Trials@uspto.gov
`571-272-7822
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`
`
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`Paper 12
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`Entered: November 9, 2015
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`FORD MOTOR COMPANY,
`Petitioner,
`
`v.
`
`PAICE LLC & THE ABELL FOUNDATION, INC.,
`Patent Owner.
`____________
`
`Case IPR2015-00758
`Patent 7,237,634 B2
`____________
`
`
`
`Before SALLY C. MEDLEY, KALYAN K. DESHPANDE, and
`CARL M. DEFRANCO, Administrative Patent Judges.
`
`DEFRANCO, Administrative Patent Judge.
`
`DECISION TO INSTITUTE
`37 C.F.R. § 42.108
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`

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`IPR2015-00758
`Patent 7,237,634 B2
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`
`I. INTRODUCTION
`This is a preliminary proceeding to decide the threshold question of
`
`whether inter partes review of U.S. Patent No. 7,237,634 B2 (“the ’634
`patent”) should be instituted under 35 U.S.C. § 314(a). Specifically, Ford
`Motor Company (“Ford”) filed a Petition (“Pet.”) seeking inter partes
`review of claims 80–90, 114–124, 161–171, 215–225, and 294 of the ’634
`patent, which is owned by Paice LLC & The Abell Foundation, Inc.
`(collectively, “Paice”). Paper 1. Paice filed a Preliminary Response
`(“Prelim. Resp.”) requesting that we deny institution of inter partes review.
`Paper 11. After considering the Petition and Preliminary Response, we
`conclude that Ford has demonstrated a reasonable likelihood of prevailing
`with respect to the challenged claims. Accordingly, we authorize institution
`of an inter partes review of claims 80–90, 114–124, 161–171, 215–225, and
`294.
`
`II. BACKGROUND
`
`A.
`
`The ’634 Patent 1
`The ’634 patent describes a hybrid vehicle with an internal
`combustion engine, at least one electric motor, and a battery bank, all
`controlled by a microprocessor that directs the transfer of torque from the
`engine and/or motor to the drive wheels of the vehicle. Ex. 1201, 17:17–56,
`Fig. 4. The microprocessor “monitors the rate at which the operator
`depresses pedals [for acceleration and braking] as well as the degree to
`which [the pedals] are depressed.” Id. at 27:36–38. These “operator input
`
`1 The ’634 patent is involved in several co-pending district court actions,
`including Paice LLC v. Ford Motor Co., No. 1:14-cv-00492 (D. Md.), filed
`Feb. 19, 2014, and Paice LLC v. Hyundai Motor Co., No. 1:12-cv-00499
`(D. Md.), filed Feb. 16, 2012. Pet. 3.
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`commands” are provided to the microprocessor “as an indication that an
`amount of torque” from the engine “will shortly be required” to drive the
`vehicle. Id. at 27:26–27:57. The microprocessor then compares the
`vehicle’s torque requirement against a predefined setpoint and uses the
`results of the comparison to control the vehicle’s mode of operation, e.g.,
`straight-electric, engine-only, or hybrid. Id. at 40:16–49. For instance, the
`microprocessor may utilize a control strategy that runs the engine only in a
`range of high fuel efficiency, such as when the torque required to drive the
`vehicle, or road load (RL), reaches a setpoint (SP) of approximately 30% of
`the engine’s maximum torque output (MTO). Id. at 20:61–67, 37:24–44;
`see also id. at 13:64–65 (“the engine is never operated at less than 30% of
`MTO, and is thus never operated inefficiently”). Operating the engine in
`this manner maximizes fuel efficiency and reduces pollutant emissions of
`the vehicle. Id. at 15:55–58.
`B.
`The Challenged Claims
`
`
`Of the challenged claims, five are independent—claims 80, 114, 161,
`215, and 294. Common among the challenged claims, particularly the
`dependent claims, is their relation to the electrical current and/or DC voltage
`supplied by the battery to the motor. For example, many of the challenged
`dependent claims recite limitations along the lines of “a maximum DC
`voltage supplied from said battery is at least approximately 500 volts,” “a
`maximum current supplied from said battery is less than approximately 150
`amperes,” and “a ratio of maximum DC voltage to maximum current
`supplied is at least 2.5.” In our analysis of the claims, we adopt the parties’
`short-hand reference to these voltage and current-related limitations as the
`“electrical limitations.”
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`Claims 80 through 83 are illustrative of the claims being challenged:
`
`80. A method for controlling a hybrid vehicle,
`comprising:
`
`determining instantaneous road load (RL) required to
`propel the hybrid vehicle responsive to an operator command;
`
`monitoring the RL over time;
`
`operating at least one electric motor to propel the hybrid
`vehicle when the RL required to do so is less than a setpoint
`(SP);
`operating an internal combustion engine of the hybrid
`
`vehicle to propel the hybrid vehicle when the RL required to do
`so is between the SP and a maximum torque output (MTO) of
`the engine, wherein the engine is operable to efficiently produce
`torque above the SP, and wherein the SP is substantially less
`than the MTO; and
`
`wherein said operating the internal combustion engine to
`propel the hybrid vehicle is performed when: the RL>the SP for
`at least a predetermined time; or the RL>a second setpoint
`(SP2), wherein the SP2 is a larger percentage of the MTO than
`the SP; and
`
`operating both the at least one electric motor and the
`engine to propel the hybrid vehicle when the torque RL
`required to do so is more than the MTO.
`81. The method of claim 80,
`wherein said operating the at least one electric motor
`
`comprises supplying power from a battery;
`
`wherein a ratio of maximum DC voltage to maximum
`current supplied is at least 2.5.
`82. The method of claim 81, wherein the maximum
`DC voltage is at least approximately 500 volts.
`83. The method of claim 81, wherein the maximum
`current is less than approximately 150 amperes.
`Ex. 1201, 65:11–42.
`
`
`
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`IPR2015-00758
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`The Asserted Grounds of Unpatentability
`C.
`Ford asserts three grounds of unpatentability under 35 U.S.C. § 103,
`
`namely, that claims 161–166 and 215–220 are unpatentable as obvious over
`Severinsky,2 that claims 80–85 and 114–119 are unpatentable as obvious
`over the combination of Severinsky and Frank,3 and that claims 86–90, 120–
`124, 167–171, 221–225, and 294 are unpatentable as obvious over the
`combination of Severinsky, Frank, Field,4 and SAE 1996.5 Pet. 4.
`III. ANALYSIS
`In this preliminary proceeding, we decide whether Ford has made a
`
`threshold showing, supported by sufficient evidence, of a reasonable
`likelihood that the challenged claims are unpatentable. As our decision is
`preliminary, we construe the claims only to the extent necessary without
`making a final determination until the parties have had a full and fair
`opportunity to present all evidence and argument in support of their case.
`A.
`Claim Construction
`In an inter partes review, claim terms in an unexpired patent are given
`
`their broadest reasonable construction in light of the specification of the
`patent in which they appear. 37 C.F.R. § 42.100(b). This standard involves
`determining the ordinary and customary meaning of the claim terms as
`would be understood by one of ordinary skill in the art reading the patent’s
`entire written disclosure. In re Translogic Tech., Inc., 504 F.3d 1249, 1257
`(Fed. Cir. 2007). Any special definition for a claim term must be set forth
`
`
`2 U.S. Patent No. 5,343,970, iss. Sept. 6, 1994 (Ex. 1203).
`3 U.S. Patent No. 5,842,534, iss. Dec. 1, 1998 (Ex. 1204).
`4 PCT Int’l Pub. WO 93/23263, pub. Nov. 25, 1993 (Ex. 1242).
`5 Kozo Yamaguchi, Development of a New Hybrid System—Dual System,
`SAE SPECIAL PUBLICATION SP-1156, pub. Feb. 1996 (Ex. 1230).
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`with reasonable clarity, deliberateness, and precision. In re Paulsen, 30 F.3d
`1475, 1480 (Fed. Cir. 1994). Here, our review centers on the construction of
`two claim terms—“road load (RL)” and “setpoint (SP).”6
`
`1.
`“road load” or “RL”
`The term “road load” or “RL” appears in each of the challenged
`independent claims. The specification of the ’634 patent defines “road load”
`as “the vehicle’s instantaneous torque demands, i.e., that amount of torque
`required to propel the vehicle at a desired speed,” and further notes that it
`“can be positive or negative, i.e., when decelerating or descending a hill, in
`which case the negative road load . . . is usually employed to charge the
`battery bank.” Ex. 1201, 12:42–61. Thus, consistent with the specification,
`we construe “road load” and “RL” as “the amount of instantaneous torque
`required for propulsion of the vehicle, be it positive or negative.”7
`2.
`“setpoint” or “SP”
`The term “setpoint” or “SP” is recited in four of the five challenged
`
`independent claims, namely, claims 80, 114, 161, and 215. Ford proposes
`that “setpoint” or “SP” be construed, in the context of these claims, as a
`“predetermined torque value.” Pet. 8–9. In that regard, Ford correctly notes
`that the claims compare the setpoint either to an engine torque value or a
`torque based “road load” value. Id. For example, each of claims 80, 114,
`161, and 215 recites operating the engine “when the RL [road load] required
`
`
`6 Ford also contends that the terms “low-load mode I,” “highway cruising
`mode IV,” and “acceleration mode V” are in need of construction. Pet. 10.
`Those terms are expressly defined by claim 161. Ex. 1201, 73:53–74:3. As
`such, no further construction is necessary.
`7 This construction is essentially the same as that proposed by Ford. Pet. 8.
`Paice does not propose a different construction. Prelim. Resp. 6.
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`to do so is between the SP [setpoint] and a maximum torque output (MTO)
`of the engine.” See, e.g., Ex. 1201, 65:19–22 (claim 80). Moreover, each of
`these claims speaks of the setpoint, or “SP,” as being the lower limit of a
`range in which the engine can produce torque efficiently, i.e., “wherein the
`engine is operable to efficiently produce torque above the SP, and wherein
`the SP is substantially less than the MTO.” Id. at 65:22–24. This language
`suggests that the setpoint, or “SP,” is not just any value, but a value that—
`per the surrounding language—equates to a “torque” value.
`
`Although Paice correctly notes that the specification, outside of the
`claims, describes two parameters, i.e., road load and “the state of charge of
`the battery bank,” as being measurable against respective setpoints (Prelim.
`Resp. 12, citing Ex. 1201, 40:16–26), the claim language makes clear that
`setpoint relates to a torque value and not a battery charge. Phillips v. AWH
`Corp., 415 F.3d 1303, 1314 (Fed. Cir. 2005) (en banc) (“the claims
`themselves provide substantial guidance as to the meaning of particular
`claim terms . . . the context in which a term is used in the asserted claim can
`be highly instructive”) (citations omitted).
`
`Paice also argues that “setpoint” or “SP” is the point at which the
`vehicle transitions from one operational mode to another, and in particular,
`the transition from a mode when only the motor propels the vehicle to modes
`when the engine can also be used to propel the vehicle. Prelim. Resp. 8–12.
`Citing the specification, Paice argues that “setpoint” is synonymous with a
`“transition point.” Id. at 9–10. Accordingly, Paice urges that the
`construction of “setpoint” or “SP” must be construed to indicate a point at
`which a transition between different operating modes may occur. Id. at 11–
`12.
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`Paice’s argument is misplaced. Although the specification sometimes
`uses “setpoint” interchangeably with “transition point,” elsewhere it
`acknowledges that the mode of operation does not always transition, or
`switch, at the setpoint, but instead depends on a number of parameters. For
`instance,
`the values of the sensed parameters in response to which the
`operating mode is selected may vary depending on recent
`history . . . , so that the operating mode is not repetitively
`switched simply because one of the sensed parameters
`fluctuates around a defined setpoint.
`Ex. 1201, 19:67–20:6 (emphasis added). That disclosure suggests that a
`transition does not spring simply from the recitation of “setpoint.” Rather,
`the claims make clear that the “setpoint” is the lower limit at which the
`engine is capable of producing torque efficiently, and make no mention of
`this lower limit as being a “transition” point. As such, we will not import
`into the meaning of “setpoint” an extraneous limitation that is supported by
`neither the claim language nor the specification.
`
`Finally, we regard as meaningful that nothing in the specification
`precludes a setpoint from being reset, after it has been set. A setpoint for
`however short a period of time still is a setpoint. Thus, we construe
`“setpoint” and “SP” as a “predetermined torque value that may or may not
`be reset.”
`B.
`Claims 80–90, 114–124, 161–171, 215–225, and 294—
`
`Obviousness over Severinsky, Frank, Field, and SAE 1996
`To begin, Ford provides a detailed analysis of how Severinsky
`satisfies the general hybrid configuration and torque control scheme of the
`
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`challenged claims.8 Pet. 11–33. Ford then relies on Frank, in combination
`with Severinsky, as teaching the time delay, or “hysteresis,” limitations of
`the challenged claims (id. at 33–37) and relies on Field and SAE 1996 as
`teaching the dual-motor limitations (id. at 40–42). Finally, Ford explains
`persuasively, with supporting evidence, why a skilled artisan would have
`been led to utilize Frank’s hysteresis feature with Severinsky’s setpoint to
`prevent unwanted or excessive cycling of the engine (id. at 37–38), as well
`as why a skilled artisan would have been motivated to add another motor, as
`taught by Field and SAE 1996, to the hybrid configuration of Severinsky to
`overcome inefficient operation of the engine during urban driving (id. at 42–
`49).
`At this stage, Paice argues that the Petition “fails to provide an
`
`adequate obviousness analysis” and that Severinsky, either alone or in
`combination with Frank, Field, and/or SAE 1996, fails to satisfy the
`“setpoint” and “road load-based hysteresis limitations” of the claims.
`Prelim. Resp. 13. Paice further contends that the Petition “runs afoul of 35
`U.S.C. 325(d)” and is “procedurally improper.” We address these
`arguments in order.
`
`1.
`The Obviousness Analysis
`
`Paice asserts that Ford fails to identify differences between the
`claimed invention and the prior art, and that, as to certain claim elements, it
`is unclear whether Ford is saying that Severinsky anticipates the claim
`element or simply renders it obvious. Prelim. Resp. 31–33. We are not
`
`8 Ford’s declarant, Dr. Gregory W. Davis, confirms the teachings of
`Severinsky with respect to the basic hybrid configuration and functions
`recited by the challenged claims, i.e., the engine, motor, battery, and
`controller limitations. Ex. 1207 ¶¶ 173–196, 200–213.
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`persuaded by Paice’s assertions. As discussed above, Ford’s claim chart
`clearly indicates the disclosure from Severinsky that corresponds to each
`claim limitation, and includes a representation of the extent to which that
`disclosure satisfies the corresponding claim limitation. See, e.g., Pet. 11–17,
`22–23, 30–33. Further, Ford identifies the specific claim limitations on
`which it relies upon the teachings of Frank, Field, and/or SAE 1996, and
`explains sufficiently a reason to combine those references with Severinsky.
`See, e.g., id. at 35–47. Based on that detailed analysis, we are persuaded that
`Ford has complied with its threshold burden of demonstrating a reasonable
`likelihood in proving that the challenged claims would have been obvious.
`2.
`The “Setpoint” Limitations
`
`Similar to its preliminary responses in related inter partes reviews,
`
`Paice maintains that Severinsky does not disclose a “setpoint.” Prelim. Resp.
`34–39. We are not persuaded. Paice’s argument is premised on an improper
`construction of the meaning of “setpoint.” According to Paice, “any proper
`construction of setpoint must account for its function of marking the
`transition from one claimed mode to another.” Id. at 34. But, as discussed
`above, we have not adopted Paice’s construction. At this juncture, we are
`persuaded that Severinsky evinces a “setpoint” that accords with our
`construction of the term. See Pet. 14–17.
`3.
`The Hysteresis Limitations
`
`
`Paice contends that Ford offers no rational basis for combining the
`purportedly “speed-responsive hysteresis” teachings of Severinsky and
`Frank to arrive at the load-based hysteresis control scheme of the claimed
`invention. Prelim. Resp. 39–43. This argument is unpersuasive.
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`Severinsky expressly contemplates a “hysteresis” feature that utilizes
`a time delay to reduce undesirable engine starts. Specifically, Severinsky
`provides:
`At moderate speeds, as experienced in suburban driving,
`the speed of the vehicle on average is between 30–45 mph. The
`vehicle will operate in highway mode with the engine running
`constantly after the vehicle reaches a speed of 30–35 mph. The
`engine will continue to run unless the engine speed is reduced
`to 20–25 mph for a period of time, typically 2–3 minutes. This
`speed responsive hysteresis in mode switching will eliminate
`nuisance engine starts.
`Ex. 1203, 18:34–42 (emphasis added). And, likewise, Ford points to Frank
`as confirming it was well known to utilize a hysteresis time delay in a hybrid
`control strategy to prevent excessive cycling of the engine. Pet. 35–42
`(citing Ex. 1204, 8:4–11). Ford also relies on Frank for teaching the use of a
`second on-off setpoint slightly offset from a first setpoint, also to reduce
`undesirable cycling of the engine. Id.
`
`In the context of the disclosures by Severinsky and Frank lies the
`teaching of a hysteresis time delay that depends on the engine being in a
`particular state for a period of time between on and off modes. That Frank
`also may disclose the hysteresis feature as being “speed-responsive” does
`not negate or detract from its overall teaching of applying a time delay to an
`on-off setpoint to prevent frequent cycling between the engine and motor in
`a hybrid vehicle. Indeed, Ford’s declarant, Dr. Gregory W. Davis, explains
`that “[h]ysteresis mechanisms were frequently employed in traditional
`automatic transmissions, for example, in order to prevent excessive shifting
`between gears.” Ex. 1207 ¶ 346. Dr. Davis also confirms that “[a] person of
`ordinary skill in the art would have been familiar with these techniques to
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`prevent adverse effects from rapid switching when the vehicle operation
`hovers around a particular setpoint” and “would have been familiar with
`using a time-delay in responding to the setpoint between modes in a hybrid
`vehicle, as disclosed by Frank.” Id.
`
`With that background in mind, we credit the testimony of Dr. Davis
`that a skilled artisan would have been led to incorporate Frank’s hysteresis
`time delay with Severinsky’s engine control strategy because both hybrid
`strategies utilize a threshold, or “setpoint,” for switching the engine on and
`off. Ex. 1207 ¶¶ 345–349. Also, given that Severinsky’s setpoint accounts
`for both speed and torque, we are not persuaded by Paice’s contention that
`the proposed combination would result in a “speed-responsive” hysteresis
`control scheme, as opposed to a torque-responsive control scheme that
`simply incorporates a time delay, as taught by Frank. See id. ¶ 375. On the
`current record, we are persuaded that Severinsky’s teaching of a setpoint that
`is a predetermined torque value, along with its teaching of using that torque
`value to start and stop the engine, provides sufficient support for Ford’s
`contention that the combination of Severinsky and Frank results in a torque-
`based strategy that meets the hysteresis limitations of the challenged claims.
`See Pet. 35–42.
`
`
`4.
`Paice’s Discretionary and Procedural Arguments
`Paice argues at length that Ford’s Petition should be dismissed under
`35 U.S.C. § 325(d) because it amounts to a “fifth shot at the ’634 patent”
`and is “designed to drive up costs and overburden Paice with multiple
`proceedings.” Prelim. Resp. 14; see also id. at 17–18 (arguing harassment).
`We are not persuaded. Although this latest Petition may assert some of the
`same prior art as Ford’s earlier petitions, it asserts that art in different
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`combinations and challenges different dependent claims from a patent that
`includes over 300 claims in total. Thus, notwithstanding Paice’s arguments,
`we exercise our discretion and consider the instant Petition.9
`
`We also have considered Paice’s argument that the Petition
`“improperly incorporates by reference” various arguments from the
`declaration of Dr. Davis. Prelim. Resp. 25–29. In general, arguments must
`not be incorporated by reference from one document into another document.
`37 C.F.R. § 42.6(a)(3). Here, in challenging certain claims, Ford relies on
`Dr. Davis’ testimony as evidence of what a skilled artisan would have
`understood from reading Severinsky’s disclosure at the time of the claimed
`invention. See, e.g., Pet. 15, 16, 19, 22, 29 (citing Ex. 1207). We have
`reviewed those portions of Dr. Davis’ declaration, to which Paice directs us,
`and determine that there is nothing unusual about Dr. Davis’ declaration or
`the way in which Ford relies on it insofar as incorporation by reference is
`concerned, at least not to the extent that we would disregard the Petition in
`its entirety.
`
`
`9 Paice also faults Ford for using prior decisions from related inter partes
`reviews as a “roadmap to concoct new prior art combinations and
`arguments.” Prelim. Resp. 18. This argument is not persuasive. As long as
`a petitioner is not time-barred or otherwise estopped (see, e.g., 35 U.S.C.
`§ 315), it is not per se unlawful or inequitable for a party to rely on a prior
`decision to its benefit in order to wage additional challenges on the same
`patent where sufficient justification exists for the subsequent challenge and
`it does not amount to an abuse of process. Here, Ford provides sufficient
`justification for its multiple challenges of the ’634 patent. See Pet. 1
`(explaining that the ’634 patent has 306 claims, Paice refuses to limit the
`number of asserted claims against Ford, and “Ford is filing several IPRs . . .
`to group the claims according to claimed subject matter”).
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`Paice further contends that Ford improperly incorporates by reference
`“other sections of the Petition” through a purportedly “complicated web of
`internal cross-reference citations.” Prelim. Resp. 27–28. We disagree.
`There is no per se rule against internal cross-referencing. Indeed, if
`carefully done, it avoids duplication and renders the Petition more readable.
`Contrary to Paice’s perception, we do not perceive any lack of clarity issues
`with Ford’s use of internal cross-referencing in the instant Petition.
`
`In addition, Paice does not persuade us that we should disregard the
`Petition on the basis of a purported “voluminous record.” Prelim. Resp. 29–
`30. Voluminous records are not necessarily improper. Here, Ford is
`challenging 45 claims from a patent that includes over 300 claims. It would
`not be unusual, therefore, for the evidence in support of unpatentability of
`the challenged claims to be more voluminous than would accompany a
`petition where far fewer claims are challenged. Thus, we do not perceive the
`volume of Ford’s submissions as out of the ordinary.
`
`IV. CONCLUSION
`Based on our review of the evidence and arguments presented in the
`
`Petition and Preliminary Response, we determine that Ford has
`demonstrated a reasonable likelihood of succeeding in proving that claims
`161–166 and 215–220 are unpatentable as obvious over Severinsky, that
`claims 80–85 and 114–119 are unpatentable as obvious over Severinsky and
`Frank, and that claims 86–90, 120–124, 167–171, 221–225, and 294 are
`unpatentable as obvious over Severinsky, Frank, Field, and SAE 1996. As
`such, we institute inter partes review of the challenged claims. This
`institution decision, however, should not be construed as a final
`determination with respect to either claim construction or patentability.
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`V. ORDER
`Accordingly, it is hereby:
`
`ORDERED that, pursuant to 35 U.S.C. § 314(a), an inter partes
`
`review of claims 80–90, 114–124, 161–171, 215–225, and 294 of the ’634
`patent is instituted on the grounds of obviousness under 35 U.S.C. § 103;
`and
`FURTHER ORDERED that, pursuant to 35 U.S.C. § 314(c) and 37
`
`C.F.R. § 42.4(b), inter partes review of the ’634 patent shall commence on
`the entry date of this Order, and notice is hereby given of the institution of a
`trial.
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`IPR2015-00758
`Patent 7,237,634 B2
`
`FOR PETITIONER:
`Frank A. Angileri
`John P. Rondini
`John M. Halan
`Todd W. Dishman
`BROOKS KUSHMAN P.C.
`FPGP0104IPR4@brookskushman.com
`fangileri@brookskushman.com
`jrondini@brookskushman.com
`jhalan@brookskushman.com
`tdishman@brookskushman.com
`Lissi Mojica
`Kevin Greenleaf
`DENTONS US LLP
`iptdocketchi@dentons.com
`
`
`
`
`
`
`
`FOR PATENT OWNER:
`Timothy W. Riffe
`Kevin E. Greene
`Ruffin B. Cordell
`Linda L. Kordziel
`Brian J. Livedalen
`FISH & RICHARDSON P.C.
`IPR36351-0015IPA@fr.com
`riffe@fr.com
`
`16