UNITED STATES PATENT AND TRADEMARK OFFICE
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`—————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`—————
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`WEBASTO ROOF SYSTEMS, INC.
`Petitioner,
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`v.
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`UUSI, LLC
`Patent Owner.
`
`—————
`
`Case IPR2014-_____
`Patent 7,579,802
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`—————
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`DECLARATION OF HAMID A. TOLIYAT, PH.D.
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`Attorney Docket: 130163.231151
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`—————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner,
`
`v.
`
`UUSI, LLC
`Patent Owner.
`
`—————
`
`Case IPR2014-_____
`Patent 7,579,802
`
`—————
`
`DECLARATION OF HAMID A. TOLIYAT, PH.D.
`
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`1
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`Webasto Roof Systems, Inc.
`Exhibit 1003
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`UUSI, LLC
`Exhibit 2009
`1/126
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`Attorney Docket: 130163.231151
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`
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`Table of Contents
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`Page
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`I.
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`SUMMARY OF QUALIFICATIONS ............................................................ 6
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`II.
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`UNDERSTANDING OF LEGAL PRINCIPLES ........................................... 9
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`A. Anticipation ........................................................................................... 9
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`B.
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`C.
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`D.
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`E.
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`Obviousness ........................................................................................... 9
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`Claim Construction ............................................................................. 11
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`Priority Date ........................................................................................ 12
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`Level of Ordinary Skill in the Art ....................................................... 12
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`III. BACKGROUND AND STATE OF THE ART OF TECHNOLOGY AT
`ISSUE ............................................................................................................ 13
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`IV. SUMMARY OF THE(cid:3244)802 PATENT ............................................................ 21
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`V.
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`CLAIM CONSTRUCTION .......................................................................... 24
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`VI. BACKGROUND OF THE PRIOR ART ...................................................... 28
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`A.
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`Itoh ....................................................................................................... 28
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`B.
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`Kinzl .................................................................................................... 32
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`C.
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`Lamm ................................................................................................... 34
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`D. Duhame................................................................................................ 37
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`E.
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`Jones .................................................................................................... 39
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`VII. GROUNDS OF INVALIDITY ..................................................................... 41
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`A. Ground 1: Claims 1, 6-9, and 15-16 are Rendered Unpatentable for
`Obviousness based on Itoh in view of Kinzl ....................................... 41
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`1.
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`Claim 1 ...................................................................................... 41
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`2
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Claim 6 ...................................................................................... 49
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`Claim 7 ...................................................................................... 50
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`Claim 8 ...................................................................................... 59
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`Claim 9 ...................................................................................... 60
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`Claim 15 .................................................................................... 61
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`Claim 16 .................................................................................... 67
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`Combining Itoh and Kinzl ........................................................ 68
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`B.
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`Ground 2: Claim 11 is Rendered Unpatentable for Obviousness based
`on Itoh in view of Kinzl and Duhame ................................................. 69
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`1.
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`2.
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`Claim 11 .................................................................................... 69
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`Combining Itoh, Kinzl and Jones.............................................. 72
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`C. Ground 3: Claims 1, 6-9, and 15-16 are Rendered Unpatentable for
`Obviousness based on Lamm in view of Itoh ..................................... 72
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Claim 1 ...................................................................................... 72
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`Claim 6 ...................................................................................... 79
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`Claim 7 ...................................................................................... 81
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`Claim 8 ...................................................................................... 89
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`Claim 9 ...................................................................................... 91
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`Claim 15 .................................................................................... 93
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`Claim 16 .................................................................................... 99
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`Combining Lamm and Itoh ....................................................... 99
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`D. Ground 4: Claim 11 is Rendered Unpatentable for Obviousness based
`on Lamm, in view of Itoh and Duhame ............................................100
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`1.
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`Claim 11 ..................................................................................100
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`3
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`2.
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`Combining Lamm, Itoh and Duhame .....................................103
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`E.
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`Ground 5: Claims 1, 6-9, 11 and 15-16 are Rendered Unpatentable for
`Obviousness based on Duhame in view of Kinzl .............................103
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`Claim 1 ....................................................................................103
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`Claim 6 ....................................................................................111
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`Claim 7 ....................................................................................112
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`Claim 8 ....................................................................................117
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`Claim 9 ....................................................................................117
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`Claim 11 ..................................................................................118
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`Claim 15 ..................................................................................120
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`Claim 16 ..................................................................................124
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`Combining Duhame and Kinzl ...............................................124
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`4
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`Toliyat Declaration
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`I, Hamid A. Toliyat, hereby declare as follows:
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`I have been retained by counsel for Petitioner Webasto Roof Systems, Inc.
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`
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`1.
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`2.
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`(hereinafter, “WRSI”). I am being compensated for my work in this matter at a
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`rate of $450 per hour, and my compensation is not dependent in any way on the
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`outcome of this proceeding.
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`3.
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`I have been asked to provide my opinions regarding whether claims 1, 6-9,
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`11 and 15-16 (hereinafter, “Challenged Claims”) of U.S. Patent No. 7,579,802
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`(hereinafter, “’802 Patent”) are invalid because they are anticipated or would have
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`been obvious to a person having ordinary skill in the art at the time of the alleged
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`invention. In my opinion, those claims are invalid based on the grounds I discuss
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`below.
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`4.
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`In forming by opinion, I have considered the ’802 patent claims and
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`disclosure, the prosecution history of the ’802 patent, the petition for inter partes
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`review of the ’802 patent including the exhibits, Brose’s previously filed petition
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`for inter partes review of the ’802 patent including the exhibits, UUSI’s
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`infringement contentions in litigation, and my own experience and expertise.
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`5
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`SUMMARY OF QUALIFICATIONS
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`My qualifications and background are set forth in my curriculum vitae, a
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`
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`I.
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`5.
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`copy of which is attached as Exhibit 1004. A synopsis of my qualifications and
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`background is set forth below.
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`6.
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`7.
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`I am a licensed Professional Engineer in the State of Texas.
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`I earned a Ph.D. in Electrical Engineering with a specialization in Industrial
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`Drives, Electrical Machines, Power Electronics, Power Systems and Control from
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`the University of Wisconsin-Madison in 1991, a M.S. in Electrical Engineering
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`from West Virginia University in 1986 and a B.S. in Electrical Engineering from
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`Sharif University of Technology in May 1982. Since 1987, I have held numerous
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`teaching and research positions in the field of electrical engineering at the
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`University of Wisconsin-Madison (Jan. 1987 – May 1991), Ferdowsi University of
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`Mashhad (September 1991 – January 1994) and Texas A&M University (March
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`1994 – present).
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`8.
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`I am a member of a number of professional and honorary societies, including
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`the Fellow of Institute of Electrical and Electronic Engineers (“Fellow of IEEE”),
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`American Society of Heating, Refrigerating and Air-Conditioning Engineers
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`(ASHRAE), Sigma Xi, and Phi Beta Delta.
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`9.
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`I have also received numerous professional honors. For example, I will be
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`receiving one of the highest IEEE awards, namely the Nikola Tesla Field Award in
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`2014 for “Outstanding contributions to the design, analysis and control of fault-
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`tolerant multiphase electric machines.” I am a recipient of the IEEE Power
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`Engineering Society’s Cyrill Veinott Award in Electromechanical Energy
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`Conversion. In addition, since I began teaching at Texas A&M University, I have
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`received the Patent and Innovation Award from the Texas A&M University
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`System Office of Technology Commercialization, the TEES Faculty Fellow
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`Award, a Distinguished Achievement Award, the E.D. Brockett Professorship
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`Award, the Eugene Webb Faculty Fellow Award, and the Texas A&M Select
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`Young Investigator Award. I have also received Technical Awards from the
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`Schlumberger Foundation on two occasions and the Space Act Award from
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`NASA.
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`10.
`
`I am a named inventor on numerous patent applications, including two that
`
`issued as patents, namely, U.S. Patent No. 7,049,786 for “Unipolar drive topology
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`for permanent magnet brushless DC motors and switched reluctance motors.” The
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`‘786 Patent is based on my application entitled “A Low-Cost Brushless DC Motor
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`Drive with Improved Power Factor,” which discusses a system for improved power
`
`factor. I am also a named inventor on U.S. Patent No. 6,426,605 for a Multiphase
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`Induction Motor Drive System and Method.
`
`11.
`
`I am the author of DSP-Based Electromechanical Motion Control, CRC
`
`Press, 2003, and the Co-Editor of the Handbook of Electric Motors - 2nd Edition,
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`
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`7
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`Marcel Dekker, 2004. I have also published over 420 technical papers
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`(approximately a third of which were published in IEEE Transactions publications)
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`and have presented more than 80 lectures worldwide on such topics as electric
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`machines, power electronics, motor drives, and high frequency power converters.
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`In 2005, I served as the General Chair of the IEEE International Electric Machines
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`and Drives Conference.
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`12.
`
`I have over twenty years of experience focusing on projects relating to
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`improvements in the area of motor current signature analysis (MCSA). I am a co-
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`author of the textbook, Electric Machines – Modeling, Condition Monitoring, and
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`Fault Diagnosis (CRC Press, Florida, 2012.), which is one of the largest, most
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`comprehensive textbooks available on the subjects of MCSA and condition
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`monitoring of electric machines. These theoretical analysis and practical
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`implementation strategies are based on many years of research and development at
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`the Advanced Electric Machine and Power Electronics (EMPE) Laboratory at
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`Texas A&M University.
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`13.
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`In my educational background, research and consulting duties I have
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`developed a thorough understanding of variable speed motor drives, electric
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`motors and electronic controllers of these systems.
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`14.
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`I also have significant practical experience as an electrical engineer for Neka
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`Thermal Power Plant (June 1980 to December 1981) where I worked on
`
`
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`developing the turbo-generator exciter and auxiliary systems such as inverters and
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`rectifiers, Khorasan Regional Electric Company (June 1982 to February 1983)
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`where I designed and constructed high voltage substations, including the auxiliary
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`power supplies, Allen-Bradley Company (June 1989 to September 1989) where I
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`improved a high performance AC drive, and General Motors Corporation (January
`
`1991 to May 1991) where I designed a concentrated winding machine for a DC
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`locomotive traction alternative. I have also worked as a consultant in such areas as
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`electric machines, electric motors, oil platform power systems, power electronics,
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`subsea power systems, naval ships propulsions, and wind turbine generators.
`
`II.
`
`UNDERSTANDING OF LEGAL PRINCIPLES
`
`A.
`
`Anticipation
`
`15.
`
`I understand that to anticipate a patent claim, a single prior art reference
`
`must disclose every element of the claim, either explicitly or inherently to a person
`
`of ordinary skill in the art. I understand that an element of a claim is “inherent” in
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`the disclosure of a prior art reference when the missing element is the inevitable
`
`outcome of the process and/or thing that is described in the prior art reference.
`
`B.
`
`Obviousness
`
`16.
`
`I understand that a prior art reference can render a patent claim obvious to
`
`one of ordinary skill in the art if the differences between the subject matter set
`
`forth in the patent claim and the prior art are such that the subject matter of the
`
`
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`9
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`claim would have been obvious at the time the claimed invention was made. In
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`analyzing obviousness, I understand that it is important to consider the scope of the
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`claims, the level of skill in the relevant art, the scope and content of the prior art,
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`the differences between the prior art and the claims, and any secondary
`
`considerations.
`
`17.
`
`I understand that when the claimed subject matter involves combining pre-
`
`existing elements to yield no more than one would expect from such an
`
`arrangement, the combination is obvious. I also understand that in assessing
`
`whether a claim is obvious one must consider whether the claimed improvement is
`
`more than the predictable use of prior art elements according to their established
`
`functions. I understand that there need not be a precise teaching in the prior art
`
`directed to the specific subject matter of a claim because one can take account of
`
`the inferences and creative steps that a person of skill in the art would employ. I
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`further understand that a person of ordinary skill is a person of ordinary creativity,
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`not an automaton. However, I understand that obviousness cannot be based on the
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`hindsight combination of components selectively culled from the prior art.
`
`18.
`
`I understand that in an obviousness analysis, neither the motivation nor the
`
`avowed purpose of the inventors controls the inquiry. Any need or problem known
`
`in the field at the time of the invention and addressed by the patent can provide a
`
`reason for combining elements. For example, I understand that it is important to
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`consider whether there existed at the time of the invention a known problem for
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`which there was an obvious solution encompassed by the patent’s claims. I
`
`understand that known techniques can have obvious uses beyond their primary
`
`purposes, and that in many cases a person of ordinary skill can fit the teachings of
`
`multiple pieces of prior art together like pieces of a puzzle.
`
`19.
`
`I understand that, when there is a reason to solve a problem and there are a
`
`finite number of identified, predictable solutions, a person of ordinary skill has
`
`good reason to pursue the known options within his or her technical grasp. I
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`further understand that, if this leads to the anticipated success, it is likely the
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`product not of innovation but of ordinary skill and common sense, which bears on
`
`whether the claim would have been obvious.
`
`20.
`
`I understand that secondary considerations can include, for example,
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`evidence of commercial success of the invention, evidence of a long-felt need that
`
`was solved by an invention, evidence that others copied an invention, or evidence
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`that an invention achieved a surprising result. I further understand that such
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`evidence must have a nexus, or causal relationship to the elements of a claim, in
`
`order to be relevant. I am unaware of any such secondary considerations.
`
`C.
`
`Claim Construction
`
`21.
`
`I understand that claims in an inter partes review of an unexpired patent
`
`claims are given their broadest reasonable construction in light of the specification.
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`
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`11
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`I also understand that the ’802 patent will expire on November 13, 2014. I
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`understand, once a patent has expired, the claims are interpreted in the way a
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`person of ordinary skill in the art would have understood them at the time of the
`
`alleged invention, principally in view of the patent specification and prosecution
`
`history, and in view other sources of information available at the time. I will note
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`below if application of these different standards would affect my opinion.
`
`Otherwise, it should be assumed that my opinion would not be affected by the
`
`application of either standard.
`
`D.
`
`Priority Date
`
`22.
`
`I am informed and understand that for purposes of my analysis, I am to
`
`assume that the priority date of each of claims 1, 6-9, 11, and 15-16 of the ’802
`
`Patent is April 22, 1992, the filing date of the earliest parent application to which
`
`the ’802 Patent could conceivably claim priority. All of the prior art references I
`
`address in this declaration were filed and/or published prior to April 22, 1992.
`
`E.
`
`Level of Ordinary Skill in the Art
`
`23.
`
`It is my understanding that my analysis of the interpretation and validity
`
`must be undertaken from the perspective of what would have been known or
`
`understood by someone of ordinary skill in the art at least as early as April 22,
`
`1992. It is my opinion that the claims are directed to a person with at least a
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`Bachelor of Science degree (or the equivalent) in a relevant scientific or
`
`
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`12
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`engineering field, such as electrical engineering, mechanical engineering, or
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`automotive engineering, and having approximately two (2) years of experience
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`related to control systems...
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`24.
`
`I am well acquainted with knowledge of one of ordinary skill as of at least
`
`April 22, 1992.
`
`III. BACKGROUND AND STATE OF THE ART OF TECHNOLOGY AT
`ISSUE
`
`25. By April 22, 1992, it was well recognized that systems that control the
`
`movement of closures such as windows and doors could cause bodily injury to
`
`users during closing operations. There was an important need to ensure
`
`operational safety of closure devices such as garage doors, elevator doors, and,
`
`indeed, motor vehicle windows and panels. For instance, from my understanding,
`
`by 1990, Congress issued a mandate in the Consumer Product Safety Improvement
`
`Act of 1990 that included an entrapment protection requirement for garage doors
`
`with automatic openers. (Ex. 1012.) Similarly, as the named inventors of the ’802
`
`Patent acknowledged in the background section, the National Highway Traffic
`
`Safety Administration (NHTSA) Standard 118 contained regulations to assure safe
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`operation of power-operated windows and roof panels. (See Ex. 1001 at 1:32-43.)
`
`From my understanding, the original version of this standard issued in 1971, which
`
`specified “requirements for power-operated window and partition systems to
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`minimize the likelihood of death or injury from their accidental operation.” (Ex.
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`1011 at 22940) (See also Ex. 1005 (1991 version).)
`
`26. As a result, a principal goal for those skilled in the art by April 22, 1992, and
`
`in fact much earlier, was the accurate and rapid detection of obstructions and
`
`collisions in apparatus that control the movement of windows, panels, and other
`
`moving objects that could potentially cause physical injury.
`
`27. By April 22, 1992, obstruction detection capabilities were implemented in a
`
`variety of apparatus that controlled the movement of objects that range from motor
`
`vehicle windows and sunroofs to garage doors. For instance, some prior art
`
`systems detected an obstruction through the use of non-contact and proximate-
`
`contact methods, where, for example, electrical capacitive sensing devices were
`
`installed to sense the presence of nearby objects during operation. Similarly, some
`
`prior art systems relied on direct-contact devices to detect physical pressure or
`
`force of contact at the edge of the window or panel. Other systems utilized optical-
`
`based detection devices, such as photo-sensors to detect an obstruction based on
`
`the interruption of the optical beam. Yet other prior art apparatuses monitored for
`
`abrupt changes in the armature current, voltage or temperature of the window
`
`regulator motor.
`
`28.
`
`It was well recognized by this time that technology in this field could be
`
`readily applied across applications. For instance, a person of ordinary skill in the
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`art could have readily utilized technology and methodology of detecting a collision
`
`of a garage door or elevator doors and applied them in automotive applications,
`
`such as vehicle windows or sunroofs. For instance, a person of ordinary skill in the
`
`art could program a controller that was used to control and monitor vehicle
`
`windows or sunroofs to detect a collision using techniques found in garage door
`
`controllers and elevator doors alike. As I discuss further in reference to the
`
`Duhame reference below, even the inventors of the ’802 Patent recognized that the
`
`collision detection techniques known at the time can be readily applied to a wide
`
`range of applications.
`
`29. Many of these apparatuses detected an obstruction in the path of the moving
`
`panel of a device through the use of sensors that provide information related to the
`
`physical movement of the window or panel. For instance, these sensors were often
`
`coupled or integrated with the motor so that attributes of the motor, such as the
`
`motor speed, current, voltage, temperature, and other relevant data that may be
`
`gathered and used to detect abnormalities in the movement of the window or panel,
`
`including any collision or obstruction. Indeed, it was well known by persons
`
`having ordinary skill in the art well prior to April 22, 1992 to use sensors such as
`
`Hall-effect sensors, current-based sensors, photo-optic sensors, and other types of
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`sensors to monitor the movement of the window or panel.
`
`
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`30.
`
`For example, it was well known that Hall-effect sensors that were coupled to
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`the motor could be used to determine the speed, acceleration and other information
`
`related to the movement of the window or panel. In other well-known systems,
`
`current sensors were connected to the motor of the device from which the
`
`magnitude of current can be calculated by the controller of the prior art system. By
`
`April 22, 1992, many of those in the art realized that the increased accuracy of
`
`obstruction detection could be achieved by monitoring not just the instantaneous
`
`sensor measurement, but also rate of change of these measurements, taking into
`
`consideration measurements from earlier in the current run. For example, it was
`
`well known that controllers could determine whether there is an obstruction based
`
`on changes in speed (i.e., acceleration and deceleration), changes in acceleration,
`
`changes in measured motor current, and so on. For instance, the inventors of
`
`Lamm (discussed below) recognized this, stating that “[t]he additional or
`
`alternative determination of higher derivatives, preferably at least of the second
`
`derivative, further increases the detection reliability, because changes influence the
`
`result more strongly than in the first derivative.” (Ex. 1008 at 2.)
`
`31.
`
`In the collision detecting apparatuses of the prior art, motor speed, current
`
`and other parameters detected during the movement of the panel were compared
`
`with one or more threshold values in order to detect a collision. Based on these
`
`comparisons, it was possible to detect that the window or panel has encountered an
`
`
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`16
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`obstacle during movement. For instance, in many prior systems, the controller of
`
`the system detected an obstruction or collision if the measured parameter value
`
`exceeded a predetermined threshold value stored in memory.
`
`32. Upon detection, responsive actions were taken, including stopping the motor
`
`with de-energization. It was well recognized that accurate and fast detection of
`
`obstructions is essential in order to prevent damage to the motor, the window or
`
`panel, and, of course, to prevent any injury to users.
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`33. As many in the art recognized at least as early as April 22, 1992, the one
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`shortcoming of using a simple threshold comparison against the instantaneous
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`sensor measurement was the propensity of the system to erroneously detect an
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`obstruction. For instance, the system might incorrectly determine that the window
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`or panel has come upon an obstacle based on detected increase in current or a
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`decrease in motor speed, even when there is no obstruction. Similarly, the system
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`might incorrectly continue to power the motor despite the presence of an obstacle
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`in the path of travel. These false detections and failures to detect an obstruction
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`might be caused by a variety of environmental and other external factors that affect
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`the ability of the controller to perform its detecting capabilities.
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`34.
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`Speed and current of the motor could vary between different sections of the
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`path of travel due to the inherent mechanical properties of the window or panel
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`closure system. For example, the physical structure of rails guiding the window or
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`panel along its path of travel might cause speed and the amount of current detected
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`from the motor to vary during the movement of the window or panel. Similarly,
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`the mechanical tightness of system components and slack in the cables that are
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`pulling the window or panel might also cause the motor speed and current to vary
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`along its path of travel. For instance, during operation, the speed and current of the
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`motor at the beginning of the path might be much less than the speed and motor
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`current of the motor when the object is in the middle of the path of travel.
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`35. Variations of the parameter may also be caused by environmental
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`conditions, such as ice, dirt, grime accumulation, temperature, speed of the vehicle,
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`voltage of the motor, and other attributes.
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`36.
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`In addition, it was well recognized that there would be variations in motor
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`speed and/or motor current as the apparatus aged and suffered physical fatigue due
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`to use. As the apparatus aged, components suffered from degradation, warping,
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`and other physical changes.
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`37. As a result, a person of ordinary skill in the art understood that in practice,
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`apparatuses that relied solely on a fixed threshold value or instantaneous sensor
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`reading alone were sometimes inaccurate and ineffective in detecting obstructions.
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`For instance, apparatuses sometimes produced more false positive and false
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`negatives during operations with age and varying weather conditions. These are
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`undesirable traits for systems that could cause serious bodily injury during normal
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`operations, as recognized by those in the art prior to April 22, 1992. For instance,
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`the inventors of U.S. Patent No. 4,831,509 to Jones described that “the relationship
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`between motor load and door position will vary with door age, climatic conditions
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`and track condition. Thus setting of load monitoring device to only detect actual
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`obstructions is difficult as each of these variations must be compensated for in
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`order to avoid false tripping of the door mechanism.” (Ex. 1010 at 1:34-40.)
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`38. As those in the art recognized well prior to April 22, 1992, one way that
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`false-positives and false negatives could be reduced was by taking into account
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`variations that are caused by the environmental and other external conditions. One
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`well-known method to do this was to take into consideration not only the currently
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`sensed parameter value but also data from the current or speed sensed from the
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`current run and previous cycles in determining whether there is an obstruction.
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`These prior art systems, for instance, used measured motor speed or current values
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`detected earlier during the current run to calculate or adjust the threshold value.
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`The adjusted threshold value would then be compared against the current
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`parameter measurement in order to determine whether there is an obstruction.
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`39. By April 22, 1992, it was well known that controllers of systems for
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`operating windows or panel could be readily programmed to perform any number
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`of functions, including executing a wide range of mathematical calculations using
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`any number and type of parameters in order to accurately and quickly detect when
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`there is a collision along the path of travel.
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`40.
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`In many of the prior art references, the collision detection algorithms used
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`by these apparatuses were often discussed by reference to a comparison that was
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`processed by the controller of the apparatus. For example, some references
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`described that a collision was detected if a sensed or calculated parameter (e.g.,
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`acceleration) exceeded a predetermined value. A person of ordinary skill in the art
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`would have recognized that the controller would be programmed to process a
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`corresponding mathematical formula, e.g., St – St-1 > (cid:302), to detect the collision. A
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`person of ordinary skill in the art would have understood the equivalent
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`mathematical formulas for algorithms that are based on any number or type of
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`measurements, including those based on speed, current, change in speed or current,
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`or change in acceleration (and so on), as it would have been well within his or her
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`knowledge and education.
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`41. Moreover, a person of ordinary skill in the art would have known that these
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`comparisons could be equivalently expressed in a variety of manners, including
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`expressed in the context of a comparison with the most current speed measurement
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`(e.g., St). That is, using the same example listed in the previous paragraph, a
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`person of ordinary skill in the art would have recognized that the formula can be
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`expressed as St > (cid:302) + St-1, whereby the controller is comparing the most recent
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`speed measurement against an adaptive threshold ((cid:302) + St-1).
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`42. By April 22, 1992, computer memory was widely used by these types of
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`apparatuses in the industry in order to store the relevant data needed by the
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`controller to detect a collision, including measurement data from the sensors,
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`predetermined values used to calculate a threshold, temporary calculation results,
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`and others. Programmable controllers were used by a number of prior art systems
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`to perform these calculations and collision detection.
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`IV.
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`SUMMARY OF THE’802 PATENT
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`43.
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`In g