NHK Seating of America, Inc.
`v.
`
`Lear Corporation
`
`IPR2014-01079
`U.S. Patent No. 6,631,949
`IPR2014-01026
`U.S. Patent No. 6,655,733
`IPR2014-01101
`U.S. Patent No. 6,631,955
`
`September 10, 2015 Trial Hearing
`
`Petitioners’ DX-1
`
`
`v.
`
`Lear Corporation
`
`IPR2014-01079
`U.S. Patent No. 6,631,949
`IPR2014-01026
`U.S. Patent No. 6,655,733
`IPR2014-01101
`U.S. Patent No. 6,631,955
`
`September 10, 2015 Trial Hearing
`
`Petitioners’ DX-1
`
`
`
`Overview of '949, '733, and '955
`Patents
`
`Petitioners’ DX-2
`
`
`
`Overview of '949, '733 and '955
`
`Petitioners’ DX-3
`
`
`
`Overview of '949, '733 and '955
`
`'949 Fig. 6
`
`Petitioners’ DX-4
`
`
`
`Illustrative Claim 1 from '949
`
`Petitioners' DX 5
`
`
`
`Background of '949, 733 and '955
`
`'949 col. 1, 46-60
`
`Petitioners' DX 6
`
`
`
`Summary of '949, 733 and '955
`
`'949 at FIG. 4 and col. 5, 29-34
`
`Petitioners' DX 7
`
`
`
`First and Second Manners
`
`'949 Institution Decision at page 8.
`
`Petitioners' DX 8
`
`
`
`Manner v. Trajectory
`
`'949 Patent claim 10.
`
`Petitioners' DX 9
`
`
`
`'955 File History Clarifies
`Difference Between
`"manner" and "trajectory"
`
`
`
`10Petitioners’ DX-10
`
`
`
`'955 File History
`
`2014-01101 IPR Ex. 1002 at 69, '955 Applicant Remarks
`
`Petitioner DX 11
`
`
`
`'955 File History
`
`2014-01101 IPR Ex. 1002 at 72, '955 Notice of Reasons for Allowance
`Petitioner DX 12
`
`
`
`'955 File History
`
`2014-01101 IPR Ex. 1002 at 73, '955 Notice of Reasons for Allowance
`
`Petitioner DX 13
`
`
`
`Viano Definition of 2 Trajectories
`
`The following are examples of two distinguishably
`different paths or trajectories which one of ordinary
`skill in the art would have recognized: …
`
`2) one curved path transitioning to another curved
`path, where each has different arcs, such as two semi-
`circular paths with different radii.
`
`'949 Ex. 2010 Viano Dec. ¶ 102 (emphasis added).
`
`Petitioner DX 14
`
`
`
`Grounds – '949
`
`Ground Reference[s]
`
`Basis
`
`2
`
`3
`
`4
`
`5
`
`Nakano
`
`Kage
`
`Wiklund
`
`§ 102
`
`§ 102
`
`§ 102
`
`Wiklund and Seitzer
`
`§ 103
`
`Claim[s]
`challenged
`1-3, 6-11, 20
`and 21
`1, 3 and 6-9
`
`1, 3, 4, 6-9, 12-
`17, 20 and 21
`2 and 25
`
`Petitioner DX 15
`
`
`
`Grounds – '733
`
`Ground
`
`Reference[s]
`
`Basis
`
`Kage
`
`Nakano
`
`Wiklund
`
`§ 102
`
`§ 102
`
`§ 102
`
`Wiklund and Humer § 103
`
`1
`
`2
`
`3
`
`4
`
`5
`
`Claim[s]
`challenged
`11, 14, 19 and
`20
`11, 14, 19 and
`20
`11, 14, 15, 19
`and 20
`17, 18, and 21
`
`Viano
`
`§ 102
`
`11, 19 and 20
`
`Petitioner DX 16
`
`
`
`Grounds - '955
`
`Ground Reference[s]
`
`Basis
`
`Schubring and Kage § 103
`
`2
`
`3
`
`4
`
`Claim[s]
`challenged
`3 and 7
`
`Nakano
`
`§ 102
`
`3
`
`Nakano and Kage
`
`§ 103
`
`3 and 7
`
`Petitioner DX 17
`
`
`
`'949 Ground 2:
`Claims 1-3, 6-11, 20 and 21
`Anticipated by Nakano
`'733 Ground 2:
`Claims 11, 14, 19 and 20 anticiapted
`by Nakano
`'955 Ground 2:
`Claim 3 anticiapted by Nakano
`
`Petitioners’ DX-18
`
`
`
`Nakano
`
`'949 Ex. 1005 FIG. 4
`
`Petitioners’ DX-19
`
`
`
`Nakano's First Manner
`
`'949 Ex. 1005 ¶ 26 and
`FIG. 5
`
`Petitioner DX 20
`
`
`
`Nakano's Second Manner
`
`'949 Ex. 1005 ¶ 29 and
`FIG. 5
`
`Petitioner DX 21
`
`
`
`Viano Modeling
`
`Petitioner DX 22
`
`
`
`Viano SAM Modelling
`
`Viano Declaration, '733 Ex. 2005 at ¶¶ 86 and 88
`
`Petitioner DX 23
`
`
`
`Viano SAM Modelling
`
`"The figure below shows output from my model and confirms a first
`and second trajectory of the head restraint movement in Humer '733"
`
`Viano Declaration, '733 Ex. 2005 at ¶ 88
`
`Petitioner DX 24
`
`
`
`Viano SAM Modeling Output
`
`"The figure below shows
`output from my model and
`confirms a first and second
`trajectory of the head restraint
`movement in Humer '733"
`
`Viano's SAM Modeling Output for Nakano
`
`Viano Declaration, '733 Ex. 2005 at ¶ 88
`
`Viano Dep. '733 Ex. 1015 at 17:11-14
`
`Petitioner DX 25
`
`
`
`Viano's Modified SAM Modelling
`
`'733 Ex. 1016; 1012 at 41:10-14; 42:19 -
`43:1; '733 Ex. 1015 at 7:19-23, 8:13-23;
`10:12-17
`
`Petitioner DX 26
`
`
`
`Inherent Rotation Component of Deployment
`
`'733 Ex. 2005 Viano Declaration par. 100
`
`Petitioner DX 27
`
`
`
`Viano SAM Modelling
`
`Q And while these look to be relatively straight, is it
`possible that they're slightly curved due to the pivoting?
`A Could be, yes.
`'733 Ex. 1015 at 37:21-24
`
`'733 Ex. 1016 Viano Corrected Humer Path
`
`'949 Ex. 1018, Viano SAM Model of Nakano
`
`Petitioner DX 28
`
`
`
`Viano SAM Modelling
`
`Q And while these look to be relatively straight, is it
`possible that they're slightly curved due to the pivoting?
`A Could be, yes.
`'733 Ex. 1015 at 37:21-24
`
`'733 Ex. 1016 Viano Corrected Humer Path
`
`'949 Ex. 1018, Viano SAM Model of Nakano
`
`Petitioner DX 29
`
`
`
`Lear's "Two Trajectory" Tests
`
`Petitioner DX 30
`
`
`
`Single Equation - Test
`
`'733 PO Response at 57
`
`'733 Ex. 1012 Viano Deposition 36:7-10;
`see also 29:25 – 30:7 and 36:22-25
`
`Petitioner DX 31
`
`
`
`Differentiable Test
`
`'949 Ex. 1023
`
`Petitioner DX 32
`
`
`
`Differentiable Test
`
`'949 Ex. 1012, Viano
`Deposition at 35:3-7
`
`'949 Ex. 1012, Viano
`Deposition at 37:15-25
`
`Petitioner DX 33
`
`
`
`Differentiable Test
`
`'949 Decision on Institution at 7.
`
`Petitioner DX 34
`
`
`
`Differentiable Test
`
`Q Okay. Dr. Viano, I want to go back to your Nakano equation models again. You
`said that your equation for Nakano was differential over the entire path; do you
`remember that?
`
`A I said I believed it was…But I hadn't verified that.
`
`…Q
`
` Was it -- would it be differentiable between x and y over the entire patent?
`A I believe that's true for the parameters that I put in that represent the Nakano
`geometry because the shape looks like it's pretty simple.
`
`Q But you didn't do that exercise?
`A Differentiate it?... No.
`
`Q Wouldn't that tell us if there's a discontinuity in the path?
`A Well, I think when you look at the trajectory, it's -- there's no discontinuity;
`that's a single path.
`
`Viano Deposition Ex. 1012 – 69:24 – 7:22
`
`Petitioner DX 35
`
`
`
`Differentiable Test
`
`Dr. Kent Reply Declaration, '949 Ex. 1013 at ¶ 35
`
`Petitioner DX 36
`
`
`
`Different Curvature Test
`
`2014-01101 IPR Ex. 1002 at 73, '955 Notice of Reasons for Allowance
`
`Petitioner DX 37
`
`
`
`Different Curvature Test
`
`The following are examples of two distinguishably
`different paths or trajectories which one of ordinary
`skill in the art would have recognized: …
`
`2) one curved path transitioning to another curved
`path, where each has different arcs, such as two semi-
`circular paths with different radii.
`
`'949 Ex. 2010 Viano Dec. ¶ 102 (emphasis added).
`
`Petitioner DX 38
`
`
`
`Different Curvature Test
`
`'949 Ex. 1013 at ¶ 46; markup of Viano's Nakano Model; Note '949
`Ex. 1018 is deposition exhibit 3015.
`
`Petitioner DX 39
`
`
`
`Lear/Viano Tests for 1
`versus 2 Trajectories
`
`'949 Ex. 1013
`Kent Reply
`Decl. Par. 48
`
`Petitioner DX 40
`
`
`
`Patent Owner's Arguments
`
`Petitioners’ DX-41
`41
`
`
`
`First and Second Manner (claim 1)
`
`'949 PO Response
`at 20; see also
`'733 PO response
`at 26
`
`'949 PO Response at
`12.
`
`Petitioner DX 42
`
`
`
`Nakano – First and Second Manner
`
`'949 Petition at 24.
`
`Petitioner DX 43
`
`
`
`1st and 2nd Trajectories
`
`'955 PO Response at 32
`
`Petitioner DX 44
`
`
`
`1st and 2nd Trajectories – Different Curvature Test
`
`'949 Ex. 1013 at ¶ 46; markup of Viano's Nakano Model; Note '949
`Ex. 1018 is deposition exhibit 3015.
`
`Petitioner DX 45
`
`
`
`Lear/Viano Tests for 1
`versus 2 Trajectories
`
`'949 Ex. 1013
`Kent Reply
`Decl. Par. 48
`
`Petitioner DX 46
`
`
`
`Guide Member and Follower Cause Headrest to Move In First
`and Second Manner (claim 1)
`
`'949 PO Response at 25; see also '733 PO Response at 34.
`
`'949 Institution Decision at 17.
`
`Petitioner DX 47
`
`
`
`Guide Member and Follower Cause Headrest to Move In First
`and Second Manner (claim 1)
`
`'949 Ex. 1005 at [26]
`
`Petitioner DX 48
`
`
`
`Guide Member and Follower Cause Headrest to Move In First
`and Second Manner (claim 1)
`
`'949 Ex. 1005 at [29]
`
`Petitioner DX 49
`
`
`
`Bracket 35
`
`'949 PO
`Response at 27;
`See also '733 PO
`Response at 36.
`
`Petitioner DX 50
`
`
`
`Bracket 35
`
`'949 Institution Decision at 17 and 18.
`Petitioners’ DX-51
`
`Petitioner DX 51
`
`
`
`Bracket 35
`
`'949 Ex. 2010 Viano Declaration, par. 111
`
`Petitioner DX 52
`
`
`
`Follower Extending Laterally from Headrest Extension
`
`'949 PO Response at 28; see also '733 PO response at 31
`
`'949 PO Response at 29
`
`Petitioners’ DX-53
`
`Petitioner DX 53
`
`
`
`Follower Extending Laterally from Headrest Extension
`
`'733 Ex. 1002 FH at page 77
`
`733 Ex. 1008
`Viano '043,
`FIG. 4
`(annotated)
`
`Petitioners’ DX-54
`
`Petitioner DX 54
`
`
`
`Follower Extending Laterally from Headrest Extension
`
`'949 Petition at 33.
`Q The headrest extension 41, that goes
`inside of holder 36, correct?
`A I believe so, yes.
`Q And inside of 37, as well?
`A Providing adjustment of the height of the
`head restraint, yes.
`Q Right. So… 36 is wider than the headrest
`extension?
`A It's a larger diameter, yes.
`'949 Ex. 1012 Viano Depo. 60:12 – 61:1
`Petitioner DX 55
`
`733 Ex. 1008 Viano '043,
`FIG. 4 (annotated)
`
`Petitioners’ DX-55
`
`
`
`Decreasing Forward Velocity '949 Claims 10 and 11
`
`'949 PO Response at 32; see also '955 PO Response at 37
`
`Petitioners’ DX-56
`
`Petitioner DX 56
`
`
`
`Decreasing Forward Velocity Claims 10 and 11
`
`'949 Ex. 1018, Viano SAM Model
`
`Petitioners’ DX-57
`
`Petitioner DX 57
`
`
`
`'949 Ground 3:
`Claims 1, 3 and 6-9 are anticipated by
`Kage
`'733 Ground 1:
`Claims 11, 14, 19 and 20 are
`anticipated by Kage
`
`Petitioners’ DX-58
`
`
`
`'949 Ex. 1006 Kage – Overview ¶ 45
`
`Portion of Kage Fig. 3
`
`Petitioner DX 59
`
`
`
`Patent Disclosure v. Kage
`
`'949 Patent Col. 1, lines 57 - 60
`
`Ex. 1006 Kage at [45]
`
`Petitioner DX 60
`
`
`
`Patent Owner's Arguments
`
`Petitioners’ DX-61
`61
`
`
`
`Kage - two manners
`
`'949 PO Response at 37; see also '733 PO Response at 21
`
`Petitioner DX 62
`
`
`
`Two manners
`
`See '949 Ex. 1006 at ¶ [45] (emphasis added)
`
`Petitioner DX 63
`
`
`
`'955 Ground 4:
`Claims 3 and 7 are obvious in view of
`Nakano and Kage
`
`Petitioners’ DX-64
`
`
`
`'955 Decrease the Forward Velocity
`
`'955 Patent Col. 3, lines 58-65
`
`Petitioner DX 65
`
`
`
`Springs
`
`'955 PO Response at 41
`
`Petitioner DX 66
`
`
`
`Nakano and Kage
`
`'955 PO Response at 42
`
`'955 PO Response at 43
`
`Petitioner DX 67
`
`
`
`Nakano and Kage
`
`'955 Ex. 1017 Viano Deposition at 23:2-5.
`
`Petitioner DX 68
`
`
`
`Nakano and Kage
`
`'955 Ex. 1017 Viano Deposition at 19:9-13.
`
`Ex. 1006 Kage at [45]
`
`Petitioner DX 69
`
`
`
`'955 Ground 2:
`Claims 3 and 7 are obvious in view of
`Schubring and Kage
`
`Petitioners’ DX-70
`
`
`
`Schubring
`
`'955 Institution Decision at page 11
`
`Petitioner DX 71
`
`
`
`Patent Owner's Arguments
`
`Petitioners’ DX-72
`72
`
`
`
`Schubring and Kage
`
`'955 PO Response at page 21
`
`'955 PO Response at page 24
`
`Petitioner DX 73
`
`
`
`Schubring and Kage
`
`'955 PO Response at page 22
`
`'955 Ex. 1017 Viano Deposition at 23:2-5.
`
`Petitioner DX 74
`
`
`
`Schubring and Kage
`
`'955 Ex. 1017 Viano Deposition at 19:9-13.
`
`'955 Ex. 1006 Kage at [45]
`
`Petitioner DX 75
`
`
`
`Schubring and Kage
`
`'955 PO Response at 27.
`
`Petitioner DX 76
`
`
`
`Schubring and Kage
`
`'955 Ex. 1017 Viano Deposition at 22:6-17.
`
`Petitioner DX 77
`
`
`
`'949 Ground 4:
`Claims 1, 3, 4, 6-9, 12-17, 20 and 21
`anticipated by Wiklund
`'733 Ground 3:
`Claims 11, 14, 15, 19 and 20
`anticipated by Wiklund
`
`Petitioners’ DX-78
`
`
`
`Wiklund
`
`'949 Institution Decision at 21
`Petitioner DX 79
`
`
`
`Wiklund
`
`'949 Institution Decision at 22
`
`Petitioner DX 80
`
`
`
`Patent Owner's Arguments
`
`Petitioners’ DX-81
`81
`
`
`
`Wiklund
`
`'949 PO Response at 41; see also '733 PO Response at 39.
`
`Petitioner DX 82
`
`
`
`Wiklund
`
`Wiklund, '949 Ex. 1007 at 5:25-28
`
`Petitioner DX 83
`
`
`
`Wiklund Followers
`
`'949 PO Response at 45; See also '733 PO Response at 43
`
`'949 PO Response at 47
`
`Petitioner DX 84
`
`
`
`Wiklund Followers
`
`Q And the extension is colored
`yellow in [Wiklund]; do you see
`that?
`A Yes.
`Q And that fits inside the holder
`23?
`A Appears to, yes.
`Q So 23 is wider than the
`headrest extension?
`A Yes.
`
`'949 Ex. 1012 Viano
`Deposition 61:15-21
`
`'949 Ex. 1109 (Viano Dep Ex.
`949-3008)
`
`Petitioner DX 85
`
`
`
`Wiklund
`
`'949 PO Response at 47; see also '733 PO Response at 46
`
`'949 PO Response at 50
`
`Petitioner DX 86
`
`
`
`Wiklund
`
`'733 Ex. 1013, Kent
`Reply Declaration
`par. 49
`
`Petitioner DX 87
`
`
`
`'733 Ground 4:
`Claims 17, 18, and 21 are obvious in
`view of Wiklund and Humer
`
`Petitioners’ DX-88
`
`
`
`'733 Ground 4
`
`'733 PO response at 51
`
`Petitioner DX 89
`
`
`
`'949 Ground 5:
`Claims 2 and 25 Obvious in view of
`Wiklund and Seitzer
`
`Petitioners’ DX-90
`
`
`
`Cams
`
`'949 PO response at 53
`
`'949 PO response at 54
`
`Petitioner DX 91
`
`
`
`Cams
`
`Seitzer, '949 Ex. 1008 at pg. 1
`
`Seitzer, '949 Ex. 1008 at pg. 1
`
`Petitioner DX 92
`
`
`
`Cams
`
`Viano Deposition, '949 Ex. 1012 at 79:9-18
`
`Petitioner DX 93
`
`
`
`Wiklund motion profile
`
`Wiklund, '949 Ex. 1007 at 5:25-28
`
`Seitzer, '949 Ex. 1008 at pg. 1
`
`Petitioner DX 94
`
`
`
`'733 Ground 5:
`Claims 11, 19 and 20 anticipated by
`Viano
`
`Petitioners’ DX-95
`
`
`
`Viano Prior Art
`
`'733 PO Response at 53
`
`Petitioner DX 96
`
`
`
`Viano Prior Art
`
`'733 PO Response at 54
`
`Petitioner DX 97
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