`Case 1:13-cv-00539-SLR Document 1 Filed 04/05/13 Page 2 of 5 PageID #: 2
`
`
`
`train operated, designed and experimented with several types of sensors, and developed a
`
`complete system, including the sensor, interface, computational software, and display. His initial
`
`prototype system also measured and displayed 12 volt power consumption. The end result was a
`
`fully operational system that could measure and display torque distribution to the drive wheels,
`
`which Mr. Wai installed in his vehicle. Mr. Wai formed VMD, Inc., and filed an application for
`
`a patent on his invention on October 14, 2003, and the U.S. Patent and Trademark Office issued
`
`him U.S. Patent No. 7,145,442 on December 5, 2006.
`
`PARTIES
`
`3.
`
`Plaintiff Vehicle Operation Technologies, LLC (“VOT”) is a Delaware limited
`
`liability company.
`
`4.
`
`On information and belief, Defendant Ford Motor Company (“Defendant”) is a
`
`Delaware corporation with its principal office at One American Road, Dearborn, Michigan
`
`48126. Defendant has appointed The Corporation Trust Company, Corporation Trust Center,
`
`1209 Orange Street, Wilmington, Delaware 19801, as its agent for service of process.
`
`JURISDICTION AND VENUE
`
`5.
`
`This action arises under the patent laws of the United States, 35 U.S.C. § 1, et
`
`seq., including § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
`
`and 1338(a).
`
`6.
`
`This Court has personal jurisdiction over Defendant because, among other
`
`reasons, Defendant has done business in this District, has committed and continues to commit
`
`acts of patent infringement in this District, and has harmed and continues to harm VOT in this
`
`District, by, among other things, using, selling, offering for sale, and importing infringing
`
`products and services in this District.
`
`
`
`2
`
`AHM601_000845
`
`

`

`Case 1:13-cv-00539-SLR Document 1 Filed 04/05/13 Page 3 of 5 PageID #: 3
`
`
`
`7.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391(b)-(d) and 1400(b)
`
`because, among other reasons, Defendant is subject to personal jurisdiction in this District, has
`
`committed and continues to commit acts of patent infringement in this District. On information
`
`and belief, for example, Defendant has used, sold, offered for sale, and imported infringing
`
`products in this District.
`
`COUNT I
`INFRINGEMENT OF U.S. PATENT NO. 7,145,442
`
`VOT is the owner by assignment of the Wai Patent, entitled “Vehicle Operation
`
`8.
`
`Display System.” A true and correct copy of the Wai Patent is attached as Exhibit A.
`
`9.
`
`Defendant has been and now is directly infringing the Wai Patent, literally and
`
`under the doctrine of equivalents, in this judicial District and elsewhere in the United States, by,
`
`among other things, making, using, importing, offering for sale, and/or selling torque and
`
`component power consumption sensor and display system products and services that include,
`
`among other things, at least one signal source producing sensory data, a processing device
`
`operably coupled to said signal source to transform said sensory data into a display signal, a
`
`display device to receive and display the display signal as a viewable image, the image
`
`comprised of information regarding at least one operating parameter, said at least one operating
`
`parameter comprised of torque and/or braking forces delivered at the wheels of a motor vehicle,
`
`and whereby the generated image is observable by the operator of said motor vehicle. The
`
`infringing products and services include, for example, Defendant’s Ford Focus Electric, Ford C-
`
`Max Hybrid, Ford Fusion Hybrid, Ford MKZ Hybrid, Ford Escape Hybrid, and all of
`
`Defendant’s vehicles equipped with Ford’s All Wheel Drive.
`
`10.
`
`By engaging in the conduct described herein, Defendant has injured VOT and is
`
`thus liable for infringement of the Wai Patent pursuant to 35 U.S.C. § 271(a).
`
`
`
`3
`
`AHM601_000846
`
`

`

`Case 1:13-cv-00539-SLR Document 1 Filed 04/05/13 Page 4 of 5 PageID #: 4
`
`
`
`11.
`
`Defendant has committed these acts of infringement without license or
`
`authorization.
`
`12.
`
`As a result of Defendant’s infringement of the Wai Patent, VOT has suffered
`
`monetary damages and is entitled to a money judgment in an amount adequate to compensate for
`
`Defendant’s infringement, but in no event less than a reasonable royalty for the use made of the
`
`invention by Defendant, together with interest and costs as fixed by the Court, and VOT will
`
`continue to suffer damages in the future unless Defendant’s infringing activities are enjoined by
`
`this Court.
`
`13.
`
`VOT has also suffered and will continue to suffer severe and irreparable harm
`
`unless this Court issues a permanent injunction prohibiting Defendant, its agents, servants,
`
`employees, representatives, and all others acting in active concert therewith from infringing the
`
`Wai Patent.
`
`
`
`VOT respectfully requests that this Court enter:
`
`PRAYER FOR RELIEF
`
`A.
`
`A judgment in favor of VOT that Defendant has infringed the Wai Patent;
`
`B.
`
`A permanent injunction enjoining Defendant and its officers, directors, agents,
`
`servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all
`
`others acting in active concert therewith from infringement of the Wai Patent, or
`
`such other equitable relief the Court determines is warranted;
`
`C.
`
`A judgment and order requiring Defendant to pay VOT its damages, costs,
`
`expenses, and prejudgment and post-judgment
`
`interest
`
`for Defendant’s
`
`infringement of the Wai Patent as provided under 35 U.S.C. § 284, and an
`
`accounting of ongoing post-judgment infringement;
`
`
`
`4
`
`AHM601_000847
`
`

`

`Case 1:13-cv-00539-SLR Document 1 Filed 04/05/13 Page 5 of 5 PageID #: 5
`
`
`
`D.
`
`A judgment and order finding that this is an exceptional case within the meaning
`
`of 35 U.S.C. § 285 and awarding to VOT its reasonable attorneys’ fees against
`
`Defendant;
`
`E.
`
`A judgment and order requiring Defendant to provide an accounting and to pay
`
`supplemental damages to VOT, including without limitation, pre-judgment and
`
`post-judgment interest; and
`
`F.
`
`Any and all other relief to which VOT may be entitled.
`
`DEMAND FOR JURY TRIAL
`
`VOT, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
`
`any issues so triable by right.
`
`
`Dated: April 5, 2013
`
`Of Counsel:
`
`Alexander C.D. Giza
`Marc A. Fenster
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`(310) 826-7474
`agiza@raklaw.com
`mfesner@raklaw.com
`
`
`
`
`
`BAYARD, P.A.
`
`/s/ Stephen B. Brauerman
`Richard D. Kirk (#0922)
`Stephen B. Brauerman (#4952)
`Vanessa R. Tiradentes (#5398)
`222 Delaware Avenue, Suite 900
`P.O. Box 25130
`Wilmington, DE 19899
`(302) 655-5000
`rkirk@bayardlaw.com
`sbrauerman@bayardlaw.com
`vtiradentes@bayardlaw.com
`
`
`Attorneys for Plaintiff
`Vehicle Operation Technologies LLC
`
`5
`
`AHM601_000848
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 1 of 21 PageID #: 6
`Case 1:13-cv—00539-SLR Document 1-1 Filed 04/05/13 Page 1 of 21 PageID #: 6
`
`EXHIBIT A
`EXHIBITA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`AH M601 _000849
`
`AHM601_000849
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 2 of 21 PageID #: 7
`Case i=13-CV-00539'SLR D°°””‘e“t1'llllllllllllllllllllllllllllllMMfllllllflllflllflllfllfilll
`
`US007145442B1
`
`(12) United States Patent
`Us 7,145,442 B1
`(10) Patent No.:
`Wai
`(45) Date of Patent:
`Dec. 5, 2006
`
`(54) VEHICLE OPERATION DISPLAY SYSTEM
`
`(76)
`
`Inventor: Yu Hei Sunny Wai, 2282 Hastings Dr.,
`Belmont, CA (US) 94002
`
`( * ) Notice:
`
`Subject to any disclaimer, the term of this
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 127 days.
`
`(21) Appl. No.: 10/684,031
`
`(22)
`
`Filed:
`
`Oct. 14, 2003
`
`5,949,330 A *
`5,949,345 A *
`6,398,688 B1
`6,493,623 B1
`6,497,301 B1
`6,603,393 B1
`6,721,634 B1 *
`
`............ 340/461
`9/1999 Hoffman et a1.
`............. 340/461
`9/1999 Beckert et al.
`6/2002 Brown et al. ........... 475/204
`12/2002 Nishida et al.
`........ 701/89
`12/2002 Iida et a1. ............... 180/249
`8/2003 Sumada et a1.
`...... 340/461
`4/2004 Hauler et al.
`............... 340/441
`
`
`
`* cited by examiner
`
`Primary ExamineriThomas Mullen
`
`(57)
`
`ABSTRACT
`
`(51)
`
`Int. Cl.
`(2006.01)
`B60Q 1/00
`(52) US. Cl.
`...................... 340/438; 340/440; 340/441;
`340/453; 340/461; 340/815.4
`(58) Field of Classification Search ........ 340/4597462,
`340/438, 440, 441, 453, 815.4, 815.45, 815.44,
`340/815.53, 691.1, 691.6, 521, 522, 691.3;
`701/29735; 345/33, 35740
`See application file for complete search history.
`
`(56)
`
`References Cited
`U.S. PATENT DOCUMENTS
`
`6/1986 Haubner et al.
`............ 340/461
`4,594,572 A *
`
`9/1996 Opel
`........................ 701/36
`5,555,502 A *
`
`..... 340/461
`.
`5,825,284 A * 10/1998 Dunwoody et al.
`................ 340/461
`5,880,710 A *
`3/1999 Jaberi et al.
`
`An apparatus, method, system and/or image editing process
`for presenting Visual displays to the driver of a motor vehicle
`regarding the real time operating condition of the vehicle
`systems and components. These include the anti-lock brak-
`ing system, the stability of the vehicle as to proximity to
`rolling over, the power consumed by vehicle components
`such as the heating system and lights and/or, for four-wheel
`drive vehicles, the torque and/or braking forces delivered to
`the wheels. The information is acquired from sensors and/or
`from signals generated by the vehicle and it processed by the
`vehicle CPU or, in another embodiment, by a display CPU,
`the information being presented in black and white or in
`color using an LED, LCD, vacuum fluorescent means,
`numerical display, gauge, meter or PDA.
`
`44 Claims, 10 Drawing Sheets
`
`11,77
`
`1 ,41
`
`5
`
`2,42
`
`
`
`AH M601 _000850
`
`AHM601_000850
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 3 of 21 PageID #: 8
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 3 of 21 PageID #: 8
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 1 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`11.77
`
`11,77
`
`1.41
`
`
`
`5
`
`7
`
`242
`l
`
`
`
`9
`
`30,75
`
`16 38
`’
`
`30,75
`
`- 12
`
`13
`
`-13
`
`16,38
`
`16
`
`16
`
`I4““‘4
` 16,38
`
`Figure 1
`
`11,77
`
`3,43
`
`3
`
`5
`
`8
`
`4,44
`
`Figure 2
`
`
`
`
`{Ii/111m
`
`10
`
`
`AHM601_000851
`
`AHM601_000851
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 4 of 21 PageID #: 9
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 4 of 21 PageID #: 9
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 2 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny W31
`
`77
`
`11,49,
`
`11 49 77
`i
`’
`1
`
`41 ,42,43,44
`
`
`
`7,8/
`
`\
`
`
`
`'
`
`Figure 5B
`
`41 ,42,43,44
`
`7,8
`
`\
`
`11,49,77
`
`Figure SC
`
`Figure 5A
`
`41142-43144
`17
`
`11,77
`
`/
`
`41’42'43’44 I
`g
`
`17
`
`17
`17
`
`7.8
`
`17
`
`7,8
`
`11,77
`
`[1'77
`41,42,43,44
`
`
`
`1.,
`
`“\177
`
`41 ,42,43,44
`
`17
`l \
`1,3
`
`Figure 6A
`
`Figure 63
`
`Figure 7A
`
`Figure 7B
`
`AHM601_000852
`
`AHM601_000852
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 5 of 21 PageID #: 10
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 5 of 21 PageID #: 10
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 3 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`237514
`
`18
`
`22
`
`45
`
`46
`
`46
`
`45
`
`23,46,50
`
`i—EJ‘C'
`
`83
`
`Figure 10E
`
`1 1
`/
`
`t 75
`
`Figure 8A
`
`8
`
`50
`
`9
`
`23,423.50
`
`Figure 10A
`
`27
`
`A 51
`
`26
`23,46,50
`
`26
`
`Figure 103
`
`20,24,35
`’
`a
`
`20,24,35
`b
`
`8
`
`6
`
`
`
`1 1
`
`30
`
`Figure 9
`
`AH M601 _000853
`
`AHM601_000853
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 6 of 21 PageID #: 11
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 6 of 21 PageID #: 11
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 4 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System.
`
`Yu Hei Sunny Wai
`
` Figure 17D
`
`AHM601_000854
`
`AHM601_000854
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 7 of 21 PageID #: 12
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 7 of 21 PageID #: 12
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 5 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`
`
`Figure 193
`
`54
`
`50
`
`0
`
`Figure 10C
`
` Scalar
`
`
`I Module I Generation I Formating I
`
`Image
`
`Device
`
`72
`
`31
`
`79
`
`Figure 20
`
`AHM601_000855
`
`AHM601_000855
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 8 of 21 PageID #: 13
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 8 of 21 PageID #: 13
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 6 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`1
`
`29
`
`31
`
`31
`
`
`
`71...,LEE}.
`
`
`
`(1'. fi
`
`
`1|
`.l
`
`
`Figure 11A
`
`1 7, ‘
`
`,
`
`'I
`
`
` 29
`-i"'=-
`
`L...
`mm
`
`31
`
`I
`
`/‘
`
`Figure 113
`
`AH M601 _000856
`
`AHM601_000856
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 9 of 21 PageID #: 14
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 9 of 21 PageID #: 14
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 7 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`
` Figure 123 34
`Figure 14
`
`1 1,49,77
`
`1,2 3,4
`
`58
`
`50,51
`
`7,8
`
`Figure 13
`
`AH M601 _000857
`
`AHM601_000857
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 10 of 21 PageID #: 15
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 10 of 21 PageID #: 15
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 8 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`1 1 ,49,77
`
`
`
`Figure 15
`
`16,38 53
`
`53
`
`16,38 56 59
`
`/
`
`53
`
`Figure 16
`
`AH M601 _000858
`
`AHM601_000858
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 11 of 21 PageID #: 16
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 11 of 21 PageID #: 16
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 9 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display Sys1em
`
`Yu Hei Sunny Wai
`
`1 1 ,49,77
`
`1 1,80\
`
`
`
`71
`
`71
`
`T1
`
`71
`
`'71
`
`71
`
`71
`30,75
`
`.
`
`>
`
`10.5 ’
`
`l
`
`0.0
`
`0 o ,.
`'
`
`16
`
`65
`
`86
`
`67
`
`68
`
`69
`
`25
`
`33
`
`16
`
`16
`
`30,75
`
`Figure 17A
`
`Figure 178
`
`AH M601 _000859
`
`AHM601_000859
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 12 of 21 PageID #: 17
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 12 of 21 PageID #: 17
`
`U.S. Patent
`
`Dec. 5, 2006
`
`Sheet 10 of 10
`
`US 7,145,442 B1
`
`Vehicle Operation Display System
`
`Yu Hei Sunny Wai
`
`
`
`Figure 18A
`
`70
`
`Figure 183
`
`AH M601 _000860
`
`AHM601_000860
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 13 of 21 PageID #: 18
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 13 of 21 PageID #: 18
`
`US 7,145,442 B1
`
`1
`VEHICLE OPERATION DISPLAY SYSTEM
`
`FIELD OF INVENTION
`
`This invention relates generally to the field of information
`acquisition and display devices on a real-time basis and
`more particularly to systems which monitor the operation of
`powered vehicles and which display the status or condition
`of various aspects of vehicle operation for the driver. The
`invention specifically relates to the display of systems
`involving the anti-lock braking system, the stability of the
`vehicle as to proximity to rolling over, the power consumed
`by vehicle components such as the heating system and lights
`and/or, for four-wheel drive vehicles,
`the torque and/or
`braking forces delivered to the wheels. The information is
`acquired from sensors and/or from signals generated by the
`vehicle and is processed by the vehicle CPU or, in another
`embodiment by a display CPU. The processed information
`is then displayed for the driver in black and white or in color
`using an LED, LCD, vacuum fluorescent means, numerical
`display, gauge or meter.
`
`BACKGROUND OF THE INVENTION
`
`No prior art can be found which discloses the present
`invention. Historically the status of drive train components,
`of anti-locking brake system components, power usage by
`vehicle components, and/or of the approach of a rollover
`condition have not been displayed for the driver by any type
`of vehicle.
`
`US. Pat. No. 6,398,688, by Brown, et al, however dis-
`closes a visual display in FIG. 1 but without elaboration in
`the specification.
`US. Pat. No. 6,497,301 by lida, et al, discloses an
`indicator 25 and alarming lamp and alarm 26 in FIG. 1
`without further elaboration in the specification. Regarding
`the same type of disclosure, reference is made to US. Pat.
`No. 6,493,623 Nishida, et al.
`US. Pat. No. 46,603,393 by Sumada, et al, discloses a
`display for a vehicle operator for functional status of the
`vehicle but only mentions an open hood latch. No mention
`is made of the dynamics of operation of the vehicle.
`US. Pat. No. 5,825,284, Dunwoody et al, discloses a
`system and method of calculating the approach of a rollover
`condition for a vehicle. The method described uses a “lateral
`
`load transfer” sensor to calculate the center of gravity which
`is an inoperable means to make this calculation. Restated,
`very low weight loadings on a vehicle can be configured
`which will give high lateral loading and which result in no
`turning moment whatever. The Dunwoody patent is com-
`pletely inoperable. The present invention uses a harmonic
`frequency sensor which provides the means to calculate the
`center of gravity of a vehicle with great accuracy. With this
`and the input from a lateral acceleration sensor, the approach
`to a rollover condition of a vehicle is calculated with great
`accuracy.
`US. Pat. No. 5,949,330, Hoffman et al, discloses a
`general monitoring and diagnosing means without reference
`to monitoring vehicle parameters and without reference to
`the approach of a rollover condition of a vehicle.
`US. Pat. No. 6,721,634, Hauler, et al, discloses the use of
`a “freely programmable instrument cluster” within a vehicle
`but does not recite any vehicle parameters which are to be
`monitored and displayed. No reference is made regard
`monitoring vehicle parameters which would indicate the
`approach of a rollover condition of a vehicle.
`
`2
`
`US. Pat. No. 5,555,502, Opel, discloses a control system
`and an associated method with feedback input by the driver
`of a vehicle but does not recite any vehicle parameters which
`are to be monitored and displayed. No reference is made
`regard monitoring vehicle parameters which would indicate
`the approach of a rollover condition of a vehicle.
`US. Pat. No. 5,880,710, Jabei, et al, utilizes a filtering and
`selection means for information but does not recite any
`vehicle parameters which are to be monitored and displayed.
`No reference is made regard monitoring vehicle parameters
`which would indicate the approach of a rollover condition of
`a vehicle.
`
`US. Pat. No. 4,594,572, Haubner, et al, discloses a
`complex display means and primarily addresses the process-
`ing of information. The sole example given of a condition to
`be monitored is that of an open trunk compartment. Other-
`wise it does not recite any vehicle parameters which are to
`be monitored and displayed. No reference is made regarding
`the monitoring of vehicle parameters which would indicate
`the approach of a rollover condition of a vehicle.
`US. Pat. No. 5,949,345, Berkert, et al, discloses a system
`based upon a computer program without the utilization of a
`dedicated display. The sole vehicle parameter mentioned
`which is to be monitored is the fuel gauge. Torque related
`information, as delivered to the wheels and the approach to
`a rollover condition by a vehicle are not mentioned.
`The present invention discloses the use of a dynamic or
`real time display of the relative amounts of torque being
`transferred to the axles of a four-wheel drive vehicle and the
`
`use of an accurate monitoring means to indicate the
`approach of a rollover condition of a vehicle. These types of
`displays are currently unavailable to vehicle operators. No
`patents, including those cited above, disclose the method,
`system, process or apparatus of the present invention.
`
`SUMMARY OF THE INVENTION
`
`The present invention is an apparatus, method, process
`and system for displaying real-time operational information
`about a motor vehicle to the driver. The invention specifi-
`cally relates to the display of the status of systems involving
`the anti-lock braking system, the stability of the vehicle as
`to the approach of a rollover condition, the power consumed
`by vehicle components such as the heating system and lights
`and the torque and/or braking forces delivered to the wheels.
`The information is acquired from sensors and/or from sig-
`nals generated by the vehicle and is processed by the vehicle
`CPU or, in another embodiment, by a display CPU. The
`processed information is then displayed for the driver in
`black and white or in color using an LED, LCD, vacuum
`fluorescent means, numerical display, gauge or meter.
`The preferred images used in said display to convey said
`operating parameters are meaningful,
`symbolic, easily
`understood and spare in style. The presentation is in either
`black and white or color and the variety of types of display
`devices enumerated all generally serve to adequately display
`the needed information. Audible signals and/or warnings are
`used to augment these visual presentations. The preferred
`displays are time-variant, concise and appropriate for the
`information presented and include a proportional symbolic
`display, bar charts, a segmented bar chart, variable-size or
`variable-shape icon or images.
`It is an object of the present invention to provide an
`improved display means and system for the display of
`vehicle operating parameters to an operator of a motor
`vehicle.
`
`5
`
`10
`
`15
`
`20
`
`25
`
`30
`
`35
`
`40
`
`45
`
`50
`
`55
`
`60
`
`65
`
`AH M601 _000861
`
`AHM601_000861
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 14 of 21 PageID #: 19
`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 14 of 21 PageID #: 19
`
`US 7,145,442 B1
`
`3
`It is another object of the present invention to display
`information regarding the distribution of torque or driving
`forces at the wheels of a vehicle to the operator of the
`vehicle.
`
`It is another object of the present invention to display
`information to the operator regarding the approach of a
`rollover condition of the vehicle.
`
`It is another object of the present invention to collection
`information for display to an operator regarding the driving
`forces at the wheels of a vehicle by using a flux sensor or
`Hall effect sensor.
`
`It is another object of the present invention to display to
`the operator of a vehicle, information regarding the usage of
`power by various power consuming components of the
`vehicle.
`
`As disclosed by the present invention, the following items
`are new, useful applications of existing technologies for the
`display of information regarding the performance of a
`vehicle to the operator of the vehicle:
`(1) the torque or driving forces being delivered to the
`wheels;
`(2) the slippage of one or more wheels relative to the other
`wheels, particularly for four wheel drive vehicles;
`(3) the accurate visual display of the approach of a
`rollover condition of the vehicle;
`(4) the power being used by the power consuming com-
`ponents of a vehicle;
`(5) the use of true audible warnings for the approach of a
`rollover condition of a vehicle.
`
`These applications are not obvious as the required tech-
`nologies are old and the need for these applications has been
`long standing. Until the present invention, they have been
`unavailable.
`
`These and other objects an advantages of the present
`invention will become clear to those skilled in the art in view
`
`of the description of the best presently known mode of
`carrying out
`the invention and the applicability of the
`preferred embodiment as described herein and as illustrated
`in the several figures of the drawings.
`
`BRIEF DESCRIPTION OF THE DRAWINGS
`
`FIG. 1 is a display of a scalar bar diagram image of the
`braking force on the two rear wheels.
`FIG. 2 is a display of four wheel images representing the
`amplitude of the braking force on each wheel and the turning
`angle of the front wheels.
`FIGS. 3 and 4 are displays of wheel images indicating the
`amplitude of the braking force on each wheel.
`FIG. 5Ais a display of four wheel images representing the
`amplitude of the braking force on each wheel.
`FIGS. 5B and 5C are displays of wheel images represent-
`ing the amplitude of the relative amount of torque delivered
`to each of four wheels.
`
`FIGS. 6A, 6B, 7A and 7B are each a display of a wheel
`image indicating the amplitude of the torque delivered to a
`wheel.
`
`FIGS. 8A, 8B and 9 are each a diagram of a system
`schematically showing component monitoring, data pro-
`cessing means and an image display.
`FIG. 10A schematically illustrates an in—line connector.
`FIG. 10B schematically illustrates an in-line connector
`and an inserted coil.
`
`FIGS. 10C and 10D illustrate a clamping induction coil.
`FIG. 10E schematically illustrates an in-line current sens-
`ing device.
`
`10
`
`15
`
`20
`
`25
`
`30
`
`35
`
`40
`
`45
`
`50
`
`55
`
`60
`
`65
`
`AH M601 _000862
`
`4
`
`FIGS. 11A and 11B are each a schematic diagram of an
`ABS system monitoring, data processing means and an
`image display.
`FIGS. 12A and 12B are each a schematic diagram of an
`accelerometer and harmonic frequency sensor, data process-
`ing means and an image display.
`FIG. 13 is a display of a torque distribution image.
`FIG. 14 schematically illustrates placement of a wheel
`load sensor.
`
`FIG. 15 illustrates a display of torque and braking repre-
`sentations for four wheels.
`
`FIG. 16 illustrates a display of torque, braking and
`steering representations for the wheels of a four wheel
`vehicle.
`
`FIGS. 17A and 17B each illustrate a display of symbols
`and/or numerals, each representing the power consumption
`of a system component.
`FIGS. 17C and 17D each illustrate a bar chart pie segment
`display of images of power consuming components of a
`system.
`FIGS. 18A and 18B are each a schematic diagram of
`power component monitoring, data processing means and an
`image display.
`FIGS. 19A and 19B each illustrate a display indicating the
`approach to a rollover condition.
`FIG. 20 is a flow chart illustrating functional processing
`of information by a display CPU and system.
`
`Reference Numerals - Description
`
`Description
`deft front tire
`{ight front tire
`deft rear tire
`{ight rear tire
`5mm transfer case
`(car transfer case
`5mm axle
`(car axle
`:ront-rear transfer shaft
`3raking indicator line
`General reference number for a display
`Jpper display bar
`nower display bar
`)ower source
`n—gear braking indicator
`Tighlighted item
`3and, moving traction indicator
`Vehicle outline
`Tarmonic frequency sensor
`Tigh temperature tape
`Arc indicator
`Wheel steering angle sensor
`Wheel steering angle sensor connector
`Electromagnetic clutch
`Winch symbol
`n-line connector
`Toroidal coil sensor
`Master brake cylinder and controller
`3rake
`Display device, mounted
`3rake line
`CPU, vehicle
`)ower takeoff symbol
`Electromagnetic clutch controller
`:lux sensor
`CPU, display system
`Accelerometer or gravity direction sensor
`3ar chart amplitude
`CPU connector
`Negative bar chart amplitude
`3ar chart, left front wheel
`
`
`
`Numeral
`1.
`2.
`3.
`4.
`5.
`6.
`7.
`8.
`9.
`10.
`11.
`12.
`13.
`14.
`15.
`16.
`17.
`18.
`19.
`20.
`21.
`22.
`23.
`24.
`25.
`26.
`27.
`28.
`29.
`30.
`31.
`32.
`33.
`34.
`35.
`36.
`37.
`38.
`39.
`40.
`41.
`
`AHM601_000862
`
`

`

`Case 1:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 15 of 21 PageID #: 20
`Case l:13-cv-00539-SLR Document 1-1 Filed 04/05/13 Page 15 of 21 PageID #: 20
`
`US 7,145,442 B1
`
`5
`
`-continued
`
`Reference Numerals - Description
`
`Numeral
`
`Description
`
`42.
`43.
`44.
`45.
`46.
`47.
`48.
`49.
`50.
`51.
`52.
`53.
`54.
`55.
`56.
`57.
`58.
`59.
`60.
`61.
`62.
`63.
`64.
`65.
`66.
`67.
`68.
`69.
`70.
`71.
`72.
`73.
`74.
`75.
`76.
`77.
`
`78.
`79.
`80.
`81.
`82.
`83.
`84.
`85.
`
`
`
`Bar chart, rigit front wheel
`Bar chart, le
`rear wheel
`Bar chart, rigit rear wheel
`Wheel speed sensor
`Wheel speed connector
`Connector, vehicle CPU
`ABS controller
`Bar chart
`Connector to vehicle CPU
`Connector to display CPU
`Scalar bar diagram
`Indicator bar
`Clamping induction coil
`Sound amplitude indication symbol
`Bar chart divider
`Analog to digital (ND) converter
`Wheel load sensor
`Direction arrow
`Vehicle lighting symbol
`Net acceleration vector
`Center of gravity of vehicle
`7
`Ground
`Stereo system (speaker) symbol
`Air conditioning system symbol
`Cruise control symbol
`Ieating system symbol
`3ar chart
`)ower sensor
`Numerical display
`Scalar module
`Vector angle
`{adial line
`Vehicle display panel
`{eference image data module
`General reference number for a
`variable image
`3ar chart in pie segment format
`Device formating module
`Numerical display
`mage generation module
`7
`n-line series current sensor
`Alarm speaker
`Alarm speaker connector
`
`
`
`DESCRIPTION OF THE PREFERRED
`EMBODIMENT OF THE INVENTION
`
`The best known method for the presentation of graphical
`information to the driver of a motor vehicle regarding
`specific real-time operating parameters of the vehicle using
`display devices is the present
`invention. These specific
`real-time operating parameters are defined as the operation
`of an anti-lock braking system (ABS) and/or the behavior of
`the vehicle as to stability,
`that is,
`to the approach of a
`rollover condition and/or operation of a vehicle as to the
`power consumed by vehicle components and/or, for four-
`wheel or all-wheel drive vehicles, operation of the vehicle as
`to the torque and/or braking forces delivered to the wheels
`(which are not limited to these factors).
`The sophisticated manner in which a modern four-wheel
`drive vehicle’s controlling CPU distributes torque to the
`wheels obscures the details of transferred power by trans-
`forming the vehicle’s performance into a seamless and
`uniform continuity, regardless of road conditions. Variations
`in a wheel’s traction due to a slippery surface result in the
`delivery of less power to the wheel to avoid slippage. This
`invisible and comprehensive management of power distri-
`
`AH M601 _000863
`
`6
`bution greatly eases the burden of driving in dangerous
`situations. However many drivers would like to have, and
`frequently would benefit from viewing, displayed informa-
`tion regarding the real-time operation of the vehicle and the
`control system.
`It
`is to the presentation of this type of
`operational information that the present invention is ori-
`ented. The various data acquisition means, the related com-
`putational processes, the variety of display devices which
`can be utilized in real
`time and the various graphical
`symbols and forms together with their real-time variations
`are used to present said operating parameters and comprise
`the essence of the present invention. The manner of accel-
`erating, braking and/or steering by a driver, affect a vehicle’ 5
`performance. The dynamic display of these parameters
`therefore is also within the scope of the present invention
`(which is not limited to these factors).
`The preferred images used in said display to convey said
`operating parameters are meaningful,
`symbolic, easily
`understood and spare in style. The presentation is in either
`black and white or color and the variety of types of display
`devices enumerated all generally serve to adequately display
`the needed information. Audible signals and/or warnings can
`be used to augment these visual presentations. The preferred
`displays are time-variant, concise and appropriate for the
`information presented and include a proportional symbolic
`display, bar charts, a segmented bar chart and variable-size
`or variable-shap

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket