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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 IPR2014-01415
`Patent 8,214,097
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`Patent Owner’s Preliminary Response to
`Petition for Inter Partes Review of U.S.
`Patent No. 8,214,097
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`Page 1 of 18
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`Patent No. 8,214,097
`Patent Owner Preliminary Response
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`Case IPR2014-01415
`Attorney Docket No: 36351-0013IP2
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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 ’097 PATENT .................................................. 3 
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`III.  GROUNDS 3 AND 4 ARE DEFECTIVE BECAUSE FORD HAS
`FAILED TO ESTABLISH THAT TAKAOKA QUALIFIES AS A
`PRIOR ART “PRINTED PUBLICATION.” ............................................. 5 
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`IV.  CUMULATIVE GROUNDS OF UNPATENTABILITY ........................ 10 
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`V.  CONCLUSION ............................................................................................ 12 
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`Patent No. 8,214,097
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`Case IPR2014-01415
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`TABLE OF AUTHORITIES
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` Page(s)
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`Cases
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`In re Hall,
`781 F.2d 897 (Fed. Cir. 1986) .......................................................................... 5, 6
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`In re Wyer,
`655 F.2d 221, 210 USPQ 790 (CCPA 1981) ........................................................ 6
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`ResQNet.com, Inc. v. Lansa, Inc.,
`594 F.3d 860 (Fed. Cir. 2010) ......................................................................... 7, 8
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`SRI Int'l, Inc. v. Internet Sec. Sys., Inc.,
`511 F.3d 1186 (Fed. Cir. 2008) ........................................................................ 6, 7
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`Synopsys, Inc. v. Mentor Graphics Corp.,
`IPR2012-00042 (Paper No. 16) (PTAB Feb. 22, 2013) ....................................... 7
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`Statutes
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`35 U.S.C. 102 ............................................................................................................. 9
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`35 U.S.C. § 102(a) ..................................................................................................... 6
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`35 U.S.C. § 103 .......................................................................................................... 5
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`35 U.S.C. § 311(b) ..................................................................................................... 5
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`35 U.S.C. § 313 .......................................................................................................... 1
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`35 U.S.C. § 325(d) ............................................................................................. 10, 12
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`Regulations
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`37 C.F.R. § 1.97(h) .................................................................................................... 8
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`37 C.F.R. § 42.107 ..................................................................................................... 1
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`37 C.F.R. § 42.20(c) ................................................................................................... 5
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`Patent No. 8,214,097
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`77 Fed. Reg. 48680 (Aug. 14, 2012) ....................................................................... 10
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`Case IPR2014-01415
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`77 Fed. Reg. 48756 (Aug. 14, 2012) ....................................................................... 10
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`Other Regulations
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`MPEP § 2001.04 ........................................................................................................ 8
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`MPEP § 2128(I) ......................................................................................................... 6
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`Toshifumi Takaoka et al., A High-Expansion Ratio Gasoline Engine
`for the Toyota Hybrid System ............................................................................... 6
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`Patent No. 8,214,097
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`I.
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`INTRODUCTION
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`Case IPR2014-01415
`Attorney Docket No: 36351-0013IP2
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`Paice and the The Abell Foundation, Inc. (“the Patent Owner” or collectively
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`referred to as “Paice”) respectfully submit this Preliminary Response in accordance
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`with 35 U.S.C. § 313 and 37 C.F.R. § 42.107, responding to the Petition for Inter
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`Partes Review (“the Petition”) filed by Ford Motor Company (“the Petitioner”)
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`against U.S. Patent No. 8,214,097 (“the ‘097 patent”).1 Paice requests that the
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`Board not institute inter partes review because the Petition fails to establish a
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`reasonable likelihood that the challenged claims are unpatentable.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 IPR2014-00570, the Patent Owner presented reasons why Ford lacks
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`standing to challenge the ’097 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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`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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`For example, with respect to Grounds 3 and 4, contrary to the assertions in
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`the Petition, Ford has failed to establish that Takaoka qualifies as a prior art
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`“printed publication.”
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`For Ground 4, the Petition proposes cumulative grounds of unpatentability
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`with respect to the previously filed request for inter partes review IPR2014-00570.
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`Ford has not presented any distinction between these grounds. The Board should
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`deny Ground 4 at least for this reason, but to the extent the Board institutes on one
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`ground, the cumulative grounds should be denied.
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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 the petition.
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`This petition should be denied.
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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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`II. BACKGROUND OF THE ’097 PATENT
`The ’097 patent describes a hybrid vehicle featuring a hybrid control
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`Case IPR2014-01415
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`strategy that reduces emissions during start and operation of the hybrid vehicle.
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`See, e.g., Ex. 1101 at col. 1:24-32 and col. 29:63 to col. 30:12. For example, the
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`’097 patent describes a hybrid control strategy that allows for starting the engine at
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`a near stoichiometric air-fuel ratio and for limiting the rate of increase of engine
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`torque during operation of the hybrid vehicle such that the combustion of fuel in
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`the engine occurs at a substantially stoichiometric air-fuel ratio. See, e.g., id. at
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`col. 27:31-35, col. 29:63 to col. 30:12, col. 37:2-6, col. 37:39-42, and col. 38:62 to
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`col. 39:14. This reduces emission of unburned fuel and improves fuel economy.
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`During the engine startup process of conventional engines, a rich air-fuel
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`mixture on the order of 6-7 times the stoichiometric air-fuel ratio is provided to
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`ensure that some fraction of the fuel is in the vapor phase, since only fuel in the
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`vapor phase can be ignited by a spark. See, e.g., id. at col. 29:64-67. Most of the
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`excess fuel condenses as liquid on the cold cylinder walls and is emitted unburned.
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`See, e.g., id. at col. 29:67 to col. 30:3. In contrast, the hybrid control strategy
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`described by the ’097 patent allows for starting the engine at high speeds, creating
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`turbulence in the combustion chamber that is sufficient to ensure the presence of
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`vapor so that a near-stoichiometric air-fuel mixture can be provided to the engine
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`during the startup phase. See, e.g., id. at col. 30:3-12.
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`Moreover, during operation of conventional engines, the operator’s
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`depressing of the accelerator pedal causes additional fuel to be injected and thus,
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`results in a non-stoichiometric and inefficient combustion. See, e.g., id. at col.
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`39:1-14. By contrast, the ’097 patent describes a hybrid control strategy that
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`allows for limiting the rate of increase of engine output torque during operation to
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`reduce emissions. See, e.g., id. at col. 37:39-42. An example of the hybrid control
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`strategy disclosed by the ’097 patent is illustrated in Figure 7(a) (annotated):
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`The solid line of the graph in Figure 7(a) depicts the vehicle’s instantaneous
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`torque requirement (road load), whereas the dashed line of the graph depicts the
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`engine’s instantaneous output torque. See, e.g., id. at col. 37:51-63. As shown in
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`Figure 7(a) starting at point D, the rate of increase of the engine’s output torque is
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`limited so as to maintain substantially stoichiometric combustion. See, e.g., id. at
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`col. 38:62-65. When this occurs, the engine’s output torque does not meet the road
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`load, and the traction motor and/or starting motor(s) provides the balance of the
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`torque to propel the vehicle (see red cross-hatched annotation in Fig. 7(a)).
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`III. GROUNDS 3 AND 4 ARE DEFECTIVE BECAUSE FORD HAS
`FAILED TO ESTABLISH THAT TAKAOKA QUALIFIES AS A
`PRIOR ART “PRINTED PUBLICATION.”
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`Ground 3 challenges claims 4, 14, and 24 as unpatentable under 35 U.S.C. §
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`103 over Severinsky ’970, Anderson, Yamaguchi, and Takaoka, and Ground 4
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`challenges claims 30 and 34 as unpatentable under 35 U.S.C. § 103 over
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`Severinsky ’970 and Takaoka. These grounds are unsustainable. In particular, it is
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`the petitioner’s burden to establish that a reference qualifies as a prior art “printed
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`publication” and Ford has not met its burden, because Ford has not provided any
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`evidence establishing that Takaoka is a prior art “printed publication.” See 37
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`C.F.R. § 42.20(c); see also In re Hall, 781 F.2d 897, 899 (Fed. Cir. 1986).
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`Consequently, institution should be denied for Grounds 3 and 4, because these
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`grounds rely wholly or in part on Takaoka.
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`Inter partes review may only be requested on the basis of prior art consisting
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`of patents or printed publications. See 35 U.S.C. § 311(b). Thus, the statute itself
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`precludes institution based on a document which has not been established as a
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`patent or printed publication. Since Ford has not presented any evidence that the
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`unauthenticated reference Takaoka qualifies as a prior art “printed publication,” the
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`statute requires that the Petition must be denied as to Grounds 3 and 4.
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`“Public accessibility” is a touchstone of determining whether a reference
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`constitutes a “printed publication.” See, e.g., SRI Int'l, Inc. v. Internet Sec. Sys.,
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`Inc., 511 F.3d 1186, 1194 (Fed. Cir. 2008); see also In re Hall, 781 F.2d at 899.
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`“A given reference is ‘publicly accessible’ upon a satisfactory showing that such
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`document has been disseminated or otherwise made available to the extent that
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`persons interested and ordinarily skilled in the subject matter or art exercising
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`reasonable diligence, can locate it.” See SRI Int'l, Inc. at 1194; see also In re
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`Wyer, 655 F.2d 221, 210 USPQ 790 (CCPA 1981) and MPEP § 2128(I).
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`In the Petition, Ford merely asserts that “Toshifumi Takaoka et al., A High-
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`Expansion Ratio Gasoline Engine for the Toyota Hybrid System, Toyota Technical
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`Review Vol. 47, No. 2 (April 1998) (“Takaoka,” Ex. 1107), which was published
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`in April 1998, is prior art under 35 U.S.C. § 102(a)” (see Petition at 4,) but has not
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`provided any evidence that the Takaoka reference was disseminated or otherwise
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`made available to the public before the priority date of the ’097 patent (the “critical
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`date”.) There is no indication in Takaoka itself regarding to whom, or when, the
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`technical review was ever disseminated. Takaoka is a document designated as
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`“Toyota Technical Review Vol. 47 No. 2 Apr. 1998.” While this may seem to
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`indicate that Takaoka was part of a periodical, nothing indicates that this is a
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`periodical commonly circulated to the relevant public. On this information alone,
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`it is equally likely that this was a periodical that was normally circulated only
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`inside of Toyota. Likewise, even though the document references “Apr. 1998,”
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`this, on its own, does not evidence any dissemination or availability of the
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`document to the relevant public early enough to constitute prior art to the ’097
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`patent. Moreover, the fact that this article may have been located now does not
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`imply that it was available prior to the critical date of the ‘097 patent.
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`Furthermore, Ford has presented no testimony, declaration, or other
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`evidence that Takaoka was disseminated or otherwise made available to the
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`relevant public prior to the critical date.3 There is no declaration from any person
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`3 See, e.g., Synopsys, Inc. v. Mentor Graphics Corp., IPR2012-00042 (Paper
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`No. 16), at *35-36 (PTAB Feb. 22, 2013) (denying institution based on a document
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`where petitioner did not establish that it was a "printed publication"); SRI Int'l, Inc.
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`v. Internet Sec. Sys., Inc., 511 F.3d 1186, 1195-98 (Fed. Cir. 2008) (finding that a
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`paper posted on an open FTP site was not a "printed publication", e.g., due to
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`insufficient evidence of public accessibility via a customary search and insufficient
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`evidence of cataloguing or indexing in a meaningful way); and ResQNet.com, Inc.
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`with personal knowledge of Takaoka stating when this document was created, or to
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`whom it was disseminated. Furthermore, there is no evidence that any person
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`skilled in the art even accessed or received the Takaoka reference prior to the
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`critical date.
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`The fact that the Patent Owner submitted a version of the Takaoka reference
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`in an Information Disclosure Statement (IDS) during prosecution of U.S. Patent
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`No. 7,104,347, which is related to the’097 patent, does not somehow convert
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`Takaoka into a printed publication, nor does this constitute Patent Owner’s
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`admission that Takaoka is prior art to the ’097 patent. See, e.g., ResQNet.com,
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`Inc. v. Lansa, Inc., 594 F.3d 860, 866 (Fed. Cir. 2010); see also 37 C.F.R. §
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`1.97(h); MPEP § 2001.04. Moreover, the Patent Owner specifically stated with the
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`submission of the IDS that “[c]itation of a document herein should not be
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`considered an admission that the disclosure thereof is indeed relevant to the
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`v. Lansa, Inc., 594 F.3d 860, 865-66 (Fed. Cir. 2010) (finding that a user manual
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`was not a "printed publication").
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`invention defined by the claims, nor that the document thus made of record is
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`indeed effective as prior art under 35 USC 102.” See Ex. 1126 at 246. 4
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`Accordingly, since Ford has failed to establish that Takaoka qualifies as a
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`prior art “printed publication,” Grounds 3 and 4 of the Petition should be denied.
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`4 See, e.g., Institution Decision of IPR2014-00832, IPR2014-00835, and
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`IPR2014-00838 (The Board denied institution of all grounds because petitioners
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`have failed to show that the relied upon reference qualifies as prior art for the
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`following reasons: (1) a statement summarizing the Examiner’s rejections
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`suggesting that a document is a publication does not amount to an admission that
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`the document is a prior art “printed publication”; (2) Patent owner’s silence with
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`respect to the Examiner’s contention that a document is prior art is not an
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`admission that the document is in fact a prior art “printed publication”; (3) An IDS
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`filed by the Patent Owner in connection with a patent application does not
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`constitute an admission that the references included in the IDS are prior art; (4)
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`Amending claims in response to the Examiner’s rejection does not amount to an
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`admission that the applied references are prior art.)
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`IV. CUMULATIVE GROUNDS OF UNPATENTABILITY
`Notwithstanding the reasons presented above, this petition (“the ’1415 IPR”)
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`should be denied because Ford’s art and arguments at least with respect to Ground
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`4 are substantially similar to the art and arguments previously presented in
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`IPR2014-00570 (“the ’570 IPR”) filed by Ford against the ’097 patent. The Office
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`may deny institution of an IPR if “the same or substantially the same prior art or
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`arguments previously were presented to the Office.” See 35 U.S.C. § 325(d)
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`(emphases added)); see also 77 Fed. Reg. 48756, 48765 (Aug. 14, 2012); 77 Fed.
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`Reg. 48680, 48685, 48702 (Aug. 14, 2012).
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`In this particular case, Ford simply swaps Takaoka for Anderson in its
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`proposed grounds of unpatentability for claim 30, without any explanation as to
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`why the proposed grounds in the ’1415 IPR are not redundant. See the ’570 IPR at
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`49-50 and the ’1415 IPR at 53-56; see also Ex. 1002 at ¶¶ 356-357 and Ex. 1102 at
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`¶¶ 669-671. In particular, in the ’570 IPR, Ford applies Severinsky ’970 to the
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`limitations referred to as [30.0-30.6] and Anderson to the limitations referred to as
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`[30.7] and [30.8.] Then, in the ’1415 IPR, Ford applies Severinsky ’970 to the
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`limitations referred to [30.0-30.6] and Takaoka to the limitations referred to as
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`[30.7] and 30.8.] See the ’570 IPR at 47-50 and the ’1415 IPR at 51-55.
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`Moreover, Ford uses both Anderson and Takaoka the same way and does not
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`set forth any distinction between Anderson and Takaoka to demonstrate that the
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`proposed grounds are not redundant. Specifically, in support of the proposed
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`rejection under Ground 6 of the ’570 IPR, Ford cites Anderson at page 7:
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`“Emissions - Frequently, one of the principle aims of a hybrid vehicle is to
`reduce vehicle emissions to ULEV (Ultra Low Emission Vehicle) levels.
`Consequently, APU emissions are very important for system success. In
`general, emissions are minimized when a stoichiometric air to fuel ratio
`is maintained by a closed loop feedback system (using an oxygen sensor
`for feedback). In some operating regimes, such as engine starts and
`transients, the stoichiometric ratio is very difficult to maintain resulting in an
`increase in emissions . . . Transients present an emissions problem that is
`largely related to the speed of the transient. The closed loop feedback system
`that maintains the stoichiometric air fuel ratio is sufficient during quasi-
`steady state modes, however, it can only react as fast as the O2 levels can be
`sensed. If the transient is too fast, the engine may run rich, increasing
`CO and HC emissions, or lean, increasing NOx emissions. Some of this
`effect can be reduced using a hybrid strategy that only allows slow
`transients, but this places greater strain on the LLD.” See Ex. 1105 at p. 7
`(emphasis added.)
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`In support of the proposed rejection under Ground 4 of the ’1415 IPR, Ford cites
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`Takaoka at page 2 and 5-6:
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`“(2) In order to achieve a major reduction in emissions, the engine would
`operate with λ = 1 over its entire range, and the exhaust system would use
`a 3-way catalyst . . . (2) By allocating a portion of the load to the electric
`motor, the system is able to reduce engine load fluctuation under conditions
`such as rapid acceleration. This makes it possible to reduce quick
`transients in engine load so that the air-fuel ratio can be stabilized
`easily.” See Ex. 1107 at pp. 2 (emphasis added.)
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`In essence, Ford cites to sections in Anderson and Takaoka describing
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`similar subject matter and uses the same arguments in the ’1415 IPR it had already
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`presented in the ’570 IPR with respect to the feature reciting a controller limiting a
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`rate of increase of engine torque such that combustion of fuel within the engine
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`occurs at a substantially stoichiometric ratio (referred to in the petitions as [30.7]
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`and [30.8].) Thus, Ford presents substantially the same art and substantially the
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`same arguments. Consequently, notwithstanding the reasons mentioned above, the
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`Board should exercise its discretion under 35 U.S.C. § 325(d) to deny at least
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`Ground 4.
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`V. CONCLUSION
`For the reasons set forth above, Patent Owner request that the Board:
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`1.
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`Denies Grounds 3 and 4, because Ford has failed to establish that
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`Takaoka qualifies as a prior art “printed publication”;
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`2.
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`Denies Ground 4, because substantially the same arguments were
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`previously presented to the Office in the ’570 IPR under Ground 6.
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`3.
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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: FPGP0110IPR2@brookskushman.com
`
`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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`Page 18 of 18
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`FORD 1207
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