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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FORD MOTOR COMPANY
`Petitioner
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`v.
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`PAICE LLC & THE ABELL FOUNDATION, INC.
`Patent Owner
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`Case IPR2014-01416
`Patent 7,237,634
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`Patent Owner’s Preliminary Response to
`Petition for Inter Partes Review of U.S.
`Patent No. 7,237,634
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`Patent No. 7,237,634
`Patent Owner Preliminary Response
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`Case IPR2014-01416
`Attorney Docket No: 36351-0015IP2
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`TABLE OF CONTENTS
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`I.
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`II.
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`INTRODUCTION ........................................................................................... 1
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`BACKGROUND OF THE ’634 PATENT ..................................................... 3
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`III. DEFECTS IN THE PROPOSED GROUNDS OF UNPATENTABILITY ... 6
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`A. Ground 3 is defective because Ford has failed to establish a
`reasonable likelihood that Tabata ’201 in view of the general
`knowledge of a POSA describes or suggests the features recited in
`claims 215 and 228. ............................................................................... 6
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`Ford has failed to demonstrate a reasonable likelihood that
`1.
`Tabata ’201 in view of the general knowledge of a POSA describes or
`suggests the desirability of using an engine to efficiently produce
`torque above a setpoint (SP) that is substantially less than the
`maximum torque output (MTO) of the engine in a hybrid vehicle. ...... 6
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`Ford has failed to demonstrate a reasonable likelihood that
`2.
`Tabata ’201 in view of the general knowledge of a POSA describes or
`suggests monitoring a state of charge of a battery comprised in the
`hybrid vehicle. ..................................................................................... 11
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`IV. CONCLUSION .............................................................................................. 14
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`TABLE OF AUTHORITIES
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` Page(s)
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`Statutes
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`35 U.S.C. § 313 .......................................................................................................... 1
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`35 U.S.C. § 314 (a) .................................................................................................. 14
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`Other Authorities
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`37 C.F.R. § 42.107 ..................................................................................................... 1
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`37 C.F.R. § 42.108(c) ............................................................................................... 14
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`Patent No. 7,237,634
`Patent Owner Preliminary Response
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`I.
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`INTRODUCTION
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`Case IPR2014-01416
`Attorney Docket No: 36351-0015IP2
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`Paice LLC and The Abell Foundation, Inc. (collectively, “Patent Owner”)
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`respectfully submit this Preliminary Response in accordance with 35 U.S.C. § 313
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`and 37 C.F.R. § 42.107, responding to the Petition for Inter Partes Review (“the
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`Petition”) filed by Ford Motor Company (“Petitioner”) against U.S. Patent No.
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`7,237,634 (“the ‘634 patent”).1 Patent Owner requests that the Board not institute
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`inter partes review with respect to Ground 3 because the Petition fails to establish
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`a reasonable likelihood that Petitioner will prevail with respect to at least one of
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`the challenged claims. 2
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`1 To the extent Patent Owner does not address particular assertions made in
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`the Petition, Patent Owner hereby reserves those arguments for the Patent Owner
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`Response should the Board institute trial.
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`2 In IPR2014-00904, the Patent Owner presented reasons why Ford lacks
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`standing to challenge the ’634 patent because of Ford’s breach of an Arbitration
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`Agreement between the parties. The Board found that the standing issue was not
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`ripe since the question of breach was unresolved at that point. The Patent Owner
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`also had filed in the District Court a motion for preliminary injunction based on the
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`For proposed ground 3, Petitioner has failed to demonstrate a reasonable
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`likelihood that the prior art relied upon anticipates or renders obvious the
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`challenged claims.
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`For example, with respect to Ground 3, Petitioner has failed to demonstrate a
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`reasonable likelihood that Tabata ’201 in view of the general knowledge of a
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`POSA describes or suggests the desirability of using an engine to efficiently
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`produce torque above a setpoint (SP) that is substantially less than the maximum
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`torque output (MTO) of the engine in a hybrid vehicle as required by claim 215.
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`Furthermore, Petitioner has failed to demonstrate a reasonable likelihood that
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`Tabata ’201 in view of the general knowledge of a POSA describes or suggests
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`breach of contract. On October 8, 2014, the District Court denied the motion for
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`preliminary injunction. See Paice v. Ford, 1:14-cv-492 (ECF 79) (D. Md. Nov. 6,
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`2014) (redacted memorandum opinion). However, the question regarding breach
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`of contract remains unresolved and consequently the Patent Owner has not briefed
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`the issue in this preliminary response. But when the issue is resolved in the Patent
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`Owner’s favor, the Patent Owner believes the issue of standing will be ripe and
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`reserves the right to raise the standing issue at that time.
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`monitoring a state of charge of a battery comprised in the hybrid vehicle as
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`required by claim 228.
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`Accordingly, Ford’s Petition fails to establish a reasonable likelihood that it
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`would prevail with respect to at least one of the claims challenged in Ground 3 of
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`the Petition. Therefore, Ground 3 of the Petition should be denied.
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`II. BACKGROUND OF THE ’634 PATENT
`The ’634 patent (Ex. 1101), entitled “Hybrid Vehicles,” issued on July 3,
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`2007, from an application with a priority date of September 14, 1998. The ’634
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`patent discloses embodiments of a hybrid electric vehicle, with an internal
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`combustion engine, one or more electric motors and a battery bank. A
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`microprocessor is employed to control the internal combustion engine, the one or
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`more motors, and the battery bank based on the hybrid vehicle’s instantaneous
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`torque requirements such that the internal combustion engine is run under high
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`efficiency conditions. See, e.g., Ex. 1101 at Abstract.
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`An embodiment of the hybrid vehicle disclosed in the ’634 patent is shown
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`in Figure 3, reproduced below:
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`As shown, a traction motor 25 is connected to the road wheels 34 through a
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`differential 32. A starter motor 21 is connected to the internal combustion engine
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`40. The motors 21 and 25 are functional as either motors or generators, depending
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`on the operation of the corresponding inverter/charger units 23 and 27, which
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`connect the motors to the battery bank 22. See Ex. 1101 at 26:19-30.
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`These components are controlled by a microprocessor 48 or any controller
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`capable of examining input parameters and signals and controlling the mode of
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`operation of the vehicle. See, e.g., Ex. 1101 at 26:31-27:25. For example, control
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`of engine 40 is accomplished by way of control signals provided by the
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`microprocessor to the electronic fuel injection (EFI) unit 56 and electronic engine
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`management (EEM) unit 55. Control of (1) starting of the engine 40; (2) use of
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`motors 21 and 25 to provide propulsive torque; or (3) use of motors as generators
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`to provide regenerative recharging of battery bank 22, is accomplished through
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`control signals provided by the microprocessor to the inverter/charger units 23 and
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`27. See, e.g., Ex. 1101 at 26:64-27:25; 28:42-52.
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`The hybrid vehicle may be operated in a number of modes based on the
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`vehicle’s instantaneous torque requirements, the engine’s maximum torque output,
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`the state of charge of the battery, and other operating parameters. In an
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`implementation of the ’634 patent, the microprocessor employs a hybrid system
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`control strategy based on sensed and calculated values for system variables that are
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`evaluated against setpoints and causes the vehicle to operate in various operating
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`modes pursuant to this control strategy. See, e.g., Ex. 1101 at 40:16-26.
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`For example, in mode I, the hybrid vehicle is operated as an electric car,
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`with the traction motor providing all torque to propel the vehicle. Ex. 1101 at
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`37:24-32. As the vehicle continues to be propelled in electric only mode, the state
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`of charge of the battery may become depleted, and need to be recharged. In this
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`case, the hybrid vehicle may transition to mode II to recharge the battery, in which
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`the vehicle operates as in mode I, with the addition of the engine running the
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`starter/generator motor to provide electrical energy to operate the traction motor
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`and recharge the battery. See, e.g., Ex. 1101 at 37:32-36. When the internal
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`combustion engine can be operated in its fuel efficient range to propel the vehicle,
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`the hybrid vehicle operates in mode IV, with the engine providing torque to propel
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`the vehicle. Ex. 1101 at 37:42-44; 38:51-61. If the vehicle requires additional
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`torque, such as for acceleration or hill-climbing, the vehicle may enter mode V,
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`where the traction motor provides additional torque to propel the vehicle beyond
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`that provided by engine 40. Ex. 1101 at 38:1-8.
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`III. DEFECTS IN THE PROPOSED GROUNDS OF
`UNPATENTABILITY
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`Proposed Ground 3 of unpatentability is defective for at least the reasons
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`detailed below.
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`A. Ground 3 is defective because Ford has failed to establish a
`reasonable likelihood that Tabata ’201 in view of the general
`knowledge of a POSA describes or suggests the features recited in
`claims 215 and 228.
`The Board should deny the present Petition for inter partes review of claim
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`215 (and its dependent claims 228, 233, 235, and 236) and claim 228 under
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`Ground 3 because Ford has failed to establish a reasonable likelihood that Tabata
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`’201 in view of the general knowledge of a POSA renders obvious claim 215.
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`1.
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`Ford has failed to demonstrate a reasonable likelihood that
`Tabata ’201 in view of the general knowledge of a POSA
`describes or suggests the desirability of using an engine to
`efficiently produce torque above a setpoint (SP) that is
`substantially less than the maximum torque output (MTO)
`of the engine in a hybrid vehicle.
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`The Board should deny the present Petition for inter partes review of claim
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`215 under Ground 3 because Ford has failed to demonstrate that there is a
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`reasonable likelihood that Tabata ’201 in view of the general knowledge of a
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`POSA describes or suggests the desirability of using an engine to efficiently
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`produce torque above a setpoint (SP)3 that is substantially less than the maximum
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`torque output (MTO) of the engine in a hybrid vehicle.
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`Tabata ’201 relates to “a hybrid vehicle drive system having a power drive
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`state in which the vehicle is driven by both an engine and an electric motor, or an
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`engine assist drive mode in which the electric motor cooperates with the engine to
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`serve as a drive power source.” See Ex. 1105 at col. 1:18-24. Figure 15 illustrates
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`a subroutine executed by a hybrid drive controller of the hybrid drive system for
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`determining an operation mode:
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`3 The Patent Owner does not agree with the Board’s construction of the term
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`“setpoint” in its Institution Decision of IPR2014-00579 and reserves the right to
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`further address the Board’s construction in its response and upon appeal of the
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`Board’s claim construction to the Federal Circuit.
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`Ex. 1105, Fig. 15.
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`In particular, Tabata ’201 discloses that “[t]he predetermined first threshold value
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`P1 is a boundary value of the output above which the vehicle is driven with
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`only the engine 212 used as the drive power source” and that “the first threshold
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`value P1 is determined by experiments, so as to minimize the exhaust gas
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`emissions and the fuel consumption, depending upon the energy efficiency
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`during running of the vehicle.” See Ex. 1105 at col. 30:49-62 (emphasis added.)
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`Further, Tabata ’201 discloses that “This second threshold value P2 is a boundary
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`value of the output below which the vehicle is driven with only the engine 212
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`used as the drive power source” and that “the second threshold value P2 is
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`determined by experiments, so as to minimize the exhaust gas emissions and the
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`fuel consumption, depending upon the energy efficiency during running of the
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`vehicle.” See Ex. 1105 at col. 31:63-66 and col. 32:6-9 (emphasis added.) Thus,
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`Tabata ’201 discloses that the engine operates within a predetermined range that
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`minimizes exhaust gas emissions and fuel consumption.
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`Ford and Dr. Davis assert that “Since the setpoint (P1) is less than the
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`engine’s MTO, the upper threshold P2, and the engine’s “sweet spot” operating
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`range (as shown in Fig. 7 above) it would have been further obvious to a POSA
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`that the setpoint (P1) is substantially less than the MTO.” See Petition at 53 and
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`Ex. 1107 at ¶ 493-496. However, neither Ford nor Dr. Davis explain how the first
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`threshold value P1 as disclosed in Tabata ’201 is substantially less than the MTO
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`of the engine. Rather, in support of the conclusory statement that “it would be
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`obvious that the lower setpoint (i.e. “P1”) is substantially less than the engine’s
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`maximum torque output (MTO) as disclosed by Tabata ‘201 and based on general
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`knowledge that the engine’s efficient operating range is below than the engine’s
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`MTO,” Dr. Davis simply states that “as discussed above in ¶¶487-491, the lower
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`threshold P1 is even less than the “sweet spot,” as annotated in Fig. 7 above.” See
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`Ex. 1107 at ¶ 496. But nowhere in these paragraphs does Dr. Davis refer to the
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`lower threshold P1 being less than the sweet spot, let alone explain how he arrived
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`at this conclusion.
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`Moreover, Dr. Davis’s statement is clearly wrong. In fact, Dr. Davis does
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`not even discuss how Tabata ’201 discloses or suggests that the first threshold
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`value P1 is below the engine’s maximum fuel efficiency ηICEmax, but rather
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`constructs an annotated Fig. 7 in which he added a dotted line for the first
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`threshold value P1 and the second threshold value P2. Dr. Davis does not provide
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`any explanation for the placement of these added lines for P1 and P2. Instead, Dr.
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`Davis merely states that “Tabata ‘201 discloses that the “predetermined range has a
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`predetermined width in the direction of the engine torque TE on the upper and
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`lower sides of the line L,” which is annotated in Fig. 7, below.” See Ex. 1107 at ¶
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`492. Dr. Davis’s interpretation of Figure 7 is mere conjecture.
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`Consequently, nowhere does Dr. Davis provide any support for his assertion
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`that the lower threshold P1 is even less than the “sweet spot” of the engine. See
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`Ex. 1107 at ¶ 496. In fact, Dr. Davis states that “Tabata ’201 further discloses that
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`the range between P1 and P2 is an empirically determined range where the
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`engine is most efficient for minimizing emissions and fuel consumption” (see
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`Ex. 1107 at ¶ 491, emphasis added,) which, if anything, would place the range
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`between P1 and P2 within the engine’s maximum fuel efficiency ηICEmax shown in
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`Fig. 7 of Tabata ’201.
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`Furthermore, claim 215 does not require operating an engine within a range
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`that minimizes exhaust gas emissions and fuel consumption, but rather that the
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`engine is operated in order to efficiently produce torque above a setpoint (SP) that
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`is substantially less than the MTO of the engine. Thus, Ford and Dr. Davis have
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`failed to demonstrate that the engine of a hybrid vehicle is to be operated
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`efficiently albeit outside a range that minimizes exhaust gas emissions and fuel
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`consumption, that is, between a first threshold P1 and a second threshold P2
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`according to Tabata ’201.
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`Therefore, Ground 3 is defective because it fails to demonstrate a reasonable
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`likelihood that Tabata ’201 in view of the general knowledge of a POSA describes
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`or suggests desirability of using an engine to efficiently produce torque above a
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`setpoint (SP) that is substantially less than the maximum torque output (MTO) of
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`the engine in a hybrid vehicle.
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`2.
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`Ford has failed to demonstrate a reasonable likelihood that
`Tabata ’201 in view of the general knowledge of a POSA
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`describes or suggests monitoring a state of charge of a
`battery comprised in the hybrid vehicle.
`The Board should deny the present Petition for inter partes review of claim
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`228 under Ground 3 because Ford has failed to demonstrate that there is a
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`reasonable likelihood that Tabata ’201 in view of the general knowledge of a
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`POSA describes or suggests “monitoring a state of charge of a battery comprised in
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`the hybrid vehicle.”
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`Specifically, neither Ford nor Dr. Davis explain how Tabata ’201 discloses
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`monitoring a state of charge of a battery. In fact, Ford simply states that:
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`“Tabata ’201 discloses that the “amount of electric energy [state of charge]”
`of the battery “can be obtained from the electric current or charging
`efficiency of the motor/generator.” (Ex. 1105 at 27:60-65.) Further, as
`shown in Fig. 15 above, Tabata ’201 illustrates how operation mode is based
`on the “SOC” thresholds of the battery. (Ex. 1105 at Fig. 15; Ex. 1107,
`Davis ¶¶524- 527.)” See Petition at 55-56.
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`However, nowhere does Ford address the monitoring of a state of charge of a
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`battery. Rather, Ford appears to rely on Dr. Davis’ conclusory statement that “[a]
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`person of ordinary skill in the art would understand that if the hybrid drive system
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`is making mode decisions based on the state of charge (SOC) of the battery and if
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`the battery has upper and lower battery state-of-charge limits, then the hybrid drive
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`controller and/or motor/generator controller is monitoring the battery state of
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`charge (SOC).” See Ex. 1107 at ¶ 527. In attempt to support this conclusory
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`statement, Dr. Davis refers to the disclosure of Tabata ’201 describing a routine
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`implemented in a hybrid drive controller for selecting an operation mode of a
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`hybrid drive system. See Ex. 1107 at ¶ 525-526; see also Ex. 1105 at col. 27:46-
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`53, col. 30:64 to 31:12, and Fig. 15.
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`Particularly, Dr. Davis asserts that “[i]n further describing the hybrid
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`operation mode subroutine in Fig. 15, Tabata ’201 further discusses how operation
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`mode is based on the SOC of the battery,” citing Tabata ’201 at col. 30:64-31:12.
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`See Ex. 1107 at ¶ 526. But nowhere does Dr. Davis explain or indicate how Tabata
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`’201 describes or suggests that the state of charge of a battery is monitored.
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`Rather, Dr. Davis cites to an operation mode determining sub-routine illustrated in
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`the flow chart of Fig. 15 of Tabata ’201 that considers the stored electric energy
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`amount SOC when selecting an operation mode of the hybrid vehicle. See Ex.
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`1107 at ¶ 526; see also Ex. 1105 at col. 27:46-49 and col. 30:64 to col. 31:4. Dr.
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`Davis does not explain how the hybrid mode selection routine disclosed by Tabata
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`’201 necessarily requires monitoring the state of charge of the battery. For
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`instance, the battery SOC used in the hybrid mode selection routine disclosed by
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`Tabata ’201 can be obtained when needed and does not need to be monitored. See
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`e.g., Ex. 1105 at col. 27:60-65.
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`In any event, the mere conclusory nature of this assertion means it is entitled
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`to little or no weight, and that it does not provide sufficiently articulated reasoning
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`to support a conclusion of obviousness. Moreover, this simple statement does not
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`relate this purported knowledge to the disclosure of Tabata ’201, or explain how
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`this knowledge means that Tabata ’201 discloses monitoring a state of charge of a
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`battery comprised in the hybrid vehicle. Accordingly, Ford has not met its burden
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`to show a reasonable likelihood that Ford would prevail with respect to claim 228
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`as required by 35 U.S.C. § 314(a); 37 C.F.R. § 42.108(c).
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`IV. CONCLUSION
`For the reasons set forth above, Patent Owner requests that the Board:
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`1.
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`Denies Ground 3 because Ford has failed to demonstrate a reasonable
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`likelihood that Tabata ’201 in view of the general knowledge of a POSA discloses
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`or suggests the features of claims 215 and 228;
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`2.
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`Denies any of the proposed Grounds on any basis that the Board sees
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`fit.
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`Please apply any fees or any credits to Deposit Account No. 06-1050.
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`Respectfully submitted,
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` /Timothy W. Riffe/
`Timothy W. Riffe, Reg. No. 43,881
`Kevin E. Greene, Reg. No. 46,031
`Attorneys for Patent Owner
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`Date: December 16, 2014
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`Customer Number 26191
`Fish & Richardson P.C.
`Telephone: (202) 783-5070
`Facsimile: (202) 783-2331
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
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`certifies that on December 16, 2014, a complete and entire copy of this Patent
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`Owner’s Preliminary Response was provided via email to the Petitioner by serving
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`the correspondence email address of record as follows:
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`Frank A. Angileri
`Brooks Kushman P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, Michigan 48075
`Email: FPGP0104IPR3@brookskushman.com
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`Lissi Mojica
`Kevin Greenleaf
`Dentons US LLP
`1530 Page Mill Road
`Suite 200
`Palo Alto, California 94304-11251
`Email: lissi.mojica@dentons.com
`Email: kevin.greenleaf@dentons.com
`Email: iptdocketchi@dentons.com
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`/Susan C. Johnson/
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`Susan C. Johnson
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(214) 292-4086
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