Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 1 of 12 PageID #: 1
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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 2 of 12 PageID #: 2
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CASE NO.
`
`JURY DEMAND
`
`NIDEC MOTOR CORPORATION,
`Plaintiff,
`
`v.
`
`BROAD OCEAN MOTOR LLC;
`
`BROAD OCEAN TECHNOLOGIES LLC;
`
`ZHONGSHAN BROAD OCEAN MOTOR
`CO. LTD; and
`
`MOTORS AND ARMATURES, INC.
`
`Defendants.
`
`3.
`
`Broad Ocean Technologies LLC is a corporation organized and existing under the laws of
`
`the State of Michigan that has engaged, and is engaging, in business in Texas and in this judicial
`
`district.
`
`[NOTE: The allegations in this paragraph will
`
`likely have evidentiary support after a reasonable
`
`opportunity for investigation and discovery].
`
`4.
`
`Zhongshan Broad Ocean Motor LLC is a Chinese corporation that has engaged, and is
`
`engaging, in business in the United States of America, Texas, and in this judicial district. [NOTE:
`
`The allegations in this paragraph will likely have evidentiary support after a reasonable opportunity for investigation
`
`and discovery].
`
`5.
`
`Motors & Armatures, Inc. is a corporation organized and existing under the laws of the
`
`State of New York that has engaged, and is engaging, in business in Texas and in this judicial
`
`district.
`
`[NOTE: The allegations in this paragraph will
`
`likely have evidentiary support after a reasonable
`
`ORIGINAL COMPLAINT
`
`opportunity for investigation and discovery].
`
`Plaintiff Nidec Motor Corporation (“NMC”), through its attorneys, files this complaint
`
`against defendants Broad Ocean Motor LLC, Broad Ocean Technologies LLC and Zhongshan
`
`Broad Ocean Motor Co., Ltd. (collectively “Broad Ocean”) and Motors & Armatures, Inc.
`
`(“MARS”) and hereby alleges as follows:
`
`I. PARTIES
`
`1.
`
`Plaintiff NMC is a corporation organized and existing under the laws of the state of
`
`Delaware.
`
`II. JURISDICTION AND VENUE
`
`6.
`
`This is an action for infringement of several United States patents, and arises under the
`
`patent laws of the United States, 35 U.S.C. § 271, et. seq. This Court has exclusive subject matter
`
`jurisdiction of such action under 28 U.S.C. §§ 1331 and 1338(a)
`
`7.
`
`This Court has personal jurisdiction over Broad Ocean and MARS by virtue of Broad
`
`Ocean and MARS’ regular commercial and business activities within and/or directed to the State of
`
`2.
`
`Broad Ocean Motor LLC is a corporation organized and existing under the laws of the
`
`State of Delaware that has engaged, and is engaging, in business in Texas and in this judicial district.
`
`Texas.
`
`8.
`
`Venue is proper before this Court pursuant to 28 U.S.C. § 1391(b) and (c) and 28 U.S.C.
`
`[NOTE: The allegations in this paragraph will likely have evidentiary support after a reasonable opportunity for
`
`§ 1400(b).
`
`investigation and discovery].
`
`1
`
`2
`
`BOM Exhibit 1027
`BOM v. Nidec
`IPR2014-01121
`
`1
`
`

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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 3 of 12 PageID #: 3
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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 4 of 12 PageID #: 4
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`COUNT I
`
`INFRINGEMENT OF U.S. PATENT NO. 5,818,194
`
`15.
`
`In addition to direct and contributory infringement of the ‘194 Patent through their acts
`
`associated with the Infringing Broad Ocean Motors, Broad Ocean and MARS sell motors that,
`
`9.
`
`On October 6, 1998, United States Patent No. 5,818,194 (the “’194 Patent”) was duly and
`
`when used as intended by Broad Ocean and MARS and in accordance with instructions provided
`
`legally issued for “Direct Replacement Variable Speed Blower Motor.” A true and correct copy of
`
`by Broad Ocean and MARS, directly infringe the ‘194 Patent. As such, Broad Ocean and MARS
`
`the ’194 Patent is attached hereto as Exhibit A and made a part hereof.
`
`have induced infringement of the ‘194 Patent.
`
`10.
`
`NMC is the assignee and owner of all rights and title to the ’194 Patent, with the exclusive
`
`16.
`
`Broad Ocean and MARS and/or individuals within Broad Ocean’s or MARS’ employ had
`
`right to enforce the patent against infringers and to sue for and collect damages for all relevant
`
`knowledge of the ’194 Patent prior to the filing of the Original Complaint in this action. [NOTE:
`
`times, including the right to assert the present cause of action.
`
`The allegations advanced in this paragraph will likely have evidentiary support after a reasonable opportunity for
`
`11.
`
`Broad Ocean manufactures, makes, has made, uses, practices, imports, provides, supplies,
`
`investigation and discovery].
`
`distributes, sells and/or offers for sale products, including but not limited to ECM drop-in
`
`17.
`
`Broad Ocean’s and MARS’ infringement of the ’194 Patent was and is willful. Despite
`
`replacements for PSC blower motors, that directly infringe one or more claims in the ’194 Patent.
`
`knowing of the ‘194 Patent, Broad Ocean and MARS engaged in, and continue to engage in, acts
`
`12.
`
`MARS uses, practices, imports, provides, supplies, distributes, sells and/or offers for sale
`
`that infringe the ‘194 Patent.
`
`products, including but not limited to ECM drop-in replacements for PSC blower motors, that
`
`18.
`
`At all relevant times, NMC has complied with any marking and/or notice provisions of 35
`
`directly infringe one or more claims in the ’194 Patent.
`
`U.S.C. § 287 with respect to the ’194 Patent. Among other things, NMC has marked products
`
`13.
`
`Broad Ocean and MARS’ products that directly infringe the ’194 Patent include but are not
`
`utilizing the subject matter of the ‘194 Patent with the number of the ‘194 Patent. As an example,
`
`limited to the Broad Ocean AZURE DIGI-MOTORs that are - alone or in combination with an
`
`photographs of NMC’s RESCUE EcoTech® motor bearing the number of the ‘194 Patent are
`
`external device - capable of operating in a PSC mode (collectively the “Infringing Broad Ocean
`
`provided below:
`
`Motors”). Infringing Broad Ocean Motors are believed to include, but are not limited to, the
`
`products associated with the following MARS product numbers: MARS No. 08025; MARS 08026
`
`and MARS 08027.
`
`14.
`
`In addition to directly infringing the ’194 Patent, Broad Ocean and MARS have contributed
`
`to infringement of one or more claims of the ’194 Patent because the Infringing Broad Ocean
`
`Motors include features that are especially adapted for infringement and there are no substantial
`
`non-infringing uses for the infringing features.
`
`3
`
`4
`
`2
`
`

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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 6 of 12 PageID #: 6
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`19.
`
`NMC has been damaged as a result of Broad Ocean’s and MARS’ infringing conduct with
`
`respect to the ‘194 Patent. Each of Broad Ocean and MARS is, thus, liable to NMC in an amount
`
`that adequately compensates it for Broad Ocean’s and MARS’ 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.
`
`20.
`
`Broad Ocean and MARS will continue their infringement of the ’194 Patent unless
`
`enjoined by the Court. Broad Ocean’s and MARS’ infringing conduct has caused NMC irreparable
`
`harm and will continue to cause such harm without the issuance of an injunction.
`
`COUNT II
`
`INFRINGEMENT OF U.S. PATENT NO. 7,990,092
`
`21.
`
`On August 2, 2011, United States Patent No. 7,990,092 (the “’092 Patent”) was duly and
`
`legally issued for “Blower Motor for HVAC Systems.” A true and correct copy of the ’092 Patent is
`
`attached hereto as Exhibit B and made a part hereof.
`
`22.
`
`NMC is the assignee and owner of all rights and title to the ’092 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.
`
`5
`
`23.
`
`Broad Ocean manufactures, makes, has made, uses, practices, imports, provides, supplies,
`
`distributes, sells and/or offers for sale products, including but not limited to ECM drop-in
`
`replacements for PSC blower motors, that directly infringe one or more claims in the ’092 Patent.
`
`24.
`
`MARS uses, practices, imports, provides, supplies, distributes, sells and/or offers for sale
`
`products, including but not limited to ECM drop-in replacements for PSC blower motors, that
`
`directly infringe one or more claims in the ’092 Patent.
`
`25.
`
`Broad Ocean and MARS’ products that directly infringe the ’092 Patent include but are
`
`not limited to the Infringing Broad Ocean Motors.
`
`26.
`
`In addition to directly infringing the ’092 Patent, Broad Ocean and MARS have
`
`contributed to infringement of one or more claims of the ’092 Patent because the Infringing Broad
`
`Ocean Motors include features that are especially adapted for infringement and there are no
`
`substantial non-infringing uses for the infringing features.
`
`27.
`
`In addition to direct and contributory infringement of the ‘092 Patent through their acts
`
`associated with the Infringing Broad Ocean Motors, Broad Ocean and MARS sell motors that,
`
`when used as intended by Broad Ocean and MARS and in accordance with instructions provided
`
`by Broad Ocean and MARS, directly infringe the ‘092 Patent. As such, Broad Ocean and MARS
`
`have induced infringement of the ‘092 Patent.
`
`28.
`
`Broad Ocean and MARS and/or individuals within Broad Ocean’s and MARS’ employ
`
`had knowledge of the ’092 Patent prior to the filing of the Original Complaint in this action.
`
`[NOTE: The allegations in this paragraph will likely have evidentiary support after a reasonable opportunity for
`
`investigation and discovery].
`
`29.
`
`Broad Ocean’s and MARS’ infringement of the ’092 Patent was and is willful. Despite
`
`knowing of the ‘092 Patent, Broad Ocean and MARS engaged in, and continue to engage in, acts
`
`that infringe the ‘092 Patent.
`
`6
`
`3
`
`

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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 8 of 12 PageID #: 8
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`30.
`
`At all relevant times, NMC has complied with any marking and/or notice provisions of 35
`
`33.
`
`On November 1, 2011, United States Patent No. 8,049,459 (the “’459 Patent”) was duly
`
`U.S.C. § 287 with respect to the ’092 Patent. Among other things, NMC has marked products
`
`and legally issued for “Blower Motor for HVAC Systems.” A true and correct copy of the ’459
`
`utilizing the subject matter of the ‘092 Patent with the number of the ‘092 Patent. As an example,
`
`Patent is attached hereto as Exhibit C and made a part hereof.
`
`photographs of NMC’s RESCUE EcoTech® motor bearing the number of the ‘092 Patent are
`
`34.
`
`Broad Ocean manufactures, makes, has made, uses, practices, imports, provides, supplies,
`
`provided below:
`
`31.
`
`NMC has been damaged as a result of Broad Ocean’s and MARS’ infringing conduct with
`
`respect to the ‘092 Patent. Each of Broad Ocean and MARS is therefore liable to NMC in an
`
`amount that adequately compensates it for Broad Ocean’s and MARS’ 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.
`
`32.
`
`Broad Ocean and MARS will continue their infringement of the ’092 Patent unless
`
`enjoined by the Court. Broad Ocean’s and MARS’ infringing conduct causes NMC irreparable harm
`
`and will continue to cause such harm without the issuance of an injunction.
`
`COUNT III
`
`INFRINGEMENT OF U.S. PATENT NO. 8,049,459
`
`7
`
`distributes, sells and/or offers for sale products, including but not limited to ECM drop-in
`
`replacements for PSC blower motors, that directly infringe one or more claims in the ’459 Patent.
`
`35.
`
`MARS uses, practices, imports, provides, supplies, distributes, sells and/or offers for sale
`
`products, including but not limited to ECM drop-in replacements for PSC blower motors, that
`
`directly infringe one or more claims in the ’459 Patent.
`
`36.
`
`Broad Ocean and MARS’ products that directly infringe the ’459 Patent include but are
`
`not limited to the Infringing Broad Ocean Motors.
`
`37.
`
`In addition to directly infringing the ’459 Patent, Broad Ocean and MARS have contributed
`
`to infringement of one or more claims of the ’459 Patent because the Infringing Broad Ocean
`
`Motors include features that are especially adapted for infringement and there are no substantial
`
`non-infringing uses for the infringing features.
`
`38.
`
`In addition to direct and contributory infringement of the ‘459 Patent through their acts
`
`associated with the Infringing Broad Ocean Motors, Broad Ocean and MARS sell motors that,
`
`when used as intended by Broad Ocean and MARS and in accordance with instructions provided
`
`by Broad Ocean and MARS, directly infringe the ’459 Patent. As such, Broad Ocean and MARS
`
`have induced infringement of the ’459 Patent.
`
`39.
`
`Broad Ocean and MARS and/or individuals within Broad Ocean’s and MARS’ employ
`
`had knowledge of the ’459 Patent prior to the filing of the Original Complaint in this action.
`
`[NOTE: The allegations advanced in this paragraph will likely have evidentiary support after a reasonable
`
`opportunity for investigation and discovery].
`
`8
`
`4
`
`

`
`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 9 of 12 PageID #: 9
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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 10 of 12 PageID #: 10
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`40.
`
`Broad Ocean’s and MARS’ infringement of the ’459 Patent was and is willful. Despite
`
`knowing of the ‘459 Patent, Broad Ocean and MARS engaged in, and continue to engage in, acts
`
`IV
`
`JURY DEMAND
`
`that infringe the ‘459 Patent.
`
`NMC hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of Civil
`
`41.
`
`At all relevant times, NMC has complied with any marking and/or notice provisions of 35
`
`Procedure.
`
`U.S.C. § 287 with respect to the ’459 Patent.
`
`42.
`
`NMC has been damaged as a result of Broad Ocean and MARS’ infringing conduct with
`
`respect to the ‘459 Patent. Each of Broad Ocean and MARS is therefore liable to NMC in an
`
`amount that adequately compensates it for Broad Ocean’s and MARS’ 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.
`
`43.
`
`Broad Ocean and MARs will continue their infringement of the ’459 Patent unless
`
`enjoined by the Court. Broad Ocean’s and MARS’ infringing conduct causes NMC irreparable harm
`
`and will continue to cause such harm without the issuance of an injunction.
`
`9
`
`10
`
`5
`
`

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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 11 of 12 PageID #: 11
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`Case 2:15-cv-00443-JRG-RSP Document 1 Filed 03/27/15 Page 12 of 12 PageID #: 12
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`PRAYER FOR RELIEF
`
`March 27, 2015
`
`/s/_Robert J. McAughan, Jr.___________
`Robert J. McAughan, Jr.
`Attorney In Charge
`TX State Bar No. 00786096
`bmcaughan@smd-iplaw.com
`David L. Terrell
`TX. State Bar No. 24063030
`dterrell@smd-iplaw.com
`SUTTON MCAUGHAN DEAVER PLLC
`Three Riverway, Suite 900
`Houston, TX 77056
`(713) 800-5700 (T)
`(713) 800-5699 (F)
`
`AttorneysforPlaintiffNidecMotor
`Corporation
`
`THEREFORE, NMC respectfully requests that this Court enter judgment in its favor and
`
`grant NMC the following relief:
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Judgment that one or more claims of the ‘194,
`
`‘092 and/or ‘459 Patents have been
`
`infringed, either literally and/or under the doctrine of equivalents, by Defendants and/or
`
`by others to whose infringement Defendants have contributed and/or by others whose
`
`infringement has been induced by Defendants;
`
`That Defendants’ infringement be found to be willful from the time Defendants became
`
`aware of the infringing nature of its products, which was prior to the time of filing of
`
`Plaintiff’s Original Complaint, and that the Court treble damages for the period of such
`
`willful infringement pursuant to 325 U.S.C. § 284;
`
`That NMC be granted pre-judgment and post-judgment interest on the damages caused to
`
`it by reason of Defendant’s infringing activities and other conduct complained of herein;
`
`That this Court declare this an exceptional case and award NMC 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 patent-in-suit; and
`
`That NMC 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 an
`
`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.
`
`11
`
`12
`
`6
`
`

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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 1 of 13 PageID #: 13
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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 2 of 13 PageID #: 14
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`Case 2:15-cv-00443-JRG-RSP Document
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`US{|(l5HIH|‘)-1.-'\
`
`13
`
`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 2 of 13 PageID #: 14
`
`United States Patent
`Nordhy
`
`119]
`
`l’ate11t Number:
`1.1]
`145] Date of Patent:
`
`5,818,194
`Oct. 6, 1998
`
`U.S. Patent
`
`01:115. 1998
`
`Sheet 1 are
`
`5,818,194
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`
`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 3 of 13 PageID #: 15
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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 4 of 13 PageID #: 16
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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 3 of 13 PageID #: 15
`
`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 4 of 13 PageID #: 16
`
`U.S. Patent
`
`Oct. 6, 1993
`
`Sheet 2 016
`
`5,818,194
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`U.S. Patent
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`Oct. 6, 1993
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`Sheet 3 off:
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`5,818,194
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`NMC000003
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`U.S. Patent
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`on. 6, 1993
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`Sheet 4 ul‘ 6
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`5,818,194
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`U.S. Patent
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`Oct. 6, 1998
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`Sheet 5 ul‘ 6
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`5,818,194
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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 7 of 13 PageID #: 19
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`Case 2:15-cv-00443-JRG-RSP Document 1-1 Filed 03/27/15 Page 8 of 13 PageID #: 20
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`U.S. Patent
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`Oct. 6, 1993
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`Sheet 6 of 6
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`5,813,194
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`DIGITAL
`REF .
`SOURCE
`
`MA‘
`
`14B].
`
`BUFFER
`
`UIC2
`
`BUFFEFI
`
`DIGITAL
`TU
`ANALOG
`CONVERTER
`DAC1
`
`NMC000007
`
`1
`l)IREL'l‘ Rl'lI'l.t\Cl‘1l\-IENT \'Al{Ir'\lil.I'l SPEICI)
`l‘|I.(‘JWI‘}R |\-I(‘J’ll0R
`iir‘\('I([}R()UN|) ()1-'
`'l‘ill:'. INV l.ZN'i'I()N
`l. I-'ield of the Invention
`'l‘hi< invention relates to motor xx-ntrnls used in resnlential
`heating. ventilation. and air conditioning [I-IV"r’\(_'] .-systernts.
`and more particularly to it direct replacement motor control
`having an improved variable speed control and which is
`designed to he conrtectt.-Li to the stantlard power termi
`.-
`used [or a permanent split capacitor (PSCJ motor. while
`eliminating the need for extra control signals and also to a
`method oieontrolling a variable-speed motor.
`3. Brief Description of the Prior Art
`Blower rrrntors used in residential |I\-'3-‘\(' systems tradi-
`tionally use l’S(.‘ nl(:Iot‘.*'u. 'I't1t:.-:4: tttrtlttts generally have two
`independent power connection-5 to accommodate heating or
`cooling n1orJt'.~.- of operation. The heating or cooling power
`inputs are normally cortnected to different winding taps in
`the PSC motor to provide somewhat
`tlillerent operating
`speeds for the blower in the respective modes ofopcration.
`More than two sets of taps can be designed into the PSC
`motor. allowing the OEM or installer to select the operating
`speed by appropriate connection of the taps to the respective
`heating and cooling power connections. The energizing of
`these AC‘ power connections to the motor is controlled by
`activation of a temperature switch and a relay driven from
`the thermostat.
`Atypical configuration ofa lixcd speed H\-';‘\C motor used '
`in residential systems is shown in 1-'lLi. 1.
`In this
`conllguration. the single phase AC suppiy voltage (normally
`US \«''.I'\(.‘ or 230 \«"A('.‘) is supplied by connections [.1 and N.
`where |.l represents the hot side of the At? supply, and N is
`the neutral. which is at eanh potential in it typicai Il5 VAK‘ "
`residential distribution system.
`[In normal 230 VAC
`systerrts. instead of a neutral line N. another hot supply line
`would be substituted. instead.) The power to the motor is
`controlled by a relay R1 and a switch S1. ln FIG. 1. relay RI
`and switch 31 are both shown in their nort-energized posi-
`tions.
`The blower relay is controlled by the thermostat. [n the
`position shown in FIG. 1. which is the normal position for
`the heating mode of operation. A{‘ voltage l5 supplied to the
`LIH motor connection any time fan control switch S1
`closes. The fan control switch S1 closes whenever the air
`temperature in the heat exchanger exceeds a predetermined
`setpoint. l-'or a gas Furnaee system, this happens when the
`gas bumer is activated by signals from a Ih-rmostat. When
`fan control switch S1 closes, AC power is supplied to the '
`motor Ml, which will then start and run. 'lhe speed of motor
`MI is a function cl‘ motor design, tap selection in the motor,
`
`--
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`5,818,194
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`2
`Today. stale-ol‘-the an ll\«"r‘\(.‘ systems use electronic vari-
`able spced motor controllers The standard approach for
`implementing variable speed motors is dilferent from and
`generally more complex than the system used for listed
`speed motors. Atypical interconnection diagram for a vari-
`able speed motor system is shown in I-16. 2. Single phase
`AC power is supplied through a connection of l.l and N.
`'Ilti.e. prim is nzetili:-.t.t via a I'uIl—wave bridge rectitiur circuit
`comprising diodes IJI. I)2. EJ3. and D4 to supply a lJ(.‘ bus
`voltage tn a eoutverlet module VSt"l. The I)(‘ pottilit-'¢
`voltage is supplied at DCP. while the D(' negative voltage is
`supplied at
`IJ(‘N. The varialstt: speed enntrol and potvet‘
`converter module VSCI tran:sl'orrrLs the DC potential into the
`appropriate output voltage and current waveforms fur the
`.' dynamoelectric machine M2. An important consideration is
`that mmmort
`litr the control circuitry lor power converter
`\.-‘SCI is connected to the negative DC bus DCN to simplify
`the voltage and current sensing circuitry. and for ease of
`implementing the power semiconductor driver circuitry in
`VSCI. The system common SC (as distinguished from the
`eommort of power converter VSCI) is generally connected
`to eanh ground.
`(Tontrol sigttals (in addition to power connections} are fed
`into the powerconverter VSCI I.hrough an electrical isolator
`I l and typically include cool and lteul eontntancls on separate
`connections (‘C and II(.'. respectively. A themtostat or other
`type of system controller [not shown in l-'[[‘-. 2) supplies
`these signals, which are normally :4 V.-‘\(‘ or less. A variety
`of electrical prntoenls may he used, e.g_, 24 Vr‘\(.‘ nn—oll'
`signal.-t from the thermostat. or 5 nr
`I2 V tliscrcte logic
`signals from an electronic system controller. "ilk: common
`potential (system ctmirrrun SC) for these signalzs is at eanh
`ground for safety reasons. which means that
`there is a
`potential difference between the command signals appearing
`at IIT(.‘ and Ill? and the variable speed control and power
`converter \"'S(.'l circuits, the latter being referenced to the
`|)L.‘N potential. These twn commons cannot be connected
`(shorted), so an electrical isolation module ll is provided to
`couple the control signals at III.‘ and II(.‘ to power converter
`\"'5{.'l, while isolating the potential between the two sets of
`t.'it\.'tJiL~i.
`While va riablc speed systems similar to the one illustrated
`in FIG. 2 work satisI'actorily. changing a standard fixed
`speed motor in a system ofa type similar to that illustrated
`NMC000008
`in FIG. 1 has required changes in the mechanical. wiring. or
`'l‘he difliculty and
`control configuration of the system.
`exp-eme of making such changes has made it impractical, in
`many installations.
`to realize the energy efficiency and
`comfort advantages that may he realized through the use of
`variable speed motor technology in an ll\"'.M.‘ system. It
`would tlterefrtrt: he desirable tn provide a “drop in“ replace-
`ment til‘ at
`l’S(‘ rrlotur in an ll\-'.x\(‘ system tn re
`these
`advantages without requiring changes to the IIVAC ystem.
`
`10
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`5,818,194
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`3
`the selection depending upon which of the lirst and the
`second current
`inputs is supplying operating power to the
`motor: and a reference source forsupplying the at least a pair
`of tvferehra: signals to the multiplexing ut1il.'|'he multiplex-
`ing unit may comprh: a power source sensor which may be
`either a vollagrl (potential) serrsing unit or a current flow
`sensing unil. As will he described in detail below, whether
`a voltage or a current sensing unit is provided. significant
`accuracy is not required, so (hr: cost of the sensing cire'uit.ry
`can he made quiIel<1w.\=\-“l-mnthis l.‘lI‘L
`_
`s pmvinied with
`a variable speed motor having dimension-5 similar to lhat of
`a standard PSC motor used in residential llVAt‘_~.y.~:teras. the
`resulting variable speed blower motor replacement unit. can
`he used as a “:trup—in" rrplaucmrat for thc PERT motor. in
`that the replacement unit requires only the same electrical
`connections‘ as the original PSC mulor.
`input"
`It stnuld be understood that
`the term "current
`rcfers to a connection on the device that can be connected to
`a current source. However. it should also be understood that
`it could alternately be connected to any source capable of
`supplying power to the motor. For example, a "current
`input” could be connected to a voltage source capable of
`supplying the necessary power to run the motor. Of course.
`it will be understood that current would be dravm from the
`voltage source to supply the necessary power to run the -
`motor. For notational convenience. the len'rr "power input”
`is used to refer to the set of"eurrent inputs.“
`It should lll.‘:'-Lt he understood that this invention is not
`limited to ruptacentent t.L‘4:, but may also he used in (JEN!
`applications.
`It is therefore an object oflhe present invention to provide
`a low-cost variable speed replaeentent unit for a standard
`Iixed speed motor of the type used in a residential I-l\-‘AC
`system.
`It is also an object of the invention to provide it replttee— '
`ment variable speed control system in an HVAC‘ system
`without requiring changes to mechanical ooniiguratioris.
`wiring. or control of the }l\-".r\C system.
`It is a still further object at‘ the irrvcntinn to provide an
`after-market variable speed unit
`that may he used are
`a
`drup-in replacement for at PS(‘ l'|1(IItll'.
`It E yet another object of the invention to providc a
`drop-in replacemc nt ofa PSC motor in an HVAC system that
`will rcaliace thc efficiency and comfort advantages of vari-
`able specd motor control in I-IVAC systems.
`It is yet an adr.|itiunaluhjur.1 nfthe invention to pruvidc a
`variable speed replacement unit for a FSC motor that
`ms
`simple control circuits and reduces or eliminates the n
`it for
`the additional wiring commonly used with variable speed _
`motors.
`It
`is still another object of the invention to provide an
`allermtivr: to a }’5\‘l..‘ motor in [[\«’.M? systems to provide for
`
`4
`FIG. -I is a schematic diagram of a modified rectifier
`circuit suitable for use with the invention.
`FIG. 5 is a schematic diagram ofa current scnsingsystem
`suitable for use with the invention.
`FIG. 6 is a detailed schematic diagram of a voltage
`sensing and multiplexing unit in accordance with one aspect
`of the invention.
`FIG. '.i' is a schematic block diagram of an embodiment of
`the invention employing a lllnclion generator to supply a
`reference signal.
`FIG. 8 is a schematic block diagram of a current sensing
`unit in accordance with another respect of the invention.
`I-'I(i. 9 is a schematic hluck diagram nt‘ a digital reference
`.' and multiplexing unit i.r1 accordance with another aspect of
`the invention.
`[)l;"I‘A|l.|_-'I) DI.-'.*i(.‘l{||"|'l(JN [ll'”11lI_"
`I-’l{|."l-'lSRRL-LI) I;'MBt'llJlMl:'.N'l'S
`Referring now to FIG. 3. an embodiment of the invention
`is shown generally at [0, shown here as a drop-in replace-
`ment for that portion of FIG.
`I cnclusect by the rectangle
`HM. ‘Ila: embodiment ll] of the invention in FIG. 3 com-
`prises a rcetitivr 12. a system [4 which includes a multi-
`' pleating unit and a reference source, and a variable speed
`mntnr M3. A standard varialilc speed control and power‘
`converter 16 provides variable speed operation for motor
`M3 and may be eon.-aidcred as a part nr that motor For the
`purposes of this invention. Power to the embodirncnl
`ll]
`shown in FIG. I is provided via the slime scl of connedions
`provided to a PSC motor. i.e.. LIC. L1H and neutral N. as
`shown in FIG. 3. as would he expected for a drop-in
`replacement element. {It is convenient. from the standpoint
`of tenninolrgy, to refer collcmivcly to this set of connections
`as a "poweri1'IpI.I1.") Df eourfal. it will he rInL‘og,ni1Jr:rI that the
`inventive motor speed control system comprising elements
`I2. 14 and 16 isseparalely useful without the motor, both for
`OEM and for replacement use. such as for use with any
`suitalllr: motor M3.
`In accordance with the invention, at least one signal from
`an A(‘ source (connected to either |.l(.‘ or [Jill is sensed
`and converted to a logic level signal. Wsltagc (potential)
`sensing may be used. or altvmalcly. current {flow} sensing
`_ may be used. Since the sensing scheme is used only to detect
`NMC000009
`the pre.-=1:rn:= ur a'b.-ounce of voltage or cum:nt on the sensed
`line and does not require any significant accuracy. the cost
`of either type of.-aense circuitry can be made very low.
`l