throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`
`VALEO NORTH AMERICA, INC., VALEO S.A.,
`VALEO GMBH, VALEO SCHALTER UND SENSOREN GMBH,
`and CONNAUGHT ELECTRONICS LTD.
`Petitioners
`
`v.
`
`MAGNA ELECTRONICS INC.
`Patent Owner
`
`_____________________
`
`Case IPR2014-01208
`Patent 7,991,522
`_____________________
`
`
`
`
`MAGNA ELECTRONICS INC.’S DEMONSTRATIVES
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`

`
`Patent Owner Magna Electronics Inc.’s Demonstratives
`
`IPR2014‐01208
`
`1
`
`

`
`Q. Okay. And you don’t actually know whether copies
`of the article referred to in Grenier Exhibit 1 were
`available at the symposium, do you?
`A. No, I do not.
`Q. So it’s possible, in fact, that this article was not
`available at the conference; isn’t that right?
`A. I don’t -- I don’t know.
`Q. And in your declaration of Exhibit 1, in paragraph
`6, you say that “The article is currently available for
`public downloads.” Do you see that?
`A. Yes, I do.
`Q. When was this article first available for public
`download?
`A. I can only say some time after the symposium
`date. I do not have an exact date.
`Q. In fact, you don’t know when it was available for
`download, do you?
`A. No.
`Q. There’s nothing on that abstract page that you
`referred to earlier that says when it was available for
`download; isn’t that right?
`A. Yes.
`
`2
`
`Grenier Depo. Transcript (Ex. 2017), 12:3-13:5
`
`

`
`3
`
`Attachment to Broggi I Certification (Ex. 1024), Excerpt
`
`

`
`...
`
`4
`
`Attachment to Butler Affidavit (Ex. 1029), Excerpt
`
`

`
`Exhibit 1033 Timeline
`• January 8, 2015 ‐ PO’s first objections (Ex. 2018)
`served, including objection to Broggi
`
`• January 27, 2015 – PO’s second objections (Ex.
`2019) served, objecting to Grenier (Ex. 1028) and
`Butler (Ex. 1029) Declarations
`
`• February 10, 2015 – Petitioners file Broggi
`Declaration (Ex. 1033) without leave, regarding
`issues pertaining to PO’s first objections
`
`5
`
`PO Motion to Exclude, Paper 35, p. 12
`
`

`
`6
`
`Broggi Declaration (Ex. 1033), Excerpt
`
`

`
`1. An imaging system for a vehicle, said imaging system
`comprising:
`an imaging array sensor comprising a plurality of photo-
`sensing pixels, wherein said imaging array sensor is
`disposed at an exterior rearview mirror assembly at a
`side of a vehicle equipped with said imaging system;
`wherein, when said imaging array sensor is disposed at the
`exterior rearview mirror assembly, said imaging array
`sensor has a field of view exterior of the equipped
`vehicle, and wherein said imaging array sensor is oper-
`able to capture an image exterior of the equipped
`vehicle;
`a control for processing said captured image;
`wherein said control is operable to determine that said
`imaging array sensor is misaligned when said imaging
`array sensor is disposed at the exterior rearview mirror
`assembly at the side of the equi ped vehicle; and
`wherein said control, responsivet a determination of mis-
`’522 Patent (Ex. 1001), claim 1
`7
`aligimient of said imaging array sensor, is operable to at
`least partially compensate for the determined misalign-
`ment of said imaging array sensor.
`
`

`
`’522 Patent (Ex. 1001), FIGS. 3A-3C
`
`8
`
`’522 Patent (Ex. 1001), 6:40-52
`
`

`
`9
`
`Hitachi (Ex. 1013), FIG. 7
`
`

`
`10
`
`’522 Patent (Ex. 1001), claim 19
`
`

`
`11
`
`Broggi (Ex. 1006), FIG. 11
`
`

`
`12
`
`’522 Patent (Ex. 1001), claims 23 and 24
`
`

`
`Summary of Deficient Broggi Support
`
`In Record?
`Yes
`Yes
`Yes
`Yes
`Yes
`No1
`No1
`No1
`Improperly2
`*
`Yes
`
`Name
`Ex#
`Broggi
`1006
`Frahm Dec I
`1010
`Grenier Dec I
`1024
`Grenier Dec II
`1028
`Butler Dec
`1029
`Frahm Dec II
`1030
`Springrobot
`1031
`Springrobot Abstract
`1032
`Broggi Dec
`1033
`Frahm Reply Dec
`1034
`1. Order, Paper 23
`2. PO Motion to Exclude, Paper 35, p. 12
`3. PO Motion to Exclude, Paper 35, generally
`4. Not entered as Supplemental Evidence
`
`13
`
`Supp. Info.
`n/a
`n/a
`n/a
`Yes1
`Yes1
`Denied1
`Denied1
`Denied1
`No1
`n/a
`
`Mot. Excl. 3
`Supp. Ev.
`Yes
`n/a
`Yes
`n/a
`Yes
`n/a
`Yes
`No4
`Yes
`No4
`n/a
`n/a
`n/a
`n/a
`n/a
`n/a
`Not needed2
`No2,4
`Yes
`n/a
`* Patent Owner’s position
`IPR2014-01208
`
`*
`
`

`
`Patent Owner Magna Electronics Inc.’s Demonstratives
`
`IPR2014‐01204
`
`14
`
`

`
`Q. Okay. And you don’t actually know whether copies
`of the article referred to in Grenier Exhibit 1 were
`available at the symposium, do you?
`A. No, I do not.
`Q. So it’s possible, in fact, that this article was not
`available at the conference; isn’t that right?
`A. I don’t -- I don’t know.
`Q. And in your declaration of Exhibit 1, in paragraph
`6, you say that “The article is currently available for
`public downloads.” Do you see that?
`A. Yes, I do.
`Q. When was this article first available for public
`download?
`A. I can only say some time after the symposium
`date. I do not have an exact date.
`Q. In fact, you don’t know when it was available for
`download, do you?
`A. No.
`Q. There’s nothing on that abstract page that you
`referred to earlier that says when it was available for
`download; isn’t that right?
`A. Yes.
`
`15
`
`Grenier Depo. Transcript (Ex. 2009), 12:3-13:5
`
`

`
`16
`
`Attachment to Broggi I Certification (Ex. 1025), Excerpt
`
`

`
`...
`
`17
`
`Attachment to Butler Affidavit (Ex. 1027), Excerpt
`
`

`
`18
`
`Broggi Declaration (Ex. 1031), Excerpt
`
`

`
`19
`
`’114 Patent (Ex. 1001), claim 1
`
`

`
`20
`
`’114 Patent (Ex. 1001), claims 12 and 13
`
`

`
`21
`
`’114 Patent (Ex. 1001), claim 57
`
`

`
`22
`
`Petition, Paper 1, pp. 36-37
`
`

`
`23
`
`Turk Declaration (Ex. 2008), ¶¶ 56 and 57
`
`

`
`24
`
`’114 Patent (Ex. 1001), claim 51
`
`

`
`sli
`
`__
`
`% z©3!||®Ii
`
`%
`
`25
`
`Imoto (Ex. 1014), FIGS. 18-20
`
`

`
`26
`
`Turk Declaration (Ex. 2008), ¶¶ 66 and 67
`
`

`
`27
`
`’114 Patent (Ex. 1001), claim 56
`
`

`
`28
`
`Turk Declaration (Ex. 2008), ¶ 74
`
`

`
`Summary of Deficient Broggi Support
`
`Ex#
`1005
`1013
`1025
`1026
`1027
`1028
`1029
`1030
`1031
`1032
`
`29
`
`In Record?
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`
`Name
`Broggi
`Frahm Dec I
`Grenier Dec I
`Grenier Dec II
`Butler Dec
`Frahm Dec II
`Springrobot
`Springrobot Abstract
`Broggi Dec
`Frahm Reply Dec
`1. Order, Paper 26
`2. Not entered as Supplemental Evidence
`3. PO Motion to Exclude, Paper 33, generally
`
`Supp. Info.
`n/a
`n/a
`n/a
`Yes1
`Yes1
`Yes1
`Yes1
`Yes1
`Yes1
`n/a
`
`Supp. Ev.
`n/a
`n/a
`n/a
`No2
`No2
`No2
`No2
`No2
`No2
`n/a
`
`Mot. Excl. 3
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`Yes
`No
`Yes
`
`IPR2014-01204
`
`

`
`CERTIFICATE OF SERVICE
`
`Case IPR2014-01208
`Patent 7,991,522
`
`The undersigned hereby certifies that a true and correct copy of MAGNA
`
`ELECTRONICS INC.’S DEMONSTRATIVES was served electronically via e-
`
`mail on September 29, 2015, in its entirety on Attorneys for Petitioners – Valeo
`
`North America, Inc., et al..:
`
`Tammy J. Terry (Lead Counsel)
`Seema Mehta (Back-up Counsel)
`Aly Z. Dossa (Back-up Counsel)
`Peter C. Schechter (Back-up Counsel)
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, TX 77010-1034
`terry@oshaliang.com
`mehta@oshaliang.com
`dossa@oshaliang.com
`schechter@oshaliang.com
`
`
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
` Salvador M. Bezos /
`
` /
`
` Salvador M. Bezos
`Date: September 29, 2015
` Attorney for Patent Owner
`
`
`
`
`
`1100 New York Avenue, N.W. Registration No. 60,889
`Washington, D.C.20005-3934
`(202) 371-2600

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket