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`Paper No. 5
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.
`Petitioner
`
`V.
`
`NIDEC MOTOR CORPORATION
`
`Patent Owner
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`TITLE: LOW NOISE HEATING, VENTILATING AND/OR AIR
`CONDITIONING (HVAC) SYSTEMS
`
`FILED: FEBRUARY 1, 2007
`
`INVENTOR(S): MARCINKIEWICS ET AL.
`
`ISSUED: DECEMBER 1, 2009
`
`REVISED PETITION FOR INTER PARTES REVIEW OF U.S. PATENT
`
`NO. 7,626,349
`UNDER 35 U.S.C. § 312
`
`
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`Case IPR2014-01 121
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`Patent 7,626,349
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`Petitioner’s Exhibit List
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`Exhibit No.
`
`1001
`
`US. Patent No. 7,626,349
`
`1002
`
`Excerpts from the Prosecution History of Application 11/701,350,
`which issued as the ‘349 Patent
`
`1003
`
`Japanese Patent Publication JP 2003—348885 (“Hideji”)
`
`1004
`
`English Abstract of Hideji
`
`1005
`
`English translation of Hideji
`
`
`
`Description
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1006
`
`US. Patent 5,410,230 to Bessler, et al. (“Bessler”)
`
`1007
`
`1008
`
`“Electronic Control of Torque Ripple in Brushless Motors” by Peter
`Franz Kocybik (“Kocybik”)
`
`Excerpts from Paul C. Krause et al, Analysis of Electric Machinery
`and Drive Systems (2nd ed. 2002) (“Krause”)
`
`1009
`
`Expert Declaration of Dr. Mark Ehsani
`
`1010
`
`
`
`Complaint filed in Nidec Motor Corporation v. Broad Ocean Motor
`LLC et al., Civil Action No. 4:13-CV—01895-JCH (E. D. Mo.).
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`40866914.1
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`Case IPR2014-01121
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`Patent 7,626,349
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`I.
`
`INTRODUCTION
`
`Pursuant to 35 U.S.C. § 312 and 37 CPR. § 42.100 et seq., Zhongshan
`
`Broad Ocean Motor Co., Ltd., Broad Ocean Motor LLC, and Broad Ocean
`
`Technologies, LLC (collectively, “Petitioner”) request
`
`inter partes review of
`
`claims 1, 2, 3, 8, 9, 12, 16, and 19 (the “Challenged Claims”) of US. Patent No.
`
`7,626,349 (“the ’349 Patent,” Ex. 1001), which issued on December 1, 2009. The
`
`Board is authorized to deduct all required fees associated with this petition from
`
`Fulbright & Jaworski Deposit Account No. 06-23 80, under Order No. 11405494.
`
`The ‘349 Patent is generally directed to systems and methods for heating,
`
`ventilating and/or heating (“HVAC”)
`
`systems with a permanent magnet
`
`synchronous motor (“PM Motor”) that drives a fan or blower. More specifically,
`
`the PM Motor drive of the ‘349 Patent uses sine wave commutation and
`
`independent q- and d—axis currents to create continuous currents in the PM Motor’s
`
`windings.
`
`As demonstrated by various references discussed below and the declaration
`
`of Professor Mark Ehsani, long before the ‘349 Patent’s priority date, PM Motors
`
`using sine wave commutation and vector control (q- and d—axis currents) were well
`
`understood, developed, and used in a variety of industries, including HVAC. As
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`such, there is a reasonable likelihood that Petitioner will prevail on at least one of
`
`the challenged claims.
`
`II. MANDATORY NOTICES
`
`A.
`
`Real Party in Interest (37 C.F.R. § 42.8(b)(1))
`
`Zhongshan Broad Ocean Motor Co., Ltd., Broad Ocean Motor LLC, and
`
`Broad Ocean Technologies, LLC are the real parties-in-interest.
`
`B.
`
`Related Matters (37 C.F.R. § 42.8(b)(2))
`
`The following matter may affect, or be affected by, a decision in this
`
`proceeding: Nidec Motor Corporation v. Broad Ocean Motor LLC et 61]., Civil
`
`Action No. 4: 13-CV-01895-JCH (E. D. M0.) (the “Litigation”).
`
`C.
`
`Lead and Back-Up Counsel (37 C.F.R. § 42.8(b)(3))
`
`Lead counsel: Nathan J. Rees (Reg. No. 63,820)
`
`Back-up counsel: Daniel A. Prati (Reg. No. 65,869)
`
`D.
`
`Service Information (37 C.F.R. § 42.8(b)(4))
`
`Email: nate.rees@nortonrosefulbright.com
`
`Post: Nathan J. Rees, Fulbright & Jaworski L.L.P., 2200 Ross Avenue,
`
`Suite 2800, Dallas, TX 75201
`
`Phone: 214.855.7164
`
`Fax: 214.855.8200
`
`Petitioner consents to electronic service.
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`III. GROUNDS FOR STANDING
`
`Pursuant to 37 C.F.R. § 42.104(a), Petitioner certifies that the ‘349 Patent is
`
`available for inter partes review, and that Petitioner is not barred or estopped from
`
`requesting an inter partes review challenging the Challenged Claims on the
`
`grounds identified in this Petition. The ‘349 Patent has not been subject to a
`
`previous proceeding of the AIA that results in estoppel and the complaint served
`
`on Petitioner in the Litigation was served within the last 12 months.
`
`IV.
`
`STATEMENT OF PRECISE RELIEF REQUESTED FOR EACH
`
`CLAIM CHALLENGED
`
`A.
`
`Claims for Which Review is Requested (37 C.F.R. § 42.104(b)(1))
`
`Petitioner requests review and invalidation of claims 1-3, 8-9, 12, 16, and 19
`
`of the ‘349 Patent.
`
`B.
`
`Statutory Grounds of Challenge (37 C.F.R. § 42.104( b)(2))
`
`For the reasons presented below, Petitioner seeks the following relief:
`
`Ground 1: Invalidation of claims 1-3, 8-9, 12, 16, and 19 under 35 U.S.C. §
`
`102(b) based on Japanese Patent Publication JP 2003-348885 to Hideji (“Hideji”)
`
`(Ex. 1003). Hideji published in Japan on December 5, 2003, and is therefore prior
`
`art to the ‘349 Patth (whose priority date is February 1, 2007) at least under 35
`
`U.S.C. § 102(b).
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`Ground 2: Invalidation of claims 1-3, 8-9, 12, 16, and 19 under 35 U.S.C. §
`
`103(a) based on US. Patent 5,410,230 (Ex. 1004) to Bessler (“Bessler”) in view of
`
`Kocybik (Ex. 1005). Bessler issued as a US. patent on April 25, 1995, and is
`
`therefore prior art to the ‘349 Patent at least under 35 U.S.C. § 102(b). Kocybik
`
`published in the US. on July 2000, and is therefore prior art to the ‘349 Patent at
`
`least under 35 U.S.C. § 102(b).
`
`V.
`
`REASONS FOR THE RELIEF REQUESTED UNDER 37 CPR. §§
`42.22(a)(2) AND 42.104(b)(4)
`
`A.
`
`Background
`
`1.
`
`Declaration Evidence
`
`This Petition is supported by the declaration of Professor Mark Ehsani from
`
`Texas A&M University.
`
`(Ex. 1009). Dr. Ehsani offers his opinion with respect to
`
`the content and state of the prior art and the understanding of a person having
`
`ordinary skill in the art.
`
`Dr. Ehsani holds BS and MS degrees in electrical engineering fiom the
`
`University of Texas at Austin and a PhD.
`
`in Electrical Engineering from the
`
`University of Wisconsin—Madison. He is currently a tenured Professor in the
`
`Department of Electrical and Computer Engineering and the director of the Power
`
`Electronics and Motor Drives Laboratory and Advanced Vehicle Systems Research
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`Program at Texas A&M University.
`
`Dr. Ehsani has published over 370 papers in refereed conferences, and
`
`journals in the areas of energy systems, power electronics, motor drives, and
`
`electric and hybrid electric vehicles, and other areas of control, storage, and use of
`
`electric power and energy systems. He is also the co—author of 17 books on the
`
`above topics. During his over 33 years of employment at Texas A&M, Dr. Ehsani
`
`has originated and taught over eight different undergraduate and graduate electrical
`
`engineering courses on a variety of topics including power electronics, motor
`
`drives, DC power systems, electric and hybrid electric vehicles, sustainable energy
`
`and transportation systems, and industrial practice of electrical and computer
`
`engineering. Directly relevant to the ‘349 Patent, Dr. Ehsani first taught a class at
`
`Texas A&M University that covered vector control (using independent q- and d-
`
`axis currents) and sine wave commutation with PM Motor drives in 1985. See Ex.
`
`1009,1111.
`
`2.
`
`Prior Art Technology
`
`As evidenced by Dr. Ehsani’s declaration and the prior art references
`
`discussed below, by the ‘349’s 2007 priority date, motor controls for permanent
`
`magnet motors were well developed, understood and used in a variety of
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`applications. See Ex. 1009, 10. For example, a textbook by Dr. Krause, Analysis
`
`of Electric Machinery and Drive Systems (2nd ed. 2002) (“Krause”) (Ex. 1008)
`
`includes many equations
`
`and descriptions
`
`that describe the control
`
`and
`
`performance of permanent magnet motors.
`
`The ‘349 Patent includes the concept of vector control, which uses a rotating
`
`frame of reference and separates the current (and flux) provided to control the
`
`motor into a quadrature axis (“q-axis”) and a direct axis (“d-axis”). As explained
`
`in more detail the declaration of Dr. Ehsani, the use of vector control provides an
`
`analytical tool to control a permanent magnet motor to produce a commanded
`
`amount of torque or speed. See Ex. 1009, 111] 12-17. The ‘349 Patent also includes
`
`the concept of sine wave commutation, which relates to the waveforms of the
`
`currents that are fed to a PM Motor—they are sine waves, rather than square
`
`waves.
`
`Hideji (discussed below) discloses an HVAC system that uses a PM Motor
`
`that uses vector control and sine wave commutation. Bessler (also discussed
`
`below) discloses an HVAC system that uses a PM Motor. To the extent that
`
`Bessler does not disclose vector control or sine wave commutation, it would have
`
`been obvious to use well—known motor control concepts, which are disclosed in
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`Kocybik, with the PM Motors of Bessler. Therefore, the ‘349 claims are directed
`
`to teachings that were within the knowledge of one of ordinary skill in the art at the
`
`time of the invention and there is a reasonable likelihood that Petitioner will
`
`prevail on at least one of the challenged claims. A more detailed application of the
`
`prior art to the challenged claims is provided below in Section C.
`
`3.
`
`Prosecution History
`
`The ‘349 Patent was filed with 20 claims of which 3 were independent. Ex.
`
`1002, 30-49. Claims 1-15 were directed to an HVAC system, claims 16-18 were
`
`directed to a blower assembly, and claims 19-20 were directed to a method for
`
`driving an air-moving component of a HVAC system. Ex. 1002, 4144.
`
`In a non—final Office Action mailed February 26, 2009, all claims were
`
`rejected under 35 USC § 103 as being unpatentable over US. Pat. 5,410,230 to
`
`Bessler and US. Pat. 5,426,354 to Bausch. Ex. 1002, 20-24. The Office stated
`
`that Bessler taught every claim element except the use of a sine wave to control the
`
`motor system. Ex. 1002, 22. However, the Office found that Bausch taught the
`
`use of a sine waves to control a permanent magnet motor which rendered the
`
`claims obvious. Ex. 1002, 22.
`
`A response to the Office Action was filed on June 26, 2009 in which the
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`phrase “using independent values of q- and d— axis currents” was added to
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`independent claims 1, 16 and 19. Ex. 1002, 9-19. The Applicant argued that
`
`Bausch did not disclose or suggest a motor controller configured for performing
`
`sine wave commutation “using independent values of q and d axis to produce
`
`continuous currents.” Ex. 1002, 15-18.
`
`The Office mailed a Notice of Allowability on July 28, 2009 in which the
`
`examiner stated that
`
`the reasons for allowance were based on Applicant’s
`
`amendments and remarks in the response filed June 26, 2006. Ex. 1002, 3-7. The
`
`‘349 Patent issued on December 1, 2009. Ex. 1001.
`
`4.
`
`The ‘349 Patent
`
`The ‘349 Patent relates to an HVAC system that uses a permanent magnet
`
`motor that, in turn, uses sine wave commutation and independent q- and d— axis
`
`current control signals.
`
`The Background of the Invention section states that many HVAC systems
`
`used air-moving components (e.g. fans, blowers, etc.) and that those air-moving
`
`components were driven using variable speed electric motors. Ex. 1001, Col. 1:19-
`
`29. However, according to the ‘349 Patent, those variable speed motors were
`
`driven using “6-step” commutation, as opposed to using sine wave commutation.
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`Ex. 1001, Col. 1:30-47. As the ‘349 Patent explains, the known disadvantages of
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`6-step commutation included: 1) high cogging torque, 2) high torque ripple, and 3)
`
`lower efficiency. Ex. 1001, Col. 1:58-Col. 2:3.
`
`The ‘349 specification states that the HVAC system of the disclosure uses a
`
`permanent magnet motor and,
`
`in response to a control signal (such as from a
`
`thermostat), the permanent magnet motor uses sine wave commutation to produce
`
`continuous phase currents in the motor for driving an air-moving component (i.e. a
`
`fan). Ex. 1001, Col. 3:24-30.
`
`As described above in connection with the prosecution history, every
`
`independent claim of the ‘349 Patent includes the limitations of: 1) using sine wave
`
`commutation, and 2) using independent values of q- and d- axis currents.
`
`B.
`
`Claim Construction (37 C.F.R. § 42.104(b)(3))
`
`In an inter partes review, a claim in an unexpired patent
`
`is given the
`
`“broadest reasonable construction in light of the specification of the patent in
`
`which it appears.” 37 C.F.R. § 42.100(b). Petitioner therefore requests that the
`
`claim terms be given their broadest reasonable interpretation, as understood by one
`
`of ordinary skill in the art and consistent with the disclosure. See Office Patent
`
`Trial Practice Guide, 77 Fed. Reg. 48756, 48764 (Aug. 14, 2012). However,
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`because the district court may apply a different standard, the claim interpretations
`
`presented in this petition do not necessarily reflect the claim constructions that
`
`Petitioner believes should be adopted by the district court in the Litigation or any
`
`other proceeding. Petitioner does not concede that constructions offered in this
`
`petition,
`
`including
`
`constructions
`
`derived
`
`from that
`
`patentee’s
`
`apparent
`
`interpretations in the claims, should be adopted by the district court
`
`in the
`
`Litigation.
`
`Petitioner believes that the only phrase in claims 1-3, 8-9, 12, 16, and 19 that
`
`5
`requires claim construction is “back-emf motor.’ The phrase back-emf motor is
`
`not defined in the ‘349 specification and is not a term of art known to those skilled
`
`in the art. See Ex. 1009, 1] 43. All permanent magnet motors produce back emf
`
`when their rotors turn. Therefore, solely for the purposes of this inter partes
`
`review and to the extent that the phrase back-emf motor can be construed at all,
`
`“back-emf motor” should be construed to be coterminous with the phrase
`
`“permanent magnet motor.”
`
`Petitioner requests that the rest of the terms and phrases in claims 1-3, 8-9,
`
`12, 16, and 19 be given their broadest reasonable interpretation consistent with
`
`their plain and ordinary meaning.
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`C.
`
`The Challenged Claims Are Invalid Under 35 U.S.C. § 102(b)
`
`1.
`
`Ground 1 - Hideji
`
`Claims 1-3, 8-9, 12, 16, and 19 are anticipated under 35 U.S.C. § 102(b) by
`
`Hideji. Hideji generally describes an HVAC system that uses a permanent magnet
`
`motor using sine wave commutation and independent q- and d- axis current
`
`commands.
`
`See Ex. 1005. Hideji was not considered during the original
`
`prosecution of the ‘349 Patent, not is it cumulative of any prior art considered by
`
`the Examiner.
`
`The following discussion demonstrates, on a limitation-by-
`
`limitation bases, how claims 1-3, 8—9, 12, 16, and 19 of the ‘349 Patent are
`
`anticipated by Hideji.
`
`(a)
`
`Claim 1
`
`(1)
`
`“A heating, ventilating and/0r air conditioning
`(HVA C) system comprising”
`
`Hideji discloses an air conditioning system.
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hideji, 1] [0001]
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`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hideji, {I [0018]
`
`FIG.
`
`1
`
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hideji, 11 [0022]
`
`
`
`Hideji, FIG. 1
`
`See Ex. 1009, 11 33.
`
`(2)
`
`“a system controller”
`
`Hideji discloses a system controller because it discloses an HVAC system.
`
`Moreover, the target speed in FIG. 2 of Hideji comes from a system controller that
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`tells the motor controller the commanded speed of the motor.
`
`The speed control part 38 performs proportional integral control (PI
`
`control) based on the deviation between the speed of the rotor
`
`calculated by the rotor speed and position calculating part 37 and the
`
`target speed of the rotor every 1 ms, for example, to generate a torque
`
`current Iq target value.
`
`Hideji, 11 [0037]
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`3a
`‘\
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`1mm cum: Iqmwvuue
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`f
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`Hideji, FIG. 2
`
`See Ex. 1009, 11 34.
`
`To the extent the Patent Owner argues that Hideji does not disclose a system
`
`controller, it would have been obvious to one of ordinary skill in the art to use a
`
`system controller, such as a thermostat, with an HVAC system. Thermostats have
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`been used long before the ‘349 Patent’s priority date to control HVAC systems.
`
`See e.g. Bessler. See also EX. 1009, 1] 48.
`
`(3)
`
`“a motor controller”
`
`Hideji discloses a motor controller.
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hideji, 1] [0001]
`
`[T]he invention provides a method for controlling a permanent
`
`magnet synchronous motor, and for performing vector control on the
`
`permanent magnet synchronous motor in a sine wave driving mode
`
`Hideji, 1] [0006]
`
`FIG. 2 is a block diagram of a driving device for brushless DC
`
`motors.
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`Hideji, 1] [0028]
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`Each of brushless DC motors 30A and 30B includes a stator winding
`
`and a rotor of a permanent magnet which are not shown in the
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`diagram, and these brushless DC motors 30A and 30B are driven by a
`
`brushless DC motor driving device 50 respectively.
`
`Hideji,1[ [0029]
`
`«hath-g put
`
`mun 0pm! ud
`position
`
`Hideji, FIG. 2
`
`See Ex. 1009, ‘H 35.
`
`(4)
`
`“an air-moving component, and ”
`
`Hideji discloses an air-moving component.
`
`When a fan for heat exchange is driven, a part of three-phase
`
`alternating current is supplied to the brushless DC motor by a three-
`
`phase PWM inverter, converted to a revolving coordinate system of
`
`the rotor and used as flux current Id and torque current Iq. The position
`
`and revolving speed (revolutions) of the rotor are calculated through
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`Patent 7,626,349
`these currents, and drive control of the fan is performed on the basis
`
`of these calculated values.
`
`Hideji, 1] [0003]
`
`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hideji, 1] [0018]
`
`Moreover, an outdoor fan 20 which is driven by a brushless DC motor
`
`30A and blows air to the outdoor heat exchanger 19 is configured
`
`adjacent to the outdoor heat exchanger 19.
`
`Hideji, 1] [0025]
`
`An indoor fan 23 which is driven by a brushless DC motor 30B and
`
`blows air to the indoor heat exchanger 21 is configured adjacent to the
`
`indoor heat exchanger 21.
`
`Hideji, 1] [0026]
`
`See Hideji, FIG. 1.
`
`See Ex. 1009, 1] 36.
`
`(5)
`
`“a permanent magnet motor having a stationary
`assembly,
`a rotatable assembly in magnetic
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`Patent 7,626,349
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`coupling relation to the stationary assembly, and a
`shaft coupled to the air—moving component, ”
`
`Hideji discloses a permanent magnet motor, which includes a stator and a
`
`rotor. Furthermore, the rotor has a shaft that is coupled to a fan.
`
`The working state of a permanent magnet synchronous motor
`
`Hideji, Abstract
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hideji, 11 [0001]
`
`A brushless DC motor serving as a permanent magnet synchronous
`
`motor is provided with a stator winding and a rotor of a permanent
`
`magnet and is driven under the control of an inverter and the like.
`
`Hidejz', 1i [0002]
`
`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hidejz',1l [0018]
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`FIG.
`1
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hideji, 1] [0022]
`
`Moreover, an outdoor fan 20 which is driven by a brushless DC motor
`
`30A and blows air to the outdoor heat exchanger 19 is configured
`
`adjacent to the outdoor heat exchanger 19.
`
`Hidejz', 1] [0025]
`
`An indoor fan 23 which is driven by a brushless DC motor 308 and
`
`blows air to the indoor heat exchanger 21 is configured adjacent to the
`
`indoor heat exchanger 21.
`
`Hideji, 1] [0026]
`
`Each of brushless DC motors 30A and 30B includes a stator winding
`
`and a rotor of a permanent magnet which are not shown in the
`
`diagram, and these brushless DC motors 30A and 303 are driven by a
`
`brushless DC motor driving device 50 respectively.
`
`Hideji, 1] [0029]
`
`See Hidejz', FIGS. 1 and 2.
`
`40866914.1
`
`_1 8-
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`See Ex. 1009, 1] 37.
`
`(6)
`
`“wherein the motor controller is configured for
`performing
`sine wave
`commutation,
`using
`independent values of q- and d- axis currents,
`in
`response to one or more control signals received
`from the system controller to produce continuous
`phase currents in the permanent magnet motor for
`driving the air-moving component. ”
`
`Hideji performs sine wave commutation using independent values of q- and
`
`d- axis currents. Moreover, the sine wave commutation is performed in response
`
`to one or more signals from the system controller.
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hideji, 1] [0001]
`
`As known, these existing brushless DC motors are driven in a sine
`
`wave driving mode in the absence of sensors for detecting revolving
`
`speeds and positions of rotors. When a fan for heat exchange is
`
`driven, a part of three-phase alternating current is supplied to the
`
`brushless DC motor by a three—phase PWM inverter, converted to a
`
`40866914.1
`
`_19_
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`revolving coordinate system of the rotor and used as flux current Id
`
`and torque current Iq. The position and revolving speed (revolutions)
`
`of the rotor are calculated through these currents, and drive control of
`
`the fan is performed on the basis of these calculated values.
`
`Hidejz‘, 1] [0003]
`
`[T]he invention provides a method for controlling a permanent
`
`magnet synchronous motor, and for performing vector control on the
`
`permanent magnet synchronous motor in a sine wave driving mode
`
`Hideji, 1] [0006]
`
`The three-phase/two—phase coordinate conversion part 36 converts the
`
`coordinates of the alternating current
`
`Iu and Iv introduced by the
`
`current
`
`input part 35 to a revolving coordination system (d-q
`
`coordination system) on the rotor of the brushless DC motor 30A, and
`
`calculates flux current Id (d—axis current) and torque current Iq (q-axis
`
`current).
`
`Hideji, 1] [0035]
`
`See Hideji, FIG. 2.
`
`Ex. 1009, 11 38-40.
`
`40866914.1
`
`_20_
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`(b)
`
`Claim 2
`
`(1)
`
`“The HVAC system of claim 1 wherein the
`stationary assembly includes a plurality of phase
`windings and the motor controller is configured
`for energizing all of the phase windings at the
`same time. ”
`
`Hideji discloses a permanent magnet synchronous motor
`
`that has a
`
`stationary assembly (stator) that has a plurality of phase windings. In addition, the
`
`motor controller in Hideji is configured to energize all of the phase windings at the
`
`same time.
`
`A brushless DC motor serving as a permanent magnet synchronous
`
`motor is provided with a stator winding and a rotor of a permanent
`
`magnet and is driven under the control of an inverter and the like.
`
`Hideji, 1] [0002]
`
`As known, these existing brushless DC motors are driven in a sine
`
`wave driving mode in the absence of sensors for detecting revolving
`
`speeds and positions of rotors. When a fan for heat exchange is
`
`driven, a part of three-phase alternating current is supplied to the
`
`brushless DC motor by a three-phase PWM inverter...
`
`Hideji, 11 [0003]
`
`40866914.]
`
`_21_
`
`
`
`Case IPR2014-01 121
`
`Patent 7,626,349
`Each of brushless DC motors 30A and 30B includes a stator winding
`
`and a rotor of a permanent magnet which are not shown in the
`
`diagram, and these brushless DC motors 30A and 30B are driven by a
`
`brushless DC motor driving device 50 respectively.
`
`Hideji, 1| [0029]
`
`The brushless DC motor driving device 50 roughly includes a three-
`
`phase PWM inverter 31
`
`Hideji, 1] [0030]
`
`Thus, the three-phase PWM inverter 31 converts the direct current
`
`into alternating current having the assigned frequency and voltage
`
`corresponding to the working state of the brushless DC motor 30A,
`
`and the alternating current is supplied to the brushless DC motor 30A,
`
`so as to control the revolving speed and the like of the brushless DC
`
`motor 30A.
`
`Hideji, 1[ [0031]
`
`See Hideji, FIG. 2.
`
`See Ex. 1009, 11 41.
`
`(c)
`
`Claim 3
`
`40866914.]
`
`_22_
`
`
`
`Case IPR2014—01 121
`
`Patent 7,626,349
`
`(1)
`
`“The HVAC system of claim 2 wherein the
`continuous phase
`currents
`are
`substantially
`sinusoidal. ”
`
`The phase currents in Hideji are continuous and substantially sinusoidal.
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hideji, 1] [0001]
`
`As known, these existing brushless DC motors are driven in a sine
`
`wave driving mode
`
`Hideji, 1] [0003]
`
`[T]he invention provides a method for controlling a permanent
`
`magnet synchronous motor, and for performing vector control on the
`
`permanent magnet synchronous motor in a sine wave driving mode
`
`Hideji, 1] [0006]
`
`See Ex. 1009, 1] 40.
`
`((1)
`
`Claim 8
`
`(1)
`
`“The HVAC system of claim 3 wherein the
`permanent magnet motor is a brushless permanent
`
`408669141
`
`_23_
`
`
`
`Case IPR2014-01 121
`
`Patent 7,626,349
`
`magnet (BPM) motor. ”
`
`Hideji discloses that its motors can be brushless DC motors, which are
`
`brushless permanent magnet motors.
`
`A brushless DC motor serving as a permanent magnet synchronous
`
`motor is provided with a stator winding and a rotor of a permanent
`
`magnet and is driven under the control of an inverter and the like.
`
`Hideji, 1] [0002]
`
`FIG.
`
`1
`
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hideji, 1] [0022]
`
`Each of brushless DC motors 30A and 308 includes a stator winding
`
`and a rotor of a permanent magnet which are not shown in the
`
`diagram, and these brushless DC motors 30A and 30B are driven by a
`
`brushless DC motor driving device 50 respectively.
`
`Hideji, 1] [0029]
`
`See Ex. 1009, 1] 42.
`
`(e)
`
`Claim 9
`
`40866914.!
`
`_24_
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`(1)
`
`“The HVAC system of claim 8 wherein the BPM
`motor is a back-emePM motor ”
`
`The permanent magnet motors of Hideji create back emf when they turn.
`
`A brushless DC motor serving as a permanent magnet synchronous
`
`motor is provided with a stator winding and a rotor of a permanent
`
`magnet and is driven under the control of an inverter and the like.
`
`Hideji, 1] [0002]
`
`FIG.
`
`1
`
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hidejz', 1] [0022]
`
`Each of brushless DC motors 30A and 30B includes a stator winding
`
`and a rotor of a permanent magnet which are not shown in the
`
`diagram, and these brushless DC motors 30A and 30B are driven by a
`
`brushless DC motor driving device 50 respectively.
`
`Hideji, 1] [0029]
`
`See Hideji FIG. 1.
`
`See Ex. 1009, 1] 43.
`
`(1)
`
`Claim 12
`
`40866914.]
`
`_25_
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`(1)
`
`“The HVAC system of claim 3 wherein the at least
`one control signal from the system controller
`represents a desired torque or speed of the
`permanent magnet motor. ”
`
`Hideji discloses that the control signal is a desired speed.
`
`The speed control part 38 performs proportional integral control (PI
`
`control) based on the deviation between the speed of the rotor
`
`calculated by the rotor speed and position calculating part 37 and the
`
`target speed of the rotor every 1 ms, for example, to generate a torque
`
`current Iq target value.
`
`Hideji, 11 [0037]
`
`[T]he control device 34 of the brushless DC motor driving device 50
`
`judges whether a motor running command is formed or not based on
`
`the operation of an operator or the preset program (step 81).
`
`Hideji, 1] [0044]
`
`See Hidejz', FIG. 2.
`
`See Ex. 1009, 1} 44.
`
`(g)
`
`Claim 16
`
`(1)
`
`“A blower assembly for a heating, ventilating
`and/or air conditioning (HVAC)
`system,
`the
`blower assembly comprising ”
`
`408669l4.l
`
`~26-
`
`
`
`Case IPR20 14-01 121
`
`Patent 7,626,349
`Hideji discloses a fan for use in an HVAC system.
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device...
`
`Hideji, 11 [0001]
`
`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hideji, fl [0018]
`
`An indoor fan 23 which is driven by a brushless DC motor 30B and
`
`blows air to the indoor heat exchanger 21 is configured adjacent to the
`
`indoor heat exchanger 21.
`
`Hideji, 1[ [0026]
`
`FIG.
`
`1
`
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hideji, 1] [0022]
`
`See Hideji, FIG. 1.
`
`4086691“
`
`_27_
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`See Ex. 1009, 11 45.
`
`(2)
`
`“a motor controller”
`
`See above re Claim 1 for identical claim limitation.
`
`(3)
`
`“a blower”
`
`Hideji discloses the use of a fan with the indoor air conditioning unit, which
`
`is a blower.
`
`Hideji, 11 [0003]
`
`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hideji, 11 [0018]
`
`An indoor fan 23 which is driven by a brushless DC motor 30B and
`
`blows air to the indoor heat exchanger 21 is configured adjacent to the
`
`indoor heat exchanger 21.
`
`Hideji, 1] [0026]
`
`See Hideji, FIG. 1.
`
`See Ex. 1009, 1] 45.
`
`(4)
`
`“a permanent magnet motor having a stationary
`assembly,
`a rotatable assembly in magnetic
`
`408669l4.l
`
`-28-
`
`
`
`Case IPR2014-01121
`
`Patent 7,626,349
`
`coupling relation to the stationary assembly, and a
`shaft coupled to the blower, ”
`
`Hideji discloses a permanent magnet motor, which includes a stator and a
`
`rotor. Furthermore, the rotor has a shaft that is coupled to a fan.
`
`The working state of a permanent magnet synchronous motor
`
`Hideji, Abstract
`
`The present invention relates to a method and a device for controlling
`
`a permanent magnet synchronous motor and an air conditioning
`
`device,
`
`in particular to a technology for controlling a permanent
`
`magnet synchronous motor in a sine wave driving mode.
`
`Hidejz’, fl [0001]
`
`A brushless DC motor serving as a permanent magnet synchronous
`
`motor is provided with a stator winding and a rotor of a permanent
`
`magnet and is driven under the control of an inverter and the like.
`
`Hidejz', 1[ [0002]
`
`Moreover, an air conditioning device includes an indoor unit and an
`
`outdoor unit, characterized by also including: a permanent magnet
`
`synchronous motor used for driving a fan
`
`Hideji,1[ [0018]
`
`40866914.]
`
`_29_
`
`
`
`Case IPR2014-01 121
`
`Patent 7,626,349
`FIG.
`1
`is a diagram of a refrigerant circuit of an air conditioning
`
`device with a compressor driven by a permanent magnet synchronous
`
`motor (called as brushless DC motor below).
`
`Hideji, 1] [0022]
`
`An indoor fan 23 which is driven by a brushless DC motor 30B and
`
`blows air to the indoor heat exchanger 21 is configured adjacent to the
`
`indoor heat exchanger 21.
`
`Hideji, 1] [0026]
`
`Each of brushl