Patent Owners’ Oral Hearing Demonstratives
`
`Petitioner Ford Motor Company
`v.
`Paice LLC & The Abell Foundation, Inc.
`
`Before Sally C. Medley, Jameson Lee, Kalyan K. Deshpande, and Carl
`M. DeFranco, Administrative Patent Judges
`
`1
`
`PAICE 2219
`Ford v. Paice & Abell
`IPR2015-00792
`
`
`
`Petitioner Ford Motor Company
`v.
`Paice LLC & The Abell Foundation, Inc.
`
`Before Sally C. Medley, Jameson Lee, Kalyan K. Deshpande, and Carl
`M. DeFranco, Administrative Patent Judges
`
`1
`
`PAICE 2219
`Ford v. Paice & Abell
`IPR2015-00792
`
`
`
`Agenda
`
`Three Groups
`
`I.
`
`IPR2015-00722, -00784, -00787, -00790, -00791,
`-00794, -00795
`
`II.
`
`IPR2015-00606, -00799
`
`III.
`
`IPR2015-00758, -00785, -00792, -00800, -00801
`
`2
`
`
`
`Patent/Technology Overview
`
`3
`
`
`
`Technology Background
`
`Starter motor
`
`Engine
`
`Traction Motor
`
`See e.g. IPR ’758, Paper No. 16, POR at 2-3.
`
`4
`
`Controller
`
`Battery
`
`
`
`Technology Background
`
`The hybrid electric vehicle of the
`Paice Patents can be operated in
`various “modes,” i.e. different
`combinations of the motor, engine,
`or both, to propel the vehicle:
`
`Mode I: motor only propulsion
`
`Mode II: motor propulsion,
`engine charges the battery
`
`Mode IV: engine propulsion
`
`Mode V: engine and motor
`propulsion
`
`See e.g. IPR ’758, Paper No. 16, POR at 2-3.
`
`5
`
`
`
`Technology Background
`
`In a number of embodiments, switching between these modes depends
`on an innovative system that compares the “road load” (depicted as a
`solid line in the example from Fig. 7) to a “setpoint.”
`
`Engine + motor
`propulsion
`
`Engine propulsion
`
`Motor only propulsion
`
`See e.g. IPR ’758, Paper No. 16, POR at 2-3.
`
`6
`
`
`
`Technology Background
`
`least one electric
`operating at
`motor
`to propel
`the hybrid
`vehicle when the RL required to
`do so is less than a setpoint (SP)
`
`’634 Patent, Claim 80
`
`internal
`an
`operating
`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
`
`’634 Patent, Fig. 7.
`
`’634 Patent, Fig. 9.
`
`7
`
`
`
`Technology Background
`
`“The rate of change of the
`engine's torque output is
`limited, e.g., to 2% or less
`per revolution, as indicated
`by noting that the dashed
`line in FIG. 7(a), indicating
`the instantaneous engine
`output torque, lags the solid
`line indicating the vehicle's
`instantaneous torque
`requirement. Thus limiting
`the rate of change of engine
`output torque is preferred to
`limit undesirable emissions
`and improve fuel economy”
`
`’097 Patent at 38:62-39:1
`
`’097 Patent at Fig. 7.
`
`See e.g., IPR ’792, Paper No. 16, POR at 3.
`
`8
`
`
`
`Claim Construction
`
`Claim Construction
`
`9
`
`
`
`Previous Claim Constructions
`
`Claim term
`
`Board’s Construction
`
`Patent Owners’ Proposed
`Construction
`
`“road load”
`
`“the amount of instantaneous torque
`required to propel the vehicle, be it
`positive or negative.”
`
`same
`
`“setpoint (SP)”
`
`“predetermined torque value that may or
`may not be reset.”
`
`“abnormal and
`transient conditions”
`
`It is not necessary to expressly construe
`“abnormal and transient conditions”
`beyond determining that such conditions
`encompass starting and stopping the
`engine, in comparison to other disclosed
`conditions of operating the engine
`
`“a definite, but potentially
`variable value at which a
`transition between operating
`modes may occur.”
`
`The Board should construe
`“starting and stopping of the
`engine and provision of
`torque to satisfy drivability
`or safety considerations,” to
`make clear that it does not
`include “city traffic and
`reverse operation.”
`
`10
`
`
`
`New Claim Constructions
`
`Claim term
`
`Patent Owners’ Proposed Construction
`
`“operating at least one
`electric motor to propel
`the hybrid vehicle when
`the RL required to do so
`is less than a setpoint
`(SP)” and like terms
`
`“operating at least one [first] electric motor to
`propel the hybrid vehicle when a comparison of
`the RL to a setpoint (SP) results in a
`determination that the RL required to do so is less
`than a SP.”
`
`See, e.g., IPR ’758, Paper No. 16, POR at 9-14.
`
`11
`
`
`
`Claim Construction Standards
`
`Claims must be read in light of the specification as it
`would be interpreted by one of ordinary skill in the art.
`
`In re Suitco Surface, Inc., 603 F.3d 1255, 1260 (Fed. Cir. 2010).
`
`The construction must not be “divorced from the
`specification and the record evidence” and
`inconsistent with “the one that those skilled in the art
`would reach.”
`
`Microsoft Corp. v. Proxyconn, Inc., 789 F.3d 1292, 1298
`(Fed. Cir. 2015).
`
`See, e.g., IPR ’758, Paper No. 16, POR at 4.
`
`12
`
`
`
`Comparison Terms
`
`‘634 Patent, claim 80
`
`13
`
`
`
`Comparison Terms
`
`FIG. 9 thus shows the main decision
`points of the control program run by the
`microprocessor, with the transition point
`between mode I, low-speed operation, and
`mode IV highway cruising, set at a road
`load equal to 30% of MTO.
`
`‘634 Patent at col. 41:59-62
`
`See, e.g., IPR ’758, Paper No. 16, POR at 12.
`
`14
`
`
`
`Comparison Terms
`
`The Board acknowledges that the Paice Patents compare road load to
`setpoint.
`
`See, e.g., IPR ’758, Paper No. 12, Inst. Dec. at 3.
`
`15
`
`
`
`Comparison Terms
`
`Ford admits that the claims of the Paice Patents require a comparison of
`road load to setpoint.
`
`See, e.g., IPR ’758, Paper No. 1, Pet. at Inst. Dec. at 8-9.
`
`16
`
`
`
`END
`
`17
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