`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.;
`BROAD OCEAN MOTOR, LLC; AND
`BROAD OCEAN TECHNOLOGIES, LLC
`Petitioners
`
`v.
`
`NIDEC MOTOR CORPORATION
`Patent Owner
`___________________________
`
`Case IPR2014-011211
`Patent 7,626,349
`___________________________
`
`PETITIONERS’ RESPONSE TO
`PATENT OWNER’S OBJECTIONS TO
`PETITIONERS’ DEMONSTRATIVE EXHIBITS
`
`1 Case IPR2015-00762 has been joined with this proceeding.
`
`NY 814508v.1
`
`
`
`In response to Patent Owner’s objections to Petitioner’s demonstrative
`
`exhibits DX 3 and DX 46, Petitioner notes that the subject matter disclosed in these
`
`slides relate to the disclosure of the “demanded torque” control signal and the
`
`“airflow control loop” recited in proposed claims 21-23 in the prior art of record
`
`U.S. Patent No. 7,342,379 (see Ex. 3001 in IPR2014-01121 and Ex. 1010 in
`
`IPR2015-00762), which Patent Owner ignored in its Conditional Motion to Amend
`
`(Paper 73), but addressed for the first time in its Reply (Paper 80 at pp. 8-10). See
`
`Patent Owner’s demonstrative exhibit PO 31.
`
`Dated: February 21, 2016
`
`Respectfully submitted,
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Brookfield Place
`200 Vesey Street, 20th Floor
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioners Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 814508v.1
`
`- 1 -
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e) and 37 C.F.R. §42.105(b), the undersigned
`hereby certifies that on February 21, 2016, a complete and entire copy of the
`foregoing Petitioners’ Response To Patent Owner’s Objections To Petitioners’
`Demonstrative Exhibits was electronically served in its entirety on the Patent
`Owner of record (as agreed upon by counsel) at sbrown@hoveywilliams.com,
`mwalters@hoveywilliams.com, and litigation@ hoveywilliams.com.
`
`Additionally, the undersigned certifies that on February 21, 2016, a complete
`and entire copy of this Petitioners’ Response To Patent Owner’s Objections To
`Petitioners’ Demonstrative Exhibits was electronically served on the Patent
`Owner’s below-listed counsel of
`record at
`jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`syoo@thompsoncoburn.com,
`in
`the
`co-pending litigation Nidec Motor Corporation v. Broad Ocean Motor LLC et al.,
`Civil Action No. 4:13-CV-01895-JCH (E.D. Mo.), as agreed upon by the parties.
`
`Dated: February 21, 2016
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Brookfield Place, 200 Vesey Street
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 814508v.1
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
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.
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.
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
