UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`
`
`FORD MOTOR COMPANY
`Petitioner,
`
`v.
`
`PAICE LLC & ABELL FOUNDATION, INC.
`Patent Owners.
`
`_________________________
`
`
`
`
`
`Case IPR2015-00606
`Patent 7,237,634
`_________________________
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON THE
`CROSS EXAMINATION OF DR. JEFFREY STEIN
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`
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`
`
`_________________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`
`
`FORD MOTOR COMPANY
`Petitioner,
`
`v.
`
`PAICE LLC & ABELL FOUNDATION, INC.
`Patent Owners.
`
`_________________________
`
`
`
`
`
`Case IPR2015-00606
`Patent 7,237,634
`_________________________
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON THE
`CROSS EXAMINATION OF DR. JEFFREY STEIN
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2015-00606
`Patent 7,237,634
`
`EXHIBITS
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`Exhibit Name
`U.S. Patent No. 8,214,097 File History
`Table of Ford’s IPR Petitions
`Appendix A (January 15, 2014)
`Jeffery L. Stein, Deposition Tr. (IPR2014-00570)
`(May 8, 2015)
`Jeffery L. Stein, Deposition Tr. (IPR2014-00875)
`(Mar. 3, 2015)
`Jeffery L. Stein, Deposition Tr. (IPR2014-00875)
`(May 29, 2015)
`Declaration of Daniel A. Tishman in Support of
`Patent Owners’ Motion for Pro Hac Vice Admission
`Declaration of Neil Hannemann
`Neil Hannemann CV
`Gregory W. Davis Deposition Tr. (IPR2014-00571 &
`IPR2014-00579) (Jan. 13, 2015)
`Gregory W. Davis Deposition Tr. (IPR2014-01416)
`(June 3, 2015)
`Gregory W. Davis Deposition Tr. (IPR2014-00571)
`(May 8, 2015)
`Excerpts from Neil Hannemann Deposition Tr.
`(IPR2014-00571) (April 7, 2015)
`Jeffery L. Stein, Deposition Tr. (IPR2014-00570)
`(Jan. 12, 2015)
`Jeffery L. Stein, Deposition Tr. (IPR2014-01415)
`(May 29, 2015)
`Integrated Microprocessor Control of a Hybrid i.c.
`Engine/Battery-Electric Automotive Power Train,”
`P.W. Masding, J.R. Bumby, Jan. 1990
`Masding, Philip Wilson (1988) “Some drive train
`control problems in hybrid i.c engine/battery electric
`vehicles,” Durham theses, Durham University
`Excerpt from McGraw-Hill Dictionary of Scientific
`and Technical Terms, Sixth Ed., 2003.
`Deposition Transcript of Jeffrey Stein, Ph.D.
`
`
`
`Exhibit Number
`Ex. 2801
`Ex. 2802
`Ex. 2803
`Ex. 2804
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`Ex. 2805
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`Ex. 2806
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`Ex. 2807
`Ex. 2808
`Ex. 2809
`Ex. 2810
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`Ex. 2811
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`Ex. 2812
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`Ex. 2813
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`Ex. 2814
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`Ex. 2815
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`Ex. 2816
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`Ex. 2817
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`Ex. 2818
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`Ex. 2819
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`Case IPR2015-00606
`Patent 7,237,634
`In exhibit 2819, on page 31, line 24 to page 34, line 3, Dr. Stein
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`1.
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`testified that claim 7 of U.S. Patent No. 5,343,970 (“the ’970 patent”) discloses a
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`battery providing a maximum current of 75 amperes to the electric motor, that the
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`corresponding voltage would be a voltage under load, and that claim 8 (which
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`depends from claim 7) states that the corresponding voltage is between 500 to
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`1,500 volts. This testimony is relevant to paragraphs 64-68 of Dr. Stein’s Reply
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`Declaration (Ex. 1188). The testimony is relevant because it contradicts Dr. Stein’s
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`reply declaration testimony that the ’970 patent does not disclose 500 to 1,500
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`volts under load.
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`2.
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`In exhibit 2819, on page 46, line 7-21 and page 47 line 18 to page 48,
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`line 3, Dr. Stein testified that both claim 7 (at column 23) and column 19 of
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`the ’970 patent disclose providing a maximum current of 75 amperes and that both
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`claim 8 (which depends from claim 7 and also found at column 23) and column 19
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`of the ’970 patent both disclose voltages of 500 to 1,500 volts. This testimony is
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`relevant to paragraphs 64-68 of Dr. Stein’s Reply Declaration (Ex. 1188). The
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`testimony is relevant because it calls into question Dr. Stein’s reply declaration
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`testimony that the ’970 patent disclosure that “[t]ypical maximum voltages
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`corresponding to light and heavy vehicles are between 500 and 1,500 volts” found
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`on column 19 of the ’970 patent are not clearly voltages under load.
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`Case IPR2015-00606
`Patent 7,237,634
`In exhibit 2819, on page 73, line 17-25, Dr. Stein testified that when
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`3.
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`the battery is providing power and there's a current flowing, the corresponding
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`voltage is a voltage under load. This testimony is relevant to paragraphs 25-31 of
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`Dr. Stein’s Reply Declaration (Ex. 1188). The testimony is relevant because it
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`calls into question Dr. Stein’s reply declaration testimony that U.S. Application
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`No. 09/392,743’s disclosure that disclosed operating voltages in the sentence “the
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`vehicle’s electrical system operates at higher voltage than conventional electric and
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`hybrid vehicles, e.g., 800 - 1200 V as compared to 240 V; this approximate three-
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`fold increase in the operating voltage provides a concomitant reduction in the
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`current that flows in the various modes of operation of the vehicle, to one-third the
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`current that would flow for the same amount of power transfer in a low-voltage
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`system” are not voltages under load.
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`4.
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`In exhibit 2819, on page 70, line 15 to page 71, line 8, Dr. Stein
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`testified that when a hybrid vehicle is being driven, the electrical system will
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`provide current for movement of the vehicle. This testimony is relevant to
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`paragraphs 25-31 of Dr. Stein’s Reply Declaration (Ex. 1188). The testimony is
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`relevant because it calls into question Dr. Stein’s reply declaration testimony that
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`U.S. Application No. 09/392,743’s disclosure that disclosed operating voltages in
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`the sentence “the vehicle’s electrical system operates at higher voltage than
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`conventional electric and hybrid vehicles, e.g., 800 - 1200 V as compared to 240
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`2
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`Case IPR2015-00606
`Patent 7,237,634
`V; this approximate three-fold increase in the operating voltage provides a
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`concomitant reduction in the current that flows in the various modes of operation
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`of the vehicle, to one-third the current that would flow for the same amount of
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`power transfer in a low-voltage system” are not voltages under load.
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`5.
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`In exhibit 2819, on page 77, line 18 to page 78, line 2, Dr. Stein
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`testified that when the nominal voltage is increased by threefold, the corresponding
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`current remains zero. This testimony is relevant to paragraphs 25-31 of Dr. Stein’s
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`Reply Declaration (Ex. 1188). The testimony is relevant because it calls into
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`question Dr. Stein’s reply declaration testimony that U.S. Application No.
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`09/392,743’s disclosure that disclosed operating voltages in the sentence “the
`
`vehicle’s electrical system operates at higher voltage than conventional electric and
`
`hybrid vehicles, e.g., 800 - 1200 V as compared to 240 V; this approximate three-
`
`fold increase in the operating voltage provides a concomitant reduction in the
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`current that flows in the various modes of operation of the vehicle, to one-third the
`
`current that would flow for the same amount of power transfer in a low-voltage
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`system” are nominal voltages and not voltages under load.
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`6.
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`In exhibit 2819, on page 90, line 23 to page 91, line 15, Dr. Stein
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`testified that hybrid vehicle design considerations prevent the maximum voltage of
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`the electrical system to reach infinity. This testimony is relevant to paragraphs 64-
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`67 of Dr. Stein’s Reply Declaration (Ex. 1188). The testimony is relevant because
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`Case IPR2015-00606
`Patent 7,237,634
`it calls into question Dr. Stein’s reply declaration testimony that the ’970 patent
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`does not provide written description support for the at least 500 volts limitation.
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`By: /Brian J. Livedalen/
`
`Timothy W. Riffe (Reg. No. 43,881)
`Kevin Greene, (Reg. No. 46,031)
`Brian J. Livedalen (Reg. No. 67,450)
`FISH & RICHARDSON P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`Tel: (202) 626-6447
`Fax: (202) 783-2331
`
`Attorneys for Patent Owner
`Paice LLC & Abell Foundation, Inc.
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`
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`Dated: May 20, 2016
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`CERTIFICATE OF SERVICE
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`Case IPR2015-00606
`Patent 7,237,634
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`Pursuant to 37 CFR § 42.6(e)(4), the undersigned certifies that on May 20,
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`2016, a complete and entire copy of this Patent Owner’s Motion for Observations
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`was provided via email to the Petitioner by serving the correspondence email
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`address of record as follows:
`
`Frank A. Angileri
`Sangeeta G. Shah
`Michael D. Cushion
`Michael N. MacCallum
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`
`Lissi Mojica
`Kevin Greenleaf
`Dentons US LLP
`1530 Page Mill Road, Suite 200
`Palo Alto, CA 94304-1125
`
`Email: FPGP0104IPR2@brookskushman.com
`Email: ipt.docketchi@dentons.con
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`5
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`/Edward G. Faeth/
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`Edward G. Faeth
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(202) 626-6420
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