Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`
`TRW AUTOMOTIVE U.S. LLC
`Petitioner
`
`v.
`
`MAGNA ELECTRONICS INC.
`Patent Owner
`
`_____________________
`
`Case IPR2014-01497
`Patent 8,531,278
`_____________________
`
`
`PATENT OWNER MAGNA ELECTRONICS INC.’S
`DEMONSTRATIVES
`
`
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`
`TRW AUTOMOTIVE U.S. LLC
`Petitioner
`
`v.
`
`MAGNA ELECTRONICS INC.
`Patent Owner
`
`_____________________
`
`Case IPR2014-01497
`Patent 8,531,278
`_____________________
`
`
`PATENT OWNER MAGNA ELECTRONICS INC.’S
`DEMONSTRATIVES
`
`
`
`Patent Owner’s Demonstratives
`
`TRW AUTOMOTIVE US LLC
`
`v.
`MAGNA ELECTRONICS INC.
`IPR2014-01497 (Patent No.
`8,531,278)
`
`
`
`1 1
`
`12/2/2015
`
`
`
`Instituted § 103 Grounds
`
`Challenged Claims
`1, 9, 12, 13
`
`Asserted references
`Schofield ’094 and Schofield
`’742
`
`24–32 (two mounting
`element claims)
`
`
`Schofield ’094 and Schofield
`’742
`
`
`Denied § 103 Grounds
`
`Challenged Claims
`17–22 and 33–40 (two
`mounting element claims)
`
`
`Asserted references
`Schofield ’094 and Schofield
`’742
`
`
`2
`
`Paper No. 7, Institution Decision, p. 23
`
`12/2/2015
`
`
`
`Claims 24-32 (two mounting element claims)
`
`At the outset, claims 24–32 require the same
`features of the “two mounting elements claims”
`acknowledged as not rendered obvious by the
`cited references as already set forth by the Board
`with respect to non-instituted claims 17–22 and
`33–40 and thus should be confirmed as
`patentable.
`
`3
`
`Paper No. 11, POR, p. 1.
`
`12/2/2015
`
`
`
`Claim 24 (instituted two mounting element claim)
`
`24. An accessory system for a vehicle, said accessory system comprising:a windshield, said
`windshield having an outer surface that is exterior of the vehicle when said windshield is mounted
`to a vehicle equipped with said accessory system and an inner surface that is interior of the vehicle
`when said windshield is mounted to the equipped vehicle;
`wherein said windshield is at an angle relative to vertical when said windshield is mounted to the
`equipped vehicle;
`a mirror mounting button adhesively attached at said inner surface of said windshield at a
`first location;
`an interior rearview mirror assembly mounted to said mirror mounting button;
`wherein said windshield has a mounting element adhesively attached at said inner surface at
`a second location;
`an accessory support adapted for mounting to and demounting from said mounting element;
`wherein said accessory support accommodates a lens, a CMOS photosensor array and a circuit
`board;
`wherein said accessory support is configured so that when mounted to said mounting element
`attached at said windshield, said lens is at an angle with respect to said windshield that provides a
`field of view for said lens through said windshield appropriate for a driver assistance system of the
`equipped vehicle; and
`wherein said driver assistance system comprises at least one of (i) an automatic headlamp control
`system of the equipped vehicle, (ii) a lane departure warning system of the equipped vehicle, (iii)
`an object detection system of the equipped vehicle, (iv) a traffic sign recognition system of the
`equipped vehicle, (v) a precipitation sensing system of the equipped vehicle and (vi) a collision
`avoidance system of the equipped vehicle.
`Ex. 1002, ’278 Patent, claim 24.
`12/2/2015
`
`4
`
`
`
`Claim 17 (non-instituted two mounting element claim)
`
`17. An accessory system for a vehicle, said accessory system comprising:a windshield,
`said windshield having an outer surface that is exterior of the vehicle when said
`windshield is mounted to a vehicle equipped with said accessory system and an inner
`surface that is interior of the vehicle when said windshield is mounted to the equipped
`vehicle;
`wherein said windshield is at an angle relative to vertical when said windshield is
`mounted to the equipped vehicle;
`a mirror mounting button adhesively attached at said inner surface of said
`windshield at a first location;
`an interior rearview mirror assembly mounted to said mirror mounting button;
`wherein said windshield has a mounting element adhesively attached at said inner
`surface at a second location;
`an accessory support adapted for mounting to and demounting from said mounting
`element; and
`wherein said accessory support comprises a first holding portion configured to hold a
`CMOS photosensor array, and wherein said accessory support comprises a second holding
`portion configured to hold a lens, and wherein said CMOS photosensor array held at said
`first holding portion is generally perpendicular to the longitudinal axis of the lens held at
`said second holding portion.
`
`Ex. 1002, ’278 Patent, claim 17.
`
`12/2/2015
`
`5
`
`
`
`TRW’s Characterization of Claims 24-32 in its Reply is Incorrect
`
`TRW confirms the ’278 Patent is part of a chain of filings dating back to the ’268
`patent filed on February 26, 2001. (Petition, p. 1.) The ’268 patent illustrates and
`describes a mounting element and a separate mirror mounting button together in
`the same embodiment. (See, e,g., ʼ268 patent, Ex. 2007, FIGS. 14 and 15.)
`
`6
`
`Paper No. 6, POPR, p. 15, citing ʼ268 patent, Ex. 2007, FIGS. 14 and 15
`
`12/2/2015
`
`
`
`Claim 1 – Single mounting element claim
`An accessory system for a vehicle, said accessory system comprising:
`a windshield, said windshield having an outer surface that is exterior of the vehicle when said
`windshield is mounted to a vehicle equipped with said accessory system and an inner surface
`that is interior of the vehicle when said windshield is mounted to the equipped vehicle;
`wherein said windshield is at an angle relative to vertical when said windshield is mounted to
`the equipped vehicle;
`wherein said windshield has a mounting element adhesively attached at said inner surface;
`an accessory support adapted for mounting to and demounting from said mounting
`element, said accessory support including an accessory receiving portion configured to
`receive an accessory;
`wherein at least one of (a) said accessory support comprises part of an interior rearview mirror
`assembly, (b) said accessory support includes a mirror mounting element and an interior
`rearview mirror assembly is adapted for mounting to said mirror mounting element of said
`accessory support and (c) said accessory support comprises an electrical connector; and
`wherein said accessory comprises an imaging sensor comprising a lens and a CMOS
`photosensor array and wherein said accessory receiving portion is configured to
`accommodate said imaging sensor in a manner that compensates for said angle of said
`windshield so that said imaging sensor has a more generally horizontal forward field of view
`through said windshield when said accessory support is mounted to said mounting element
`adhesively attached at said inner surface of said windshield.
`Ex. 1002, ’278 Patent, claim 1.
`
`12/2/2015
`
`7
`
`
`
`Adaptor 90 of Schofield ’742 is not an accessory support as set forth by the
`Board because it requires additional elements relative to the sensor.
`
`8
`
`Paper No. 11, POR, pp. 24; Schofield ’742, FIG. 15.
`
`12/2/2015
`
`
`
`Adaptor 90 of Schofield ’742 is not an accessory support as set forth by the
`Board because it requires additional elements relative to the sensor.
`
`Adaptor 90, shown in Figures 13–15 of
`Schofield ’742, does not include an
`accessory support as claimed in the ’278
`Patent. (Nranian Decl., ¶¶ 86–88.) As
`recognized by the Board, the claimed
`accessory support is “an element that itself
`receives and/or holds an accessory, such as
`an imaging sensor and lens, independent of
`an additional element.” (Institution
`Decision, p. 17.)
`
`9
`
`Paper No. 11, POR, pp. 26, 27.
`
`12/2/2015
`
`
`
`Adaptor 90 of Schofield ’742 is not an accessory support as set forth by the
`Board because it requires additional elements relative to the sensor.
`
`Adaptor 10 in Schofield ’742, shown in
`Figure 1 reproduced below, is not an
`element that itself receives and/or holds an
`accessory, such as an imaging sensor
`and lens, independent of an additional
`element.
`
`10
`
`Paper No. 7, Institution Decision, pp. 17, 18.
`
`12/2/2015
`
`
`
`TRW and the Board misconstrue the term “electrical
`connector” and the references—alone or in
`combination—fail to render obvious claims 1, 9, 12, 13,
`28, and 29.
`
`TRW proposes to construe this
`phrase as “… a wire for
`connecting to an electrical
`component of the vehicle.”
`(Petition, p. 5.) But this is an
`incorrect construction. A
`“wire” is simply not
`coterminous with the claimed
`“electrical connector,” which is
`the correct term to be
`construed in this case. (Nranian
`Decl., ¶ 57.)
`
`11
`
`Paper No. 11, POR, pp. 19-21.
`
`12/2/2015
`
`
`
`TRW and the Board misconstrue the term “electrical
`connector” and the references—alone or in
`combination—fail to render obvious claims 1, 9, 12, 13,
`28, and 29.
`
`As above, the meaning of “connector” cannot be strained to include
`any “connection,” failing to acknowledge common usage and
`express distinction in the ’278 Patent specification. (Nranian Decl.,
`¶ 102.)
`
`The Board cites Schofield ’094 as disclosing a circuit receiving
`data from a sensor and a logic control module to control headlamps
`but fails to show with particularity where an electrical connector
`may be found as recited in the claims. (Institution Decision, p. 22.)
`Similarly, the Board cites Schofield ’742 as disclosing a headlight
`dimming sensor, connected to the vehicle electrical system via
`wiring.
`
`12
`
`Paper No. 11, POR, p. 32.
`
`12/2/2015
`
`
`
`Case IPR2014-01497
`Patent 8,531,278
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that the foregoing PATENT OWNER
`
`MAGNA ELECTRONICS INC.’S DEMONSTRATIVES was served
`
`electronically via e-mail in its entirety on December 2, 2015, upon the following
`
`counsel for Petitioner – TRW Automotive U.S. LLC.:
`
`Jon Trembath (Lead Counsel)
`Timothy Sendek (Back-up Counsel)
`Allan Sternstein (Back-up Counsel)
`A. Justin Poplin (Back-up Counsel)
`Douglas Link (Back-up Counsel)
`Dan Cleveland, Jr. (Back-up Counsel)
`Hissan Anis (Back-Up Counsel)
`
`JTrembath@LathropGage.com
`TSendek@LathropGage.com
`Patent@LathropGage.com
`JPoplin@LathropGage.com
`DLink@LathropGage.com
`DCleveland@LathropGage.com
`HAnis@LathropGage.com
`
`Lathrop & Gage LLP
`IP Docketing, Inter Partes Review
`2345 Grand Blvd., Ste. 2400
`Kansas City, Missouri 64108
`
`
`
`Date: December 4, 2015
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Mark W. Rygiel/
`
`MARK W. RYGIEL, REGISTRATION NO. 45,871
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 NEW YORK AVENUE, NW
`WASHINGTON, D.C. 20005
`(202) 371-2600
`
`
`
`
`
`
`
`
`
`
`
`
`
`ATTORNEY FOR PATENT OWNER
`MAGNA ELECTRONICS INC.
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