DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`NORMAN INTERNATIONAL, INC.
`
`Petitioner
`
`v.
`
`HUNTER DOUGLAS, INC., ANDREW J. TOTI TESTAMENTARY TRUST,
`RUSSELL L. HINCKLEY, SR. (CO-TRUSTEE), and ROBERT F. MILLER
`(CO-TRUSTEE)
`
`Patent Owner
`
`_________________________
`
`CASE: To Be Assigned
`
`Patent No. 6,283,192 B1
`
`_________________________
`
`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`
`
`
`
`
`Norman Int. Exhibit 1006
`
`

`

`
`
`
`
`TABLE OF CONTENTS
`
`Page
`
`INTRODUCTION ........................................................................................... 1
`I.
`SUMMARY OF OPINIONS ........................................................................... 2
`II.
`III. QUALIFICATIONS AND EXPERIENCE ..................................................... 4
`A.
`Education and Work Experience ................................................................ 4
`B.
`Compensation ............................................................................................. 8
`C.
`Documents and Other Materials Relied Upon ........................................... 8
`IV. STATEMENT OF LEGAL PRINCIPLES ...................................................... 8
`A.
`Claim Construction ..................................................................................... 8
`B.
`Obviousness ................................................................................................ 9
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 10
`VI. TECHNOLOGY BACKGROUND OF CLAIMED SUBJECT MATTER OF
`THE 192 PATENT ........................................................................................ 12
`Spring Drives ............................................................................................ 12
`A.
`Transmissions ........................................................................................... 15
`B.
`Bevel Gears ............................................................................................... 17
`C.
`Combinations of Design Components ...................................................... 18
`D.
`VII. OVERVIEW OF THE 192 PATENT ............................................................ 19
`VIII. IDENTIFICATION OF THE PRIOR ART .................................................. 20
`IX. CLAIM CONSTRUCTION .......................................................................... 24
`A. “Window cover” .............................................................................................. 25
`B. “Housing” ........................................................................................................ 25
`C. “Lift cord” ........................................................................................................ 26
`D. “Pulley” ............................................................................................................ 26
`E. “Spring drive system” ...................................................................................... 27
`F. “Flat spring” ..................................................................................................... 27
`G. “Substantially flat spring” ............................................................................... 28
`H. “Rotatable end” and “Output end” .................................................................. 28
`I. “Storage end” and “Storage Spool” .................................................................. 29
`J. “Bevel gear set” and “Pair of meshed bevel gears” .......................................... 29
`
`-i-
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`Norman Int. Exhibit 1006
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`

`

`TABLE OF CONTENTS
`(continued)
`
`Page
`
`
`
`
`K. “Inherent inertia” ............................................................................................. 30
`L. “Transmission” ................................................................................................. 30
`M. “Gear transmission” ........................................................................................ 31
`N. “Plurality of intermeshed gears interconnecting the two transmission shafts”
` .................................................................................................................. 34
`O. “Brake member positioned adjacent the spring drive” .................................... 35
`P. “Torque or force which decreases as the cover is extended and increases as the
`cover is retracted” ..................................................................................... 36
`Q. “A selected gear ratio which alters the torque or force of the spring drive
`applied to the second transmission shaft as the spring winds and
`unwinds” ................................................................................................... 36
`R. “Decreases the torque or force of the spring drive applied to the second
`transmission shaft as the spring is unwound and increases the torque or
`force of the spring drive applied to the second transmission shaft as the
`spring is rewound” .................................................................................... 37
`X. UNPATENTABILITY OF THE 192 PATENT CLAIMS ............................ 38
`A.
`Tachikawa In View Of Suzuki ................................................................. 39
` 1. Reasons To Combine Tachikawa And Suzuki ........................................... 39
` 2. Claim 18 Is Rendered Obvious By Tachikawa In View Of Suzuki ........... 44
` 3. Claims 31 And 38 Are Rendered Obvious By Tachikawa In View Of
`Suzuki ................................................................................................................ 57
` 4. Claims 35 And 42 Are Rendered Obvious By Tachikawa In View Of
`Suzuki ................................................................................................................ 62
` 5. Claim 36 Is Rendered Obvious By Tachikawa In View Of Suzuki ........... 64
` 6. Claim 43 Is Rendered Obvious By Tachikawa In View Of Suzuki And
`Further In View Of Lohr ................................................................................... 65
`B.
`Tachikawa In View Of Skidmore ............................................................. 67
` 1. Reasons To Combine Tachikawa And Skidmore ....................................... 67
` 2. Claim 18 Is Rendered Obvious By Tachikawa In View Of Skidmore ....... 69
` 3. Claims 31 And 38 Are Rendered Obvious By Tachikawa In View Of
`Skidmore ........................................................................................................... 72
`
`
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`-ii-
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`

`

`TABLE OF CONTENTS
`(continued)
`
`Page
`
`
`
`
` 4. Claims 35 And 42 Are Rendered Obvious By Tachikawa In View Of
`Skidmore ........................................................................................................... 77
` 5. Claim 36 Is Rendered Obvious By Tachikawa In View Of Skidmore ....... 79
` 6. Claim 43 Is Rendered Obvious By Tachikawa In View Of Skidmore And
`Further In View Of Lohr ................................................................................... 80
`XI. CONCLUSION .............................................................................................. 82
`
`
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`-iii-
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`Norman Int. Exhibit 1006
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`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`I.
`
`INTRODUCTION
`
`1. My name is Lawrence E. Carlson, and I am a Professor Emeritus of
`
`Mechanical Engineering at the University of Colorado in Boulder, Colorado. I am
`
`also an independent consultant on various matters involving mechanical
`
`engineering.
`
`2.
`
`I have been engaged by Norman International, Inc. (“Norman”) to
`
`investigate and opine on certain issues relating to U.S. Patent No. 6,283,192 B1
`
`entitled “FLAT SPRING DRIVE SYSTEM AND WINDOW COVER” (“192
`
`patent”).
`
`3.
`
`I understand, based on information and belief, including assignment
`
`information available in the United States Patent and Trademark Office Patent
`
`Assignment Database, that the 192 patent was initially issued to named inventor
`
`Andrew J. Toti and is currently assigned to the Andrew J. Toti Testamentary Trust
`
`and its co-trustees, Russell L. Hinckley, Sr. and Robert F. Miller. In addition,
`
`based on information and belief, Hunter Douglas, Inc. is the exclusive licensee of
`
`the 192 patent in the field of window covering products. All of these individuals
`
`and entities, including Hunter Douglas, Inc., are therefore collectively referred to
`
`as “Patent Owner” in this declaration.
`
`
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`
`4.
`
`In this declaration, I will discuss the technology related to the 192
`
`patent, including an overview of that technology as it was known at the time of the
`
`earliest date to which the 192 patent may claim priority—November 4, 1997.
`
`5.
`
`This declaration is based on the information currently available to me.
`
`To the extent that additional information becomes available, I reserve the right to
`
`supplement my opinions following further investigation and study, which may
`
`include a review of documents and information that may be produced, as well as
`
`testimony from depositions that may not yet be taken.
`
`II.
`
`SUMMARY OF OPINIONS
`
`6.
`
`The 192 patent describes window cover systems and associated spring
`
`drive systems and transmissions for window covers. I have been asked by
`
`Norman’s counsel to analyze claims 17, 18, 31, 35, 36, 38, 42, and 43 of the 192
`
`patent, out of a total of 44 claims issued by the Patent Office.
`
`7.
`
`Independent claims 17, 31, and 38 recite spring drive systems that
`
`include a spring drive having a flat spring. The claims further recite a bevel gear
`
`set (claims 17 and 36) or a transmission applying a selected gear ratio between two
`
`transmission shafts (claims 18, 31, 35, 36, 38, 42, and 43).
`
`8.
`
`Based on my review of the evidence and facts, it is my opinion that
`
`the claimed combination in each of claims 17, 18, 31, 35, 36, 38, 42, and 43
`
`
`
`-2-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`contains nothing novel or inventive and, under the patentability standard of 35
`
`U.S.C. § 103(a) explained to me by Norman’s counsel as stated below, claims 18,
`
`31, 35, 36, 38, 42, and 43 are unpatentable and invalid. Specifically, the prior art
`
`references cited below disclose the flat spring drive system and window cover
`
`features of claims 18, 31, 35, 36, 38, 42, and 43, either individually or in
`
`combination. 1
`
`9.
`
`As described in further detail below, it is my opinion that claims 18,
`
`31, 35, 36, 38, and 42 of the 192 patent are unpatentable for being rendered
`
`obvious by Japanese Unexamined Patent Application Publication S54-38648
`
`(“Tachikawa”) in view of Japanese Unexamined Patent Application Publication
`
`S53-126478 (“Suzuki”). I also believe that claim 43 is unpatentable for being
`
`rendered obvious by Tachikawa in view of Suzuki, and further in view of U.S.
`
`Patent No. 3,216,528 (“Lohr”).
`
`10.
`
`It is also my opinion that claims 18, 31, 35, 36, 38, and 42 of the 192
`
`patent are unpatentable for being obvious in view of Tachikawa in combination
`
`with G.B. Patent No. 1,174,127 (“Skidmore”). Moreover, it is my opinion that
`
`
`1. I understand that the Patent Trial and Appeal Board instituted review of Claims
`17 and 26 on June 20, 2014 in Case IPR2014-00276. My opinions on the
`patentability of these two claims are set forth in the Declaration of Lawrence E.
`Carlson in Support of Petition for Inter Partes Review of U.S. Patent No. 6,283,192
`B1 in Case IPR2014-00276.
`
`
`
`-3-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`claim 43 is unpatentable for being rendered obvious by Tachikawa in view of
`
`Skidmore, and further in view of Lohr.
`
`11. For purpose of my analysis in this declaration only and based on the
`
`disclosure and file history of the 192 patent, and under the Patent Office’s standard
`
`of “broadest reasonable construction in light of the specification of the patent” to
`
`one of ordinary skill in the art, I provide my proposed construction of certain terms
`
`in claims 17, 18, 31, 35, 36, 38, 42, and 43 in a later part of this declaration.
`
`12. The subsequent sections of this declaration will first provide my
`
`qualifications and experience and then describe details of my analysis and
`
`observations.
`
`III. QUALIFICATIONS AND EXPERIENCE
`A. Education and Work Experience
`13.
`
`I received my Doctorate (D.Eng.) and Masters (M.S.) Degrees in
`
`Mechanical Engineering from the University of California at Berkeley in 1971 and
`
`1968, respectively. I also received a Bachelor of Science in Mechanical
`
`Engineering from the University of Wisconsin in 1967.
`
`14.
`
`I have spent nearly 40 years educating engineering students on
`
`mechanical and component design, primarily in the Department of Mechanical
`
`Engineering at the University of Colorado at Boulder. I was an Assistant Professor
`
`from 1974 to 1978, a tenured Associate Professor from 1978 to 1994, and a
`
`
`
`-4-
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`Norman Int. Exhibit 1006
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`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`tenured Professor from 1994 to 2010, when I became a Professor Emeritus. Prior
`
`to joining the faculty of the University of Colorado, I was an Assistant Professor of
`
`Mechanical Design in the Materials Engineering Department at the University of
`
`Illinois at Chicago from 1971 to 1974.
`
`15.
`
`I was also a founding co-director of the Integrated Teaching and
`
`Learning Laboratory and Program for the College of Engineering and Applied
`
`Science at the University of Colorado and have received several teaching awards
`
`for my work at the University of Colorado, including the Bernard M. Gordon Prize
`
`for Innovation in Engineering and Technology Education from the National
`
`Academy of Engineering in 2008. A copy of my CV is included in Attachment A.
`
`16. As a Professor of Mechanical Engineering, I regularly taught
`
`mechanical design courses at the University of Colorado beginning in the 1970’s,
`
`including Component Design, Design for Manufacturability, Invention and
`
`Innovation, and hands-on design project courses at the undergraduate and graduate
`
`levels. The catalog description for the Component Design course (MCEN-3025) is
`
`the “[a]pplication of mechanics and materials science to the detailed design of
`
`various machine elements including shafts, bearings, gears, brakes, springs, and
`
`fasteners.” It was my responsibility to teach engineering students how to describe
`
`and apply these fundamental machine elements to many types of mechanical
`
`
`
`-5-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`systems. I have also reviewed several textbooks relating to component design
`
`during the course of my career.
`
`17.
`
`In addition to my extensive teaching experience, I also have more than
`
`40 years of practical experience in mechanical design and research in numerous
`
`fields, including rehabilitation engineering, upper-limb prosthetics, consumer
`
`products, sculptures, and products to help developing countries. This includes the
`
`supervision of undergraduate and graduate research projects, most of which
`
`involved hands-on mechanical design in countless areas, including interactive
`
`learning exhibits, sporting equipment, and consumer products. My personal design
`
`efforts include a turbine-based flowmeter, a human-powered water pump, and a
`
`counterbalance mechanism for a computer monitor that allows it to float in space.
`
`I have had a supervisory and collaborative role in many other mechanisms,
`
`including a patented releasable ski binding, an improved spring-loaded rock
`
`climbing cam, and an automatic drywall screw gun. Many of these designs and
`
`design tests have been described in two dozen of my publications, which are listed
`
`in my CV (Attachment A).
`
`18. For my doctoral research project, I designed, built, and tested a
`
`pneumatically-powered above-elbow prosthesis. This complex mechanical design
`
`utilized a variety of relevant mechanical components including bevel and spur
`
`
`
`-6-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`gears, springs, cams, shafts, a clutch, pulleys, pneumatic cylinders, and other
`
`components to coordinate wrist and elbow rotation in various directions.
`
`19.
`
`I am also a named inventor of five United States patents: (1) Patent
`
`No. 4,461,085 issued July 24, 1984, entitled “Goniometer”; (2) Patent No.
`
`4,990,162 issued February 5, 1991, entitled “Rotary hand prosthesis”; (3) Patent
`
`No. 5,800,571 issued September 1, 1998, entitled “Locking mechanism for
`
`voluntary closing prosthetic prehensor”; (4) Patent No. 7,458,598 issued December
`
`2, 2008, entitled “Telemark binding with releasable riser plate assembly”; and (5)
`
`Patent No. 8,560,031 issued October 15, 2013, entitled “Extending socket for
`
`portable media player.”
`
`20. A true and accurate copy of my CV is included in Attachment A,
`
`which will supplement the additional details about my education and experience
`
`above.
`
`B. Compensation
`21.
`
`I am being compensated at the rate of $200 per hour for the services I
`
`am providing in this case. The compensation is not contingent upon my
`
`performance, the outcome of this inter partes review or any other proceeding, or
`
`any issues involved in or related to this inter partes review.
`
`
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`-7-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`
`C. Documents and Other Materials Relied Upon
`22. The documents on which I rely for the opinions expressed in this
`
`declaration are the 192 patent, the prosecution history for the 192 patent, the prior
`
`art references and information discussed in this declaration, and any other
`
`references specifically identified in this declaration, in their entirety, even if only
`
`portions of these documents are discussed here in an exemplary fashion. I also
`
`relied on my own experience and expertise in the relevant technologies and
`
`systems that were already in use prior to, and within the timeframe of the earliest
`
`potential priority date of the claimed subject matter in the 192 patent— November
`
`4, 1997.
`
`IV. STATEMENT OF LEGAL PRINCIPLES
`A. Claim Construction
`23. Norman’s counsel has advised that, when construing claim terms, a
`
`claim subject to inter partes review receives the “broadest reasonable construction
`
`in light of the specification of the patent in which it appears.” Norman’s counsel
`
`has further informed me that the broadest reasonable construction is the broadest
`
`reasonable interpretation of the claim language, and that any term that lacks a
`
`definition in the specification is also given a reasonably broad interpretation.
`
`
`
`-8-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`
`B. Obviousness
`24. Norman’s counsel has advised that obviousness under 35 U.S.C.
`
`§ 103 is a basis for invalidity. I understand that where a prior art reference
`
`discloses less than all of the limitations of a given patent claim, that patent claim is
`
`invalid if the differences between the claimed subject matter and the prior art
`
`reference are such that the claimed subject matter as a whole would have been
`
`obvious at the time the invention was made to a person having ordinary skill in the
`
`relevant art. I understand that obviousness can be based on a single prior art
`
`reference or a combination of references that either expressly or inherently
`
`discloses all limitations of the claimed invention.
`
`25. Norman’s counsel has explained that prior art needs to be either (a) in
`
`the same field of endeavor as the claimed invention, even if it addresses a different
`
`problem than the claimed invention, or (b) reasonably pertinent to the problem
`
`faced by the inventor, even if it is not in the same field of endeavor as the claimed
`
`invention. I understand that prior art is reasonably pertinent to the problem when it
`
`would have logically presented itself to an inventor’s attention in considering the
`
`problem. Norman’s counsel has also explained that in a simple mechanical
`
`invention, a broad spectrum of prior art must be explored, and it is reasonable to
`
`inquire into other areas where one of ordinary skill in the art would be aware that
`
`
`
`-9-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`similar problems exist, including where other areas have inventions with similar
`
`structure and function.
`
`26.
`
` Norman’s counsel has also explained that a conclusion of
`
`obviousness can be supported by a number of reasons. Obviousness can be based
`
`on inferences, creative steps, and even routine steps and ordinary ingenuity that an
`
`inventor would employ. A conclusion of obviousness can be supported by
`
`combining or substituting known elements according to known methods to yield
`
`predictable results, or by using known techniques to improve similar devices in the
`
`same way, or by trying predictable solutions with a reasonable expectation of
`
`success, among other reasons.
`
`V. LEVEL OF ORDINARY SKILL IN THE ART
`27.
`
`I understand from Norman’s counsel that the claims and specification
`
`of a patent must be read and construed through the eyes of a person of ordinary
`
`skill in the art at the time of the priority date of the claims. I have also been
`
`advised that to determine the appropriate level of a person having ordinary skill in
`
`the art, the following factors may be considered: (a) the types of problems
`
`encountered by those working in the field and prior art solutions thereto; (b) the
`
`sophistication of the technology in question, and the rapidity with which
`
`
`
`-10-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`innovations occur in the field; (c) the educational level of active workers in the
`
`field; and (d) the educational level of the inventor.
`
`28. The relevant technologies to the 192 patent are mechanical design
`
`components used for simple spring drive systems. The 192 patent discloses the use
`
`of these simple spring drive systems in window covers, although there are
`
`numerous potential and known applications for spring drive systems, such as
`
`counterbalancing mechanisms including window sashes, cord reels, clocks and
`
`timers, spring-powered generators, tape measures, toys, and others explained in
`
`further detail below.
`
`29. The technical problems encountered in these types of systems, and
`
`specifically the use of spring drive systems in window covers, involve basic,
`
`straight-forward mechanical device solutions. This technology is not sophisticated,
`
`and the components of this technology—flat springs and spring motors, gears
`
`(including bevel gears), cords and pulleys, shafts, transmissions, spools, cranks,
`
`and brake devices—are basic design components that have been in use long before
`
`1997.
`
`30. Based on the above considerations and factors, it is my opinion that a
`
`person having ordinary skill in the art would have an associate’s degree or a
`
`bachelor’s degree in mechanical engineering or a related field involving
`
`
`
`-11-
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`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`mechanical design coursework and a few years of working experience in the area
`
`of mechanical design. This description is approximate and additional educational
`
`experience in mechanical design could make up for less work experience in
`
`mechanical design and vice versa.
`
`VI. TECHNOLOGY BACKGROUND OF CLAIMED SUBJECT
`MATTER OF THE 192 PATENT
`31. Technology related to window covers— including spring drives or
`
`motors for window covers— involves basic mechanical design components. The
`
`components disclosed in the 192 patent, including flat springs and spring motors,
`
`gears (including bevel gears), cords and pulleys, shafts, transmissions, spools,
`
`cranks, and brake devices, have been well known individually and in various
`
`combinations long before the 192 patent was filed.
`
`A.
`Spring Drives
`32. Spring drives are basic mechanical devices with numerous
`
`applications. At its most fundamental level, a spring is a mechanical element that
`
`exerts a force when deformed. Mechanical springs are used in machines to exert
`
`force, to provide flexibility, and to store or absorb energy. There are several types
`
`of springs. In general, springs can be classified as either wire springs, flat springs,
`
`or special-shaped springs, although there are variations within these classifications.
`
`Flat springs include, for example, cantilever springs, elliptical springs, wound
`
`
`
`-12-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`motor- or clock-type power springs, and Belleville springs. Attachment B to this
`
`declaration is a true and accurate copy of a chapter entitled “Mechanical Springs”
`
`from a mechanical engineering textbook that I regularly required when I taught the
`
`junior-level Component Design course, which is required of all mechanical
`
`engineering students. It was published prior to the relevant priority date and
`
`provides additional background information on springs known to one of ordinary
`
`skill in the art. (J. Shigley & C. Mischke, Mechanical Engineering Design, 5th ed.
`
`(1989) in Attachment B.)
`
`33. The particular spring disclosed in the 192 patent is what I would refer
`
`to as a “constant-force spring” or a “flat spiral spring.” This type of spring is made
`
`from a strip of flat spring material (usually steel) that has been wound to a given
`
`curvature so that in its relaxed condition it is in the form of a tightly wound coil.
`
`(Attachment B at 443.) The unique characteristic of this type of spring is that the
`
`force exerted is independent of the deflection. In other words, the force required to
`
`uncoil a “constant-force spring” remains approximately constant, which is why it is
`
`called a “constant-force spring.” (Id.) In reality, the force required to uncoil the
`
`spring actually has slight variations, but “constant-force” is generally understood to
`
`be the best word available to describe the force-deflection characteristics of this
`
`
`
`-13-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`type of spring. It is also the term used by manufacturers who produce and sell this
`
`type of spring. A common example of this type of spring is the tape measure.
`
`34. Many springs, such as the helical extension spring used to close
`
`screen doors, have a positive spring rate; i.e., the force increases linearly with
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`deflection. Constant-force springs, on the other hand, generally have a zero spring
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`rate, although it was well-known before the relevant date for the 192 patent that
`
`constant-force springs can also be manufactured to have either a positive or a
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`negative spring rate, meaning that the force required to uncoil the spring can either
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`increase or decrease with deflection. (See, e.g., Attachment B at 443.) Based on
`
`my experience as an educator in mechanical design, this is all basic knowledge that
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`has been taught to engineering students for decades and is widely available in
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`textbooks like Mechanical Engineering Design. A person of ordinary skill in the
`
`art would have been knowledgeable about this known element.
`
`35. When a constant-force spring is mounted on two drums of different
`
`diameters, as is disclosed in the 192 patent, the result is a constant-force spring
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`motor. Constant-force spring motors were well understood in the art long before
`
`the 192 patent, including design formulas and suggestions. For example,
`
`Attachment C to this declaration is a true and accurate copy of a chapter entitled
`
`“Springs” from a mechanical engineering reference text published prior to the
`
`
`
`-14-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`relevant priority date. (Shigley, J. & C. Mischke, Standard Handbook of Machine
`
`Design (1986) in Attachment C.) This text provides design formulas and
`
`suggestions for constant-force spring motors. (See, e.g., id. at 24-10 - 24-10-4.)
`
`B.
`36.
`
`Transmissions
`
`In its broadest definition, a transmission is simply an assembly of
`
`parts that transfers power from one mechanical part to another, usually shafts. In
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`practice, a transmission is generally used to modify the speed and torque between
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`the two parts. There is an inverse relationship between speed and torque in a
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`transmission. For example, if the output shaft of a transmission rotates at twice the
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`speed of the input shaft, it will exert half the torque. By definition, torque is a
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`force applied to a moment arm. Therefore, as the gear transmission alters the
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`speed of the shaft it also alters the force acting on the moment arm; i.e., torque.
`
`37. Frequently, a transmission will convert speed and torque through the
`
`use of multiple gears. One well-known example of a transmission is a reverted
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`compound gear transmission. “Reverted” means that the input and output shafts
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`are coaxial; “compound” means that more than one pair of gears are meshing
`
`together. A common example of such a transmission is the manual automobile
`
`transmission. The Skidmore reference presents another example of a compound
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`transmission. (Skidmore at Figs. 3 & 4 (in gear box 12).)
`
`
`
`-15-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`
`38. Suzuki also discloses a simple transmission (i.e., gears 4, 5, and 7). In
`
`Suzuki, gear 4 and gear 7 determine the gear ratio of the transmission.
`
`Intermediate gear 5 simply transfers torque between gear 4 and gear 7 without
`
`affecting the gear ratio. As shown in Figure 1, gear 4 is smaller than gear 7.
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`Accordingly, Suzuki’s transmission alters the rotating speed (and consequently the
`
`torque) between the spring drive 1, 2, 3 and winding drum 6a.
`
`39. Suzuki also demonstrates that the distance traversed by the control
`
`rope 10 relative to the spring 2 can be altered depending on the gear ratio of
`
`transmission 4, 5, 7. As shown in Figure 1, the rotating end 3 of spring 2 will
`
`rotate faster than spool 11. Accordingly, the window cover can be made to travel
`
`further or shorter than the available spring length depending on the gear ratios
`
`chosen in the transmission. Thus, a transmission can be added to a spring balanced
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`window cover for the purpose of matching the available spring travel to the length
`
`of the window cover. Skidmore’s transmission has the same effect on travel. For
`
`example, gears 17, 18, 21, 22, and 23 determine how far tapes 27 and 28 travel
`
`relative to how many revolutions pulley 14 is made to rotate.
`
`40. Transmissions, including the type of transmission disclosed in the 192
`
`patent, were widely known and used in mechanical designs long before the
`
`
`
`-16-
`
`Norman Int. Exhibit 1006
`
`

`

`DECLARATION OF LAWRENCE E. CARLSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,283,192 B1
`
`
`relevant date for the 192 patent in a host of applications including t