`___________________________
`
`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
`___________________________
`
`PETITIONER’S LISTING OF EXHIBITS
`
`NY 800703v.1
`
`
`
`LISTING OF EXHIBITS
`
`Exhibit No.
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`U.S. Patent No. 7,626,349
`
`Excerpts from the Prosecution History of Application 11/701,350,
`which issued as the ‘349 Patent
`
`Japanese Patent Publication JP 2003-348885 (“Hideji”)
`
`English Abstract of Hideji
`
`English Translation of Hideji
`
`U.S. Patent No. 5,410,230 to Bessler, et al. (“Bessler”)
`
`“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”)
`
`Expert Declaration of Dr. Mark Ehsani
`
`Complaint filed in Nidec Motor Corporation v. Broad Ocean Motor
`LLC et al., Civil Action No. 4:13 CV 01895 JCH (E.D. Mo.).
`
`Declaration of Charles S. Baker in Support of Motion for Admission
`Pro Hac Vice
`
`Declaration of Nathan J. Rees in Support of Motion to Submit a
`Corrected Exhibit and Maintain Filing Date Pursuant to 37 C.F.R.
`§42.104(c)
`
`Excerpts from the Deposition Transcript of Mark Ehsani, Ph.D.,
`taken April 24, 2015
`
`Rebuttal Declaration of Ivan T. Hoffman, CPA/CFF, CLP
`
`NY 800703v.1
`
`1
`
`
`
`Exhibit No.
`
`Description
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1022
`
`1023
`
`1024
`
`1025
`
`1026
`
`1027
`
`1028
`
`1029
`
`1030
`
`1031
`
`Deposition Testimony of Dr. Mark Ehsani, Ph. D., taken April 24,
`2015 (relied upon by Ivan T. Hoffman)
`
`Deposition Testimony of Christopher J. Bokhart , taken July 21,
`2015
`
`Energy.Gov Office of Energy Efficiency and Renewable Energy
`Chapter 3
`
`USPTO Patent Assignments for U.S. Patent 7,626,349
`
`Curriculum vitae and testimony of Ivan T. Hofmann, CPA/CFF,
`CLP
`
`Declaration of Ge Hu
`
`Deposition Testimony of John Filla, taken August 7, 2015 (Rough
`Draft) (relied upon by Ivan T. Hoffman)
`
`Deposition Testimony of Mark Carrier, taken August 6, 2015
`(Rough Draft) (relied upon by Ivan T. Hoffman)
`
`AHRI Shipments for Central Air Conditioners and Air-Source Heat
`Pumps
`
`AHRI Shipments for Gas Furnaces
`
`Comparison of Nidec HVAC Market Share and Nidec Share of
`ECM Sales to Nidec’s Shares Claimed in the Bokhart Declaration
`
`Complaint filed in Nidec Motor Corporation v. Broad Ocean Motor,
`LLC et al., Civil Action No. 2:15-cv-00443-JRG-RSP (E.D. TX.).
`
`Declaration of Alan F. Kessler
`
`Resume of Alan F. Kessler
`
`List of Documents Reviewed By Alan F. Kessler
`
`ECM Motor Versions/nomenclature
`
`NY 800703v.1
`
`2
`
`
`
`Exhibit No.
`
`Description
`
`1032
`
`1033
`
`1034
`
`1035
`
`1036
`
`1037
`
`1038
`
`Article by Acoustics By Design, Perception vs. Reality: What Our
`Ears Hear, Dec. 12, 2008
`
`Declaration of Charles S. Baker
`
`Project Authorization Request
`
`Project Authorization Request
`
`Motor Comparison Chart
`
`List of Nidec Patents that Cover Certain Motors
`
`Excerpts of Deposition Testimony of Mark Carrier, taken
`August 6, 2015 (Rough Draft) (cited to in Declaration of Charles
`S. Baker)
`
`Dated: August 21, 2015
`
`Respectfully submitted,
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 800703v.1
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e) and 37 C.F.R. §42.105(b), the undersigned
`hereby certifies that on August 21, 2015, a complete and entire copy of the
`foregoing Petitioner’s Listing Of Exhibits was electronically served in its entirety
`on
`the Patent Owner
`of
`record
`(as
`agreed
`upon
`by
`counsel)
`at
`sbrown@hoveywilliams.com,
`mwalters@hoveywilliams.com,
`and
`litigation@hoveywilliams.com.
`
`Additionally, the undersigned certifies that on August 21, 2015, a complete
`the foregoing Petitioner’s Listing Of Exhibits was
`and entire copy of
`electronically served on the Patent Owner’s below-listed counsel of record at
`jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`litigation Nidec Motor
`the
`syoo@thompsoncoburn.com,
`in
`co-pending
`Corporation
`v. Broad Ocean Motor LLC et
`al., Civil Action No.
`4:13-CV-01895-JCH (E.D. Mo.), as agreed upon by the parties.
`
`Dated: August 21, 2015
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 800703v.1
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