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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
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`FORD MOTOR COMPANY
`Petitioner,
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`v.
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`PAICE LLC & ABELL FOUNDATION, INC.
`Patent Owners.
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`_________________________
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`
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`Case IPR2014-00904
`Patent 7,237,634
`_________________________
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`
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`PATENT OWNER’S MOTION FOR OBSERVATIONS ON THE
`CROSS EXAMINATION OF DR. GREGORY DAVIS
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`Case IPR2014-00904
`Patent 7,237,634
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`UPDATED LIST OF EXHIBITS
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`Exhibit Description
`
`Arbitration Agreement between Paice LLC and Ford Motor
`Company
`
`Patent Owner
`Exhibit Number
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`PAICE Ex. 2001
`
`PAICE Ex. 2002 Memorandum Opinion, U.S. District Court for the District of
`Maryland, U.S. District Judge William D. Quarles, Jr.
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`PAICE Ex. 2003
`
`Declaration in support of pro hac vice motion
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`PAICE Ex. 2004
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`Declaration of Neil Hannemann
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`PAICE Ex. 2005
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`Dr. Gregory W. Davis Deposition Transcript (Jan. 13, 2015)
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`PAICE Ex. 2006
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`PAICE Ex. 2007
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`PAICE Ex. 2009
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`Excerpt from File History for U.S. Patent 8,214,097
`“Integrated Microprocessor Control of a Hybrid i.c.
`Engine/Battery-Electric Automotive Power Train,” P.W.
`Masding, J.R. Bumby, Jan. 1990
`PAICE Ex. 2008 Masding, Philip Wilson (1988) “Some drive train control
`problems in hybrid i.c engine/battery electric vehicles,”
`Durhamtheses, Durham University
`Excerpt from McGraw-Hill Dictionary of Scientific and
`Technical Terms, Sixth Ed., 2003.
`Neil Hannemann CV
`Paice v. Ford, C.A. No. 1:14-cv-00492-WDQ, Complaint
`(Feb.19, 2014)
`Griffith Hack Report
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`PAICE Ex. 2010
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`PAICE Ex. 2011
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`PAICE Ex. 2012
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`PAICE Ex. 2013
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`Nov. 24, 2014 Letter to Wahls from Cordell
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`PAICE Ex. 2014
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`Dr. Gregory W. Davis Deposition Transcript (Feb. 25, 2015)
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`PAICE Ex. 2015
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`Dr. Gregory W. Davis, Deposition Transcript (June 3, 2015)
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`PAICE Ex. 2016
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`Dr. Gregory W. Davis, Deposition Transcript IPR Case 2014-
`01416 (June 3, 2015)
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`Case IPR2014-00904
`Patent 7,237,634
`In exhibit 2015, on page 5, lines 16-22, Dr. Davis testified that the
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`1.
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`textbook definition of road load does not include pedal position. This testimony is
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`relevant to Mr. Hannemann’s testimony at Ex. 1041 on page 46, lines 13-25. This
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`testimony is relevant because it demonstrates that both experts agree that textbook
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`road load does not include pedal position.
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`2.
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`In exhibit 2015, on page 19, lines 16-22, Dr. Davis testified that
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`despite Severinsky’s (Ex. 1003) disclosure of speed-responsive hysteresis,
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`Severinsky must consider road load because otherwise the vehicle of Severinsky
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`would be unable to determine when to enter into the engine plus motor hill
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`climbing mode at lower speeds. This testimony is relevant to Dr. Davis’s
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`testimony in Ex. 2016 where he agreed that another prior art reference (U.S. Patent
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`No. 5,842,534) also discloses speed-responsive hysteresis (page 8, line 9 – page 9,
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`line 13) and an engine plus motor hill climbing mode (page 23:2-23) but agreed
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`that the disclosed vehicle would be unable to determine when to enter into the
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`engine plus motor hill climbing mode (HEV mode) at lower speeds and would
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`instead stay in motor only mode (ZEV mode) (page 44, line 16 – page 45, line 9
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`and page 40, line 12 – page 41, line 4). This testimony is also relevant because it
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`demonstrates Dr. Davis is inconsistent with respect to the implications of the same
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`type of disclosure in different documents, which demonstrates he is applying
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`hindsight in his analysis and goes to the credibility of his testimony.
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`Case IPR2014-00904
`Patent 7,237,634
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`By: /Timothy W. Riffe /
`Timothy W. Riffe (Reg. No. 43,881)
`Kevin Greene, (Reg. No. 46,031)
`FISH & RICHARDSON P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`Tel: (202) 626-6447
`Fax: (202) 783-2331
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`Attorneys for Patent Owner
`Paice LLC & Abell Foundation, Inc.
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`- 4 -
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`Dated: June 10, 2015
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`CERTIFICATE OF SERVICE
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`Case IPR2014-00904
`Patent 7,237,634
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`Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
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`certifies that on June 10, 2015, a complete and entire copy of this Patent Owner’s
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`Motion for Observation and Exhibits was provided via email to the Petitioner by
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`serving the correspondence email addresses of record as follows:
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`Frank A. Angileri
`Brooks Kushman P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, Michigan 48075
`Email: FPGP0104IPR1@brookskushman.com
`
`Lissi Mojica
`Kevin Greenleaf
`Dentons US LLP
`1530 Page Mill Road
`Suite 200
`Palo Alto, California 94304-11251
`Email: lissi.mojica@dentons.com
`Email: kevin.greenleaf@dentons.com
`Email: iptdocketchi@dentons.com
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`/Susan C. Johnson/
`Susan Johnson
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis MN 55402
`214-292-4086
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