Case: 4:13-cv-01895-JCH Doc. #: 1 Filed: 09/25/13 Page: 1 of 17 PageID #: 1
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MISSOURI
`EASTERN DIVISION
`
`CASE NO. :
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`JURY TRIAL DEMANDED
`
`§§§§§§§§
`
`NIDEC MOTOR CORPORATION
`Plaintiff,
`
`v.
`
`BROAD OCEAN MOTOR LLC,
`BROAD OCEAN TECHNOLOGIES,
`LLC, and
`ZHONGSHAN BROAD OCEAN
`MOTOR CO., LTD.
`
`Defendants.
`
`ORIGINAL COMPLAINT
`
`Plaintiff Nidec Motor Corporation (“Nidec Motor”), through its attorneys, files this
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`complaint against Defendants, Broad Ocean Motor LLC, Broad Ocean Technologies, LLC, and
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`Zhongshan Broad Ocean Motor Co., Ltd. (collectively, “Broad Ocean”) and hereby alleges as
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`follows:
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`PARTIES
`
`1.
`
`Plaintiff Nidec Motor is a corporation organized and existing under the laws of the state
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`of Delaware, with a principal place of business in this judicial district at 8050 W. Florissant
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`Avenue, St. Louis, Missouri 63136.
`
`2.
`
`Upon information and belief, Defendant, Broad Ocean Motor LLC is a corporation
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`organized and existing under the laws of the state of Delaware, with an office at 201 E 5th Street,
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`Washington, Missouri 63090.
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`3.
`
`Upon information and belief, Defendant, Broad Ocean Technologies, LLC is a
`
`corporation organized and existing under the laws of the state of Michigan, with a principal place
`
`1
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`of business at 29615 Hudson Drive, Novi, Michigan 48377. Broad Ocean Technologies, LLC is
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`registered to do business in the State of Missouri.
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`4.
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`Upon information and belief, Defendant, Zhongshan Broad Ocean Motor Co., Ltd. is a
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`corporation organized and existing under the laws of China, with a principal place of business at
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`No. 3 Shalang Industrial Zone, West District, Zhongshan, 528411, China.
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`JURISDICTION AND VENUE
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`5.
`
`This is an action for infringement of United States patents, and arises under the patent
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`laws of the United States, 35 U.S.C. § 271, et. seq. This Court has exclusive subject matter
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`jurisdiction of such action under 28 U.S.C. §§ 1331 and 1338(a).
`
`6.
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`This Court has personal jurisdiction over Defendants by virtue of Defendants’ regular
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`commercial and business activities within and/or directed to the State of Missouri.
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`7.
`
`This Court has general jurisdiction over Defendants because Defendants have continuous
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`and systematic contacts with this forum through their making, using, selling, offering to sell,
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`and/or importing blower motors for an HVAC system in or into the State of Missouri.
`
`In
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`addition, this Court has specific jurisdiction over Defendants because Defendants purposefully
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`directed their activities at residents of this forum and this patent infringement action arises out of
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`or relates to their making, using, selling, offering to sell, and/or importing blower motors for an
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`HVAC system in or into the State of Missouri.
`
`8.
`
`Defendant, Broad Ocean Motor LLC is doing business in Missouri, has purposefully
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`availed itself of the privilege of conducting business with residents of Missouri, inter alia, by
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`having an office in this judicial district, and as such, has established sufficient minimum contacts
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`with the State of Missouri.
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`2
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`9.
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`Defendant, Broad Ocean Technologies, LLC is doing business in Missouri, has
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`purposefully availed itself of the privilege of conducting business with residents of Missouri,
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`inter alia, by registering with the State of Missouri to do business in Missouri, and as such, has
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`established sufficient minimum contacts with the State of Missouri.
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`10. Defendant, Zhongshan Broad Ocean Motor Co., Ltd. is doing business in Missouri, has
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`purposefully availed itself of the privilege of conducting business with residents of Missouri,
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`inter alia, by supplying, distributing, selling, using, making, offering to sell, and/or importing
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`blower motors for an HVAC system in or into the State of Missouri, and as such, has established
`
`sufficient minimum contacts with the State of Missouri.
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`11. Venue is proper before this Court pursuant to 28 U.S.C. § 1391(b) and (c) and 28 U.S.C.
`
`§ 1400(b).
`
`COUNT I:
`INFRINGEMENT OF U.S. PATENT NO. 7,208,895
`
`12.
`
`On April 24, 2007, United States Patent No. 7,208,895 (“the ‘895 patent”) was duly and
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`legally issued for “Control Systems and Methods for Permanent Magnet Rotating Machines.” A
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`true and correct copy of the ‘895 patent is attached hereto as Exhibit A and made a part hereof.
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`13.
`
`Nidec Motor is the assignee and owner of all rights and title to the ‘895 patent, with the
`
`right to enforce the patent against infringers and to sue for and collect damages for all relevant
`
`times, including the right to assert the present cause of action.
`
`14.
`
`Defendants manufacture, make, have made, use, practice,
`
`import, provide, supply,
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`distribute, sell and/or offer for sale products in or into the United States, including but not limited
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`to blower motors for HVAC systems, that infringe one or more claims of the ‘895 patent in
`
`violation of one or more subsections of 35 U.S.C. § 271.
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`3
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`15.
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`Defendants’ products that infringe the ‘895 patent include but are not limited to “1HP
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`115~120V Unit” BO Part Number ZWK702E0750501 (“the HP Broad Ocean Motor”).
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`16.
`
`As one example of Defendants’ infringement of the ‘895 Patent, the HP Broad Ocean
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`Motor infringes at least claims 9 and 21 of the ‘895 Patent. Details of this infringement are set
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`forth below:
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`17.
`
`Claim 9 recites “[a] permanent magnet rotating machine and controller assembly
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`configured to perform the method of claim 1.” The HP Broad Ocean Motor includes a motor
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`controller that controls a permanent magnet rotating machine that performs the method of claim
`
`1.
`
`18.
`
`As recited in claim 1, the permanent magnet rotating machine of the HP Broad Ocean
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`Motor includes “a stator and a rotor situated to rotate relative to the stator, the stator having a
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`plurality of energizable phase windings situated therein.” A photograph of the HP Broad Ocean
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`Motor having a permanent magnet rotating machine having the recited elements of claim 1 is
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`provided below:
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`4
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`19.
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`As further recited in claim 1 of the ‘895 Patent, the HP Broad Ocean Motor is configured
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`for “receiving a rotor torque demand.” As shown in the table below, the HP Broad Ocean Motor
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`exhibits substantially constant rotor torque (between 24.4 lb-in and 25.0 lb-in) over a range of
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`rotor speeds (between 600 RPMs to around 1200 RPMs). Upon information and belief, the
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`motor controller for such product must rely on a rotor torque demand to achieve such calibration
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`of torque output over a range of speeds.
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`20.
`
`As still further recited in claim 1 of the ‘895 Patent, the HP Broad Ocean Motor is
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`configured for “calculating a scaled torque demand from the received torque demand as a
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`function of a speed of the machine to obtain a substantially constant rotor torque over a range of
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`rotor speeds.” As stated in paragraph 19, the HP Broad Ocean Motor exhibits substantially
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`constant rotor torque (between 24.4 lb-in and 25.0 lb-in) over a range of rotor speeds (between
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`600 RPMs to around 1200 RPMs). Upon information and belief, the motor controller of the HP
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`Broad Ocean Motor must scale the torque demand to produce such constant rotor torque from an
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`input rotor torque demand.
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`21.
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`Furthermore, the HP Broad Ocean Motor includes a speed sensor. Upon information and
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`belief, the HP Broad Ocean Motor uses the speed of the motor as sensed by the speed sensor as
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`the feedback element to control how the torque demand is scaled in order to achieve the result of
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`5
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`a substantially constant rotor torque over a range of rotor speeds. A photograph of the HP Broad
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`Ocean Motor having a speed sensor (xHall Device “40AF139”) is provided below:
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`22.
`
`Claim 21 recites “[a] permanent magnet rotating machine and controller assembly
`
`configured to perform the method of claim 12.” The HP Broad Ocean Motor includes a motor
`
`controller that controls a permanent magnet rotating machine that performs the method of claim
`
`12.
`
`23.
`
`As recited in claim 12, the permanent magnet rotating machine of the HP Broad Ocean
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`Motor includes “a stator and a rotor situated to rotate relative to the stator, the stator having a
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`plurality of energizable phase windings situated therein.”
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`24.
`
`Upon information and belief, the HP Broad Ocean Motor is configured for “calculating
`
`an IQr demand from a speed or torque demand,” as recited in claim 12.
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`25.
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`Upon information and belief, the HP Broad Ocean Motor is configured for “calculating a
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`dr-axis injection current demand as a function of a speed of the rotor,” as recited in claim 12.
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`6
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`26.
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`Upon information and belief, the HP Broad Ocean Motor is configured for “combining
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`the IQr demand and the dr-axis injection current demand to produce an IQdr demand that is
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`compensated for any torque contribution of dr-axis-current,” as recited in claim 12.
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`27.
`
`The HP Broad Ocean Motor, when used by Broad Ocean’s customers as part of HVAC
`
`systems and as intended and instructed by Defendants, infringes at least claims 9 and 21 of the
`
`‘895 Patent. Upon information and belief, the HP Broad Ocean Motor is specifically designed
`
`and specifically marketed by Defendants as a blower motor for use in an HVAC system.
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`28.
`
`Upon information and belief, Defendants offer to sell or sell within the United States or
`
`import into the United States blower motors, which constitute an apparatus for use in practicing
`
`the claimed methods of the ‘895 Patent. The motor controller and/or permanent magnet rotating
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`machine of the HP Broad Ocean Motor constitutes a material component of the claimed
`
`invention of the ‘895 Patent.
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`29.
`
`Upon information and belief, Defendants knew that the HP Broad Ocean Motor is
`
`especially made or especially adapted for use in an infringement of the ‘895 patent. Upon
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`information and belief, the motor controller and/or permanent magnet rotating machine of the HP
`
`Broad Ocean Motor is specifically designed and specifically marketed for use in practicing
`
`claims 9 and 21 of the ‘895 Patent.
`
`30.
`
`Upon information and belief, the motor controller and/or permanent magnet rotating
`
`machine of the HP Broad Ocean Motor is not a staple article or commodity of commerce suitable
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`for substantial noninfringing use. There is no substantial non-infringing use of the motor
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`controller and permanent magnet rotating machine of the HP Broad Ocean Motor because, upon
`
`information and belief, they are specifically designed and marketed as a component of a blower
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`motor for use in an HVAC system.
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`7
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`31.
`
`Defendants and/or individuals within Defendants’ employ had knowledge of the ‘895
`
`patent by virtue of Nidec Motor’s marking of the ‘895 Patent in its products, or at the latest, by
`
`virtue of cease and desist letters (attached hereto as Exhibit B) mailed to each of Defendants
`
`respectively on September 20 and 23, 2013 which serve as notice to Defendants of the ‘895
`
`Patent and of their infringing conduct.
`
`32.
`
`At all relevant times, Nidec Motor has complied with any and all marking and/or notice
`
`provisions of 35 U.S.C. § 287 with respect to the ‘895 patent. Among other things, Nidec Motor
`
`has marked products utilizing the subject matter of the ‘895 Patent with the number of the ‘895
`
`Patent. As an example, photographs of Nidec Motor’s RESCUE EcoTech® motor bearing the
`
`number of the ‘895 Patent are provided below:
`
`33.
`
`Nidec Motor has been damaged as a result of Defendants’ infringing conduct. Defendants
`
`are, thus, liable to Nidec Motor in an amount that adequately compensates it for Defendants’
`
`infringement, which, by law, cannot be less than a reasonable royalty, together with interest and
`
`costs, including lost profits, as affixed by this Court under 35 U.S.C. § 284.
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`8
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`34.
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`Defendants will continue their infringement of the ‘895 patent unless enjoined by the
`
`Court. Defendants’ infringing conduct has caused Nidec Motor irreparable harm and will
`
`continue to cause such harm without the issuance of an injunction.
`
`COUNT II:
`INFRINGEMENT OF U.S. PATENT NO. 7,626,349
`
`35.
`
`On December 1, 2009, United States Patent No. 7,626,349 (“the ‘349 patent”) was duly
`
`and legally issued for “Low Noise Heating, Ventilating and/or Air Conditioning (HVAC)
`
`Systems.” A true and correct copy of the ‘349 patent is attached hereto as Exhibit C and made a
`
`part hereof.
`
`36.
`
`Nidec Motor is the assignee and owner of all rights and title to the ‘349 patent, with the
`
`exclusive right to enforce the patent against infringers and to sue for and collect damages for all
`
`relevant times, including the right to assert the present cause of action.
`
`37.
`
`Defendants manufacture, make, have made, use, practice,
`
`import, provide, supply,
`
`distribute, sell and/or offer for sale products in or into the United States, including but not limited
`
`to blower motors for HVAC systems, that infringe one or more claims of the ‘349 patent in
`
`violation of one or more subsections of 35 U.S.C. § 271.
`
`38.
`
`Defendants’ products that infringe the ‘349 patent include but are not limited to the HP
`
`Broad Ocean Motor.
`
`39.
`
`Upon information and belief, the HP Broad Ocean Motor is specifically designed and is
`
`specifically marketed by Defendants as a blower motor for use in an HVAC system.
`
`40.
`
`Upon information and belief, the HP Broad Ocean Motor is specifically designed and is
`
`specifically marketed by Defendants to be used in combination with an HVAC system, which
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`includes “a system controller, a motor controller, an air-moving component, and permanent
`
`magnet motor.”
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`9
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`41.
`
`The HP Broad Ocean Motor includes “a permanent magnet motor having a stationary
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`assembly, a rotatable assembly in magnetic coupling relation to the stationary assembly, and a
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`shaft coupled to the air-moving component.” A photograph of the HP Broad Ocean Motor is
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`provided below:
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`42.
`
`Further, the motor controller of the HP Broad Ocean Motor “is configured for performing
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`sinewave commutation, using independent values of Q and d axis currents, in response to one or
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`more control signals received from the system controller to produce continuous phase currents in
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`the permanent magnet motor for driving the air-moving component.” The signal plots shown
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`below show that the HP Broad Ocean Motor produces continuous phase sine wave currents in
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`the permanent magnet motor that will drive the air-moving component during use at various
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`revolutions per minute (RPMs). Upon information and belief,
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`the operation of the motor
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`controller of the HP Broad Ocean Motor is controlled by the system controller.
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`10
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`Case: 4:13-cv-01895-JCH Doc. #: 1 Filed: 09/25/13 Page: 11 of 17 PageID #: 11
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`43.
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`Further proof that the HP Broad Ocean Motor performs sine wave commutation using
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`independent values of Q and d axis currents can be found in a digital signal processor (DSP). A
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`photograph is provided below showing that the HP Broad Ocean Motor uses a digital signal
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`processor labeled with “C2L4DFP,” which, upon information and belief, is a number for a
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`Renesas DSP chip.
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`11
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`44.
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`Upon information and belief, the mode of control for the DSP in the Broad Ocean Motor
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`is to use sine wave commutation driven by independent values of Q and d axis currents to
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`provide a computationally and memory efficient manner for producing continuous sine wave
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`phase currents in the permanent magnet motor as shown by the above signal plots.
`
`45.
`
`Upon information and belief, the HP Broad Ocean Motor is specifically designed and is
`
`specifically marketed by Defendants as a blower assembly for use in an HVAC system.
`
`46.
`
`Upon information and belief, the HP Broad Ocean Motor is specifically designed and is
`
`specifically marketed by Defendants to be used in combination with an HVAC system, which
`
`include “a motor controller, a blower, and permanent magnet motor.”
`
`47.
`
`The HP Broad Ocean Motor includes a permanent magnet motor “having a stationary
`
`assembly, a rotatable assembly in magnetic coupling relation to the stationary assembly, and a
`
`shaft coupled to the blower.”
`
`48.
`
`Upon information and belief, the HP Broad Ocean Motor includes a motor controller that
`
`“is configured for performing sinewave commutation, using independent values of Q and d axis
`
`currents, in response to one or more control signals received from a system controller to produce
`
`continuous phase currents in the permanent magnet motor for driving the blower.” As stated in
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`paragraphs 42, 43, and 44 and incorporated herein by reference, the motor controller of the HP
`
`Broad Ocean Motor is specifically designed to drive the blower by “performing sinewave
`
`commutation, using independent values of Q and d axis currents, in response to one or more
`
`control signals received from a system controller to produce continuous phase currents in the
`
`permanent magnet motor.”
`
`49.
`
`Upon information and belief, the HP Broad Ocean Motor is specifically designed and
`
`specifically marketed by Defendants to perform the “method for driving an air-moving
`
`12
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`component of a heating, ventilating and/or air conditioning (HVAC) system in response to a
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`control signal.”
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`50.
`
`The HP Broad Ocean Motor includes a permanent magnet motor “having a stationary
`
`assembly and a rotatable assembly in magnetic coupling relation to the stationary assembly, said
`
`rotatable assembly coupled in driving relation to the air-moving component.”
`
`51.
`
`Upon information and belief, the HP Broad Ocean Motor performs the method of
`
`“receiving at least one control signal from a system controller.” As stated in paragraph 42 and as
`
`is standard in the industry, the HP Broad Ocean Motor receives a control signal from a system
`
`controller of an HVAC system when in use.
`
`52.
`
`Upon information and belief, the HP Broad Ocean Motor performs the method of
`
`“performing sinewave commutation, using independent values of Q and d axis currents, in
`
`response to the at least one control signals received from the system controller to produce
`
`continuous currents in the permanent magnet motor for driving said air-moving component.” As
`
`stated in paragraphs 42, 43, and 44 and incorporated herein by reference, the motor controller of
`
`the HP Broad Ocean Motor is specifically designed to drive the air-moving component by
`
`“performing sinewave commutation, using independent values of Q and d axis currents, in
`
`response to the at least one control signals received from the system controller to produce
`
`continuous currents in the permanent magnet motor.”
`
`53.
`
`The HP Broad Ocean Motor, when used by Broad Ocean’s customers as part of HVAC
`
`systems and as intended and instructed by Defendants, infringes at least claims 1, 16 and 19 of
`
`the ‘349 Patent. Upon information and belief, the HP Broad Ocean Motor is specifically
`
`designed and specifically marketed by Defendants as a blower motor for use in an HVAC system
`
`13
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`54.
`
`Upon information and belief, Defendants offer to sell or sell within the United States or
`
`import into the United States blower motors for HVAC systems, which constitute a component
`
`of and a material part of the claimed invention of the ‘349 Patent. The motor controller of the
`
`HP Broad Ocean Motor or the HP Broad Ocean Motor itself constitutes a material component of
`
`an HVAC system.
`
`55.
`
`Defendants knew that the HP Broad Ocean Motor is especially made or especially
`
`adapted for use in an infringement of the ‘349 patent. Upon information and belief, the HP Broad
`
`Ocean Motor is specifically designed and marketed for use in combination with HVAC system.
`
`56.
`
`The HP Broad Ocean Motor is not a staple article or commodity of commerce suitable for
`
`substantial noninfringing use as there is no substantial non-infringing use of the HP Broad Ocean
`
`Motor. Upon information and belief, the HP Broad Ocean Motor is specifically designed and
`
`marketed to be used with HVAC systems.
`
`57.
`
`Defendants and/or individuals within Defendants’ employ had knowledge of the ‘349
`
`patent by virtue of Nidec Motor’s marking of the ‘349 Patent in its products, or at the latest, by
`
`virtue of cease and desist letters (attached hereto as Exhibit B) mailed to each of Defendants
`
`respectively on September 20 and 23, 2013 which serve as notice to Defendants of the ‘349
`
`Patent and of their infringing conduct.
`
`58.
`
`At all relevant times, Nidec Motor has complied with any and all marking and/or notice
`
`provisions of 35 U.S.C. § 287 with respect to the ‘349 patent. Among other things, Nidec Motor
`
`has marked products utilizing the subject matter of the ‘349 Patent with the number of the ‘349
`
`Patent. As an example, photographs of Nidec Motor’s RESCUE EcoTech® motor bearing the
`
`number of the ‘349 Patent are provided below:
`
`14
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`Case: 4:13-cv-01895-JCH Doc. #: 1 Filed: 09/25/13 Page: 15 of 17 PageID #: 15
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`59.
`
`Nidec Motor has been damaged as a result of Defendants’ infringing conduct. Defendants
`
`are, thus, liable to Nidec Motor in an amount that adequately compensates it for Defendants’
`
`infringement, which, by law, cannot be less than a reasonable royalty, together with interest and
`
`costs, including lost profits, as affixed by this Court under 35 U.S.C. § 284.
`
`60.
`
`Defendants will continue their infringement of the ‘349 patent unless enjoined by the
`
`Court. Defendants’ infringing conduct has caused Nidec Motor irreparable harm and will
`
`continue to cause such harm without the issuance of an injunction.
`
`JURY DEMAND
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`Nidec Motor hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of
`
`Civil Procedure.
`
`PRAYER FOR RELIEF
`
`THEREFORE, Nidec Motor respectfully requests that this Court enter judgment in its
`
`favor and grant Nidec Motor the following relief:
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`15
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`1.
`
`Judgment that one or more claims of the ‘895 Patent have been infringed, either literally
`
`and/or under the doctrine of equivalents, in violation of one or more subsections of 35 §
`
`U.S.C. 271;
`
`2.
`
`Judgment that one or more claims of the ‘349 Patent have been infringed, either literally
`
`and/or under the doctrine of equivalents, in violation of one or more subsections of 35 §
`
`3.
`
`3.
`
`4.
`
`5.
`
`6.
`
`U.S.C. 271;
`
`An award of damages adequate to compensate Nidec Motor for the infringement that has
`
`occurred, but in no event less than a reasonable royalty as permitted by 35 U.S.C. § 284.
`
`That Nidec Motor be granted pre-judgment and post-judgment interest on the damages
`
`caused to it by reason of Defendants’ infringing activities and other conduct complained
`
`of herein;
`
`That this Court declare this an exceptional case and award Nidec Motor its reasonable
`
`attorney’s fees and costs in accordance with 35 U.S.C. § 285;
`
`That Defendants be enjoined from any further activity or conduct that infringes one or
`
`more claims of the ‘895 Patent and ‘349 Patent; and
`
`That Nidec Motor be granted such other and further relief as the Court may deem just and
`
`proper under the circumstances including, but not limited to, supplemental damages
`
`and/or and accounting for any infringing acts not covered by any damages verdict entered
`
`in this action and for any post-verdict and/or post-injunction infringing acts.
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`Case: 4:13-cv-01895-JCH Doc. #: 1 Filed: 09/25/13 Page: 17 of 17 PageID #: 17
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`Date: September 25, 2013
`
`Respectfully submitted
`
`By:/s/ Jason M. Schwent
`
`Jason M. Schwent # 53260 MO
`David B. Jinkins #49254 MO
`Siho (Scott) Yoo #65297 MO
`THOMPSON COBURN LLP
`One US Bank Plaza
`St. Louis, MO 63101-1693
`Telephone:
`(314) 552-6000
`Facsimile:
`(314) 552-7000
`jschwent@thompsoncoburn.com
`djinkins@thompsoncoburn.com
`syoo@thompsoncoburn.com
`
`Attorneys for Plaintiff
`NIDEC MOTOR CORPORATION
`
`17
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 1 of 14 PageID #: 18
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`Exhibit A
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`

`
`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 2 of 14 PageID #: 19
`Case: 4:13—cv—O1895—JCH Doc. #: 1-1 Filed: 09/25/13 Page: 2 of 14 Page|D #: 19
`
`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 1 of 8
`
`US 7,208,895 B2
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`102
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`104
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`101
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`FIG. 1
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 3 of 14 PageID #: 20
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 4 of 14 PageID #: 21
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 5 of 14 PageID #: 22
`Case 4 13 cv 01895 JCH Doc # 1 1 Filed 09/25/13 Page 50f 14 Page|D# 22
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`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 4 of 8
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`US 7,208,895 B2
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 6 of 14 PageID #: 23
`Case: 4:13—cv—O1895—JCH Doc. #: 1-1 Filed: 09/25/13 Page: 6 of 14 Page|D #: 23
`
`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 5 of 8
`
`US 7,208,895 B2
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`£39
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`3
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`Run command
`
`Start Open Loop
`Using Predetermined
`Speed Value
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`
`Value?
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`Run Closed Loop
`Using Demanded Torque
`
`FIG. 5
`
`Improved Open Loop Starting
`
`

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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 7 of 14 PageID #: 24
`Case: 4:13—cv—O1895—JCH Doc. #: 1-1 Filed: 09/25/13 Page: 7 of 14 Page|D #: 24
`
`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 6 of 8
`
`US 7,208,895 B2
`
`§_QQ
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`Run command
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`
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`— run speed control mode
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`After 1 sec
`
`Transition to true sensorless
`— transition to torque control mode
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`— run estimator with filtered calculated speed
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`Shutdown and restart
`
`Run Demanded
`Tofque
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`
`FIG. 6
`
`

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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 8 of 14 PageID #: 25
`Case: 4:13—cv—O1895—JCH Doc. #: 1-1 Filed: 09/25/13 Page: 8 of 14 PagelD #: 25
`
`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 7 of 8
`
`US 7,208,895 B2
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 9 of 14 PageID #: 26
`Case: 4:13—cv—O1895—JCH Doc. #: 1-1 Filed: 09/25/13 Page: 9 of 14 Page|D #: 26
`
`U.S. Patent
`
`Apr. 24, 2007
`
`Sheet 8 of 8
`
`US 7,208,895 B2
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`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 10 of 14 PageID #: 27
`Case: 4:13-cv-01895-JCH Doc. #: 1-1 Filed: 09/25/13 Page: 10 of 14 Page|D #: 27
`
`US 7,208,895 B2
`
`1
`CONTROL SYSTEMS AND METHODS FOR
`PERMANENT MAGNET ROTATING
`MACHINES
`
`CROSS-REFERENCE TO RELATED
`APPLICATIONS
`
`This application claims the benefit of U.S. Provisional
`Applications No. 60/694,077 and No. 60/694,066 filed Jun.
`24, 2005, the entire disclosures of which are incorporated
`herein by reference.
`
`FIELD OF THE INVENTION
`
`invention relates generally to control of
`The present
`rotating machines, including but not limited to torque con-
`trol of permanent magnet rotating machines.
`
`BACKGROUND OF THE INVENTION
`
`Various control systems and methods are known in the art
`for controlling the output
`torque of permanent magnet
`machines, such as brushless permanent magnet motors.
`Some of these machines are provided with position sensing
`devices to indicate, for motor control purposes, the rotor
`position with respect to the stator, while other machines
`detect the rotor position “sensorlessly.” As recognized by the
`present inventors, a need exists for improvements in sensor-
`based and sensorless control systems for rotating permanent
`magnet machines, including those which control the output
`torque of a PM motor.
`
`BRIEF DESCRIPTION OF THE DRAWINGS
`
`FIG. 1 is a block diagram of a rotating permanent magnet
`machine system according to one embodiment of the present
`invention.
`
`10
`
`15
`
`20
`
`25
`
`30
`
`35
`
`FIG. 2 is a block diagram of a sensorless implementation
`of the system of FIG. 1 according to another embodiment of
`the invention.
`
`40
`
`FIG. 3 is a block diagram of an exemplary embodiment of
`the torque scaler shown in FIG. 2.
`FIG. 4 is a block diagram of an exemplary embodiment of
`the Idr Injection block, the Torque to IQdr Map block and
`the vectorize block of FIG. 2.
`
`FIG. 5 is a flow diagram of an open loop starting method
`according to another embodiment of the present invention.
`FIG. 6 is a flow diagram of an alternative start-up method
`according to another embodiment of the invention.
`FIG. 7 is a graph illustrating how the optimized calculated
`value of ldr injection current varies with electrical speed.
`FIG. 8 is a graph validating the proposed solution for the
`optimized calculation of ldr.
`
`DETAILED DESCRIPTION OF EXEMPLARY
`EMBODIMENTS
`
`Illustrative embodiments of the invention are described
`
`below. In the interest of clarity, not all features of an actual
`implementation are described in this specification. It will be
`appreciated that in the development of any actual embodi-
`ment, numerous implementation-specific decisions must be
`made to achieve specific goals, such as performance objec-
`tives and compliance with system-related, business-related
`and/or environmental constraints. Moreover,
`it will be
`appreciated that such development efforts may be complex
`
`45
`
`50
`
`55
`
`60
`
`65
`
`2
`
`and time-consuming, but would nevertheless be a routine
`undertaking for those of ordinary skill in the art having the
`benefit of this disclosure.
`
`FIG. 1 illustrates a rotating permanent magnet machine
`system 100 in accordance with one embodiment of the
`present invention. The machine system includes a rotating
`permanent magnet electric machine 101, such as a perma-
`nent magnet alternating current (PMAC) motor or a perma-
`nent magnet/switched reluctance (Pl\/I/SR) motor (i.e., a
`hybrid PM machine). For simplicity, the term “motor” is
`often used in this specification. However, one skilled in the
`art having the benefit of this disclosure will understand that
`the present invention is applicable to other types of rotating
`electric machines, including generators. The PM machine
`101 shown in FIG. 1 includes a stationary component
`(stator) 102 and a rotating component (rotor) 104. The
`machine can have an inner rotor or an outer rotor construc-
`
`tion. In this exemplary embodiment, the PM machine 101 is
`a three phase machine having an inner rotor construction
`with energizable phase windings 106A, 106B, 106C wound
`about the stator which is energized through the application
`of electric power to the motor terminals.
`A drive 108 is coupled to provide electric power to the
`terminals of the machine. The drive 108 receives control
`
`inputs fr