throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of: Cashler
`Attorney Docket No.: 15625-0019IP1
`
`U.S. Patent No.: 5,732,375
`
`Issue Date:
`March 24, 1998
`
`Appl. Serial No.: 08/566,029
`
`Filing Date:
`December 1, 1995
`Title:
`METHOD OF INHIBITING OR ALLOWING AIRBAG
`DEPLOYMENT
`
`
`
`DECLARATION OF DR. KIRSTEN CARR
`
`I, Kirsten Carr, of Ann Arbor, Michigan, declare that:
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`1.
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`I have attached my curriculum vitae as Exhibit 1 to this report. I have
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`summarized my educational and professional background below.
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`2.
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`I received my B.S. degree in Mechanical Engineering from the University of
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`Michigan, Ann Arbor, in 1987 and my M.S. and Ph.D. in Mechanical
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`Engineering from the University of Illinois, Urbana, in 1990 and 1995,
`
`respectively.
`
`3.
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`I joined Ford Motor Company in 1992, working a variety of assignments,
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`including manufacturing research, powertrain quality, occupant safety
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`research, and advance safety sensors. My work in advance safety sensors
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`(2000-2004) included front impact, side impact, rollover, pre-crash, and
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`occupant classification sensor systems. Among other tasks, I was responsible
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`for evaluating occupant classification sensor technologies at various stages
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`
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`Page 1 of 34
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`HN-1003
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`of development and delivering sensor systems capable of meeting the new
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`FMVSS regulations with proven implementation readiness to vehicle
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`programs.
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`4.
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`I join Packer Engineering in 2006 as an expert in mechanical and
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`manufacturing engineering with expertise in forensic analysis of mechanical
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`components, vehicular accidents, industrial equipment, vehicle safety
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`restraint and seat systems, and electromechanical systems. I was responsible
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`for managing and performing mechanical and manufacturing engineering
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`investigations and analyses for legal, insurance, and industrial firms.
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`5.
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`I created Carr Analysis, LLC in 2011, where I am the President and
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`Principal Consultant and continuing my consulting work.
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`6.
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`I have been awarded ten (10) patents in the area of vehicle safety systems.
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`7. My other achievement (publications, presentations, reports, and lectures) are
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`listed on my curriculum vitae.
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`8.
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`9.
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`I am a professional engineer registered in the State of Michigan.
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`In writing this Declaration, I have considered the following: my own
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`knowledge and experience, including my work experience in the fields of
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`vehicle safety systems; my industry experience with those subjects; and my
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`experience in working with others involved in those fields. In addition, I
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`have analyzed the following publications and materials, in addition to other
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`materials I cite in my declaration:
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` U.S. Patent No. 5,732,375 and its accompanying prosecution history
`
`(“the ’375 Patent”, Ex. 1001)
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` German Patent DE 38 09 074 A1 (“Audi”), English Translation and
`
`Translator’s Declaration (Ex. 1004)
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` Japanese Utility Model H3-110966 (“Ohishi”), English Translation and
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`Translator’s Declaration (Ex. 1005)
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` U.S. Patent No. 5,612,876 (“Zeidler”) (Ex. 1006)
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` U.S. Patent No. 5,232,243 (“Blackburn”) (Ex. 1007)
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` Webster’s New World Dictionary of American English, 1991, pg. 937,
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`definition of “occupant” (Ex. 1008)
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`10. Although for the sake of brevity this Declaration refers to selected portions
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`of the cited references, it should be understood that one of ordinary skill in
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`the art would view the references cited herein in their entirety, and in
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`combination with other references cited herein or cited within the references
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`themselves. The references used in this Declaration, therefore, should be
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`viewed as being incorporated herein in their entirety.
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`11.
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`I am not currently and have not at any time in the past been an employee of
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`American Honda Motor Co., Inc. I have been engaged in the present matter
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`to provide my independent analysis of the issues raised in the petition for
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`inter partes review of the ’375 patent. I received no compensation for this
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`declaration beyond my normal hourly compensation based on my time
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`actually spent studying the matter, and I will not receive any added
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`compensation based on the outcome of this inter partes review of the ’375
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`patent.
`
`I.
`
`Person of Ordinary Skill in the Art
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`12.
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`I am familiar with the content of the ’375 patent, which, I have been
`
`informed by counsel, has an earliest possible filing date of December 1,
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`1995 (hereinafter “the Critical Date”). Additionally, I have reviewed the
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`other references cited above in this declaration. Counsel has informed me
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`that I should consider these materials through the lens of one of ordinary
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`skill in the art related to the ’375 patent at the time of the invention. I
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`believe one of ordinary skill around December 1, 1995 would have had a
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`Bachelor of Science in Mechanical Engineering with experience in computer
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`programming and several years of experience in vehicle safety systems or
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`the like. Alternatively, this individual could have a Bachelor of Science
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`Degree in Electrical Engineering, Computer Engineering, or Computer
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`Science with experience in the mechanical arts in addition to the experience
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`described above. Individuals with additional education or additional
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`industrial experience could still be of ordinary skill in the art if that
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`additional aspect compensates for a deficit in one of the other aspects of the
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`requirements stated above. I base my evaluation of a person of ordinary
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`skill in this art on my own personal experience, including my knowledge of
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`students, colleagues, and related professionals at the time of interest.
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`13. My findings, as explained below, are based on my education, experience,
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`and background over the last 30 years as discussed above.
`
`II.
`
`Claim Construction
`
`14.
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`I understand that, for the purposes of my analysis in this matter, the claims
`
`of the ‘375 Patent must be given their broadest reasonable interpretation
`
`consistent with the specification. Stated another way, it is contemplated that
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`the claims are understood by their plain and ordinary meanings except where
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`construed in the specification. I also understand that this “plain and ordinary
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`meaning” is with respect to how one of ordinary skill in the art would
`
`interpret the claim language. I have followed these principles in my analysis.
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`In a few instances, I have discussed my understanding of the claims in the
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`relevant paragraphs below.
`
`III. Audi
`
`15. Audi describes a “safety system for motor vehicles including an inflatable
`
`airbag.” Ex. 1004 (Audi), 2:1-4. The system has an arrangement of sensors
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`in array, including a “front sensor 11 and a rear sensor 12 that measure
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`compressive forces (F1, F2)” on the passenger seat. Id.at 3:17-19, FIG. 1.
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`These sensors are mounted on the seat’s sliding rails. Id. These sliding rails
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`are integral to the seat mount and the seat mount is integral to the passenger
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`seat. Hence, the force sensors are on the passenger seat.
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`16. The “compressive forces (F1, F2)” measured by the sensors are “sent over a
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`line 13 to a control circuit 14, which processes these values in the manner
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`illustrated in Figure 2.” Id at 3:32-46, FIG. 2. This control circuit 14 is
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`Audi’s controller. Id. The control circuit evaluates the output of the sensors
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`to determine whether to allow deployment of the airbag. Id. at FIG. 2. This
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`determination is made based on the force and the force distribution measured
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`by the sensors. For example, if the sum of the forces measured by the force
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`sensors, i.e., “F1+ F2,” is greater than a threshold, constant X, the system will
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`allow deployment of the airbag. Id. at 3:61-4:15, FIG. 2. The force
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`distribution is taken into account, for example, when the “passenger has bent
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`forward a relatively great distance (F1> F2), as indicated by the branch 26,
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`then there is a partial ignition (operation 27).” Id.
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`17. Audi discloses measuring the force detected by each sensor. As described
`
`above, Audi uses a “front sensor 11 and a rear sensor 12 that measure
`
`compressive forces (F1, F2) [and] are mounted on each sliding rail 7.” Id.at
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`3:17-19, FIG. 1. Audi describes that the “measured values determined by
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`the sensors 11, 12 are sent over a line 13 to a control circuit 14, which
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`processes these values in the manner illustrated in Figure 2.” Id at 3:32-46,
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`FIG. 2.
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`18. Audi discloses calculating the total force of the sensor array. Audi describes
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`that the forces (F1, F2) measured with the sensors are summed, “F1+ F2,” to
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`determine whether to enable deployment of the airbag. Id. at 3:61-4:15, FIG.
`
`2, operation 25.
`
`Ex. 1004 (Audi), FIG. 2.
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`
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`19. Audi discloses allowing deployment if the total force is above a total
`
`threshold force. Audi describes a total threshold force, constant X. Id. at
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`3:61-4:15, FIG. 2. If the sum of the front sensor force (F1) and the rear
`
`sensor force (F2) is greater than or equal to X, i.e., “F1+ F2≥ X,” the airbag is
`
`allowed to deploy. Id.
`
`20. Audi discloses defining a plurality of seat areas, at least one sensor located
`
`in each seat area. The arrangement of Audi’s seat sensors 11, 12 defines a
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`seat area in front of the seat center of gravity line (S) containing the front
`
`seat sensor 11 and a seat area behind the seat center of gravity line (S)
`
`containing the rear seat sensor. Id. 3:17-31, FIG. 1. FIG. 1, reproduced and
`
`annotated below, shows the seat areas and the sensors located in each area.
`
`Ex. 1004 (Audi), FIG. 1
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`
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`21. Audi discloses determining the existence of a local pressure area when the
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`calculated total force is concentrated in one of said seat areas. At operation
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`26 in FIG. 2, Audi evaluates whether the front sensor force (F1) is greater
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`than the rear sensor force (F2), i.e., “F1> F2,” to determine the existence of a
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`local pressure area. Id. at 3:32-4:15, FIG. 2. If the total force is concentrated
`
`in the front seat area, i.e., “F1 > F2” at operation 26 is met, Audi determines
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`the local pressure area is in the front seating area, such as the seating
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`position of FIG. 1. Id. at 3:48-60, 3:86-4:61, FIGS. 1-2. If the total force is
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`concentrated in the rear seat area, i.e., “F1> F2” at operation 26 is not met
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`and F2 is greater than F1, Audi determines the local pressure area is in the
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`rear seating area, for example, with the passenger 9 seated resting against the
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`backrest. Id. at 4:6-15, FIG. 2. Either case, Audi determining F1 is greater
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`than F2 or F2 is greater than F1, constitutes determining existence of a local
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`pressure area.
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`22. Audi discloses calculating a local force as the sum of forces sensed by each
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`sensor located in the seat area in which the total force is concentrated. The
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`above disclosure describes the existence of a local pressure area. Audi
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`further discloses “a front sensor 11 and a rear sensor 12 that measure
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`compressive forces (F1, F2) are mounted on each sliding rail 7” and
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`associates the single value, F1, with the compressive forces at the front of
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`the seat and the single value, F2, with the compressive forces at the rear of
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`the seat. Id. at 3:17-31 (emphasis added). “Each” indicates that there is
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`more than one rail, and thus more than one front sensor 11 and more than
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`one rear sensor 12. In my experience, seats typically have two rails, and
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`thus for a typical seat, Audi discloses two front sensors and two rear sensors.
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`Accordingly, Audi discloses that two sensors are summed to produce F1 and
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`two sensors are summed to produce F2. The output of the force sensor(s) 11
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`is “a local force,” as the output of the rear sensors, alone, is not
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`representative of the force applied across the entire seat unless the total force
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`is concentrated in this seat area. Id. Similarly, the output of Audi’s front seat
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`sensor(s) 12 represent “a local force as the sum of forces sensed by each
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`sensor located in the seat area in which the total force is concentrated” for
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`the same reasons. Id.
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`23. Audi discloses allowing deployment if the local force is greater than a
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`predefined seat area threshold force. Audi allows deployment if, in addition
`
`to F1 + F2 ≥ X, the local force in the rear seat area, (F2), is greater than the
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`front seat force (F1). Id. at FIG. 2. Thus, in such an instance, the rear seat
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`force (F2) is “the local force” and the front seat force (F1) is the “predefined
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`seat area threshold force.” The front seat force (F1) is a “predefined” seat
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`area threshold force, because the algorithm that uses the front seat force (F1)
`
`in this comparison was predefined in Audi’s controller. It is my opinion that
`
`one of ordinary skill in the art would not read the language of the claim to
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`require that the value of the threshold force be predefined. Rather, I see
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`nothing in the context of the claim that requires the word “predefined” in the
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`phrase “predefined seat area threshold force” to modify the word “threshold”
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`or the word “force.” Having a predefined threshold or a predefined force are
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`both technically feasible thresholds in an airbag system. Thus, I understand
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`the claim to be broad enough to encompass both a predefined threshold and
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`a predefined force, and believe that one of ordinary skill in the art would
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`read it similarly.
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`24. Also, Audi allows deployment if the front seat force (F1) alone, a local force,
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`is greater than constant X regardless of the value of the rear seat force (F2).
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`Id. at FIG. 2. Thus, in such an instance, the value of the seat area threshold
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`force is equal to the value of constant X. The same is true if the rear seat
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`force (F2) alone, a local force, is greater than constant X. It is my opinion
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`that one of ordinary skill in the art would not read the claim as requiring that
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`the values of the seat areas thresholds and the total force threshold be
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`different, in part, because the claim does not explicitly say they are different
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`values.
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`25. Audi discloses seat areas that overlap so that some sensors are included in
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`more than one seat area and the seat areas include a front area, rear area,
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`right area, and left area. As discussed above, in a typical seat having two seat
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`rails, Audi discloses two front sensors 11 and two rear sensors 12, i.e., a pair
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`of sensors on each rail. The figure below shows the four sensors arranged
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`on the seat rails near the four corners of the seat, which is how I believe
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`Audi’s sensors are arranged. Ex. 1004 (Audi), FIG. 1. Such an arrangement
`
`of sensors defines a front seat area over the two front sensors 11, a rear seat
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`area over the two rear sensors 12, a left seat area over the left front sensor 11
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`and the left rear sensor 12, and a right seat area over the right front sensor 11
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`and right rear sensor 12. Each of these seat areas includes a sensor and each
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`overlap so that some sensors are included in more than one seat area.
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`
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`Audi’s Seat With Multiple Seat Areas
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`IV. Audi in view of Ohishi
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`26. Ohishi discloses controlling an airbag in a vehicle “having first and second
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`sensors 23, 24 that detect weight [] provided in the front end part and the
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`back end part of the seat cushion 13a of the passenger side seat 13.” Ex.
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`1005 (Ohishi) at pg. 8. A third weight sensor 27 is provided on the front
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`floor. Id. “The first, second and third sensors 23, 24, 27 are connected to a
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`controller (controlling means) 28.” Id. at pg. 9. “The controller 28 is
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`connected to an airbag drive circuit 29 that drives the airbag.” Id. “[T]he
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`seating posture of the occupant of the passenger side seat 13 is detected
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`based on the output signal from the first, second, and third sensors 23, 24,
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`27, and the operating condition of the first inflator and the second inflator in
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`the airbag main body 16 is controlled based on these detection results.” Id at
`
`pg. 9. “[I]f the detection results of the seating posture of the occupant
`
`corresponds to [a proper seating posture], the first inflator 19 that is set to
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`have a gas generation amount that is essentially the same level as the inflator
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`of a conventional airbag device is used.” Id. at pg. 11. “[I]f the detection
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`results of the seating posture of the occupant correspond to [no occupant],
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`the first inflator 19 and the second inflator 20 are maintained in a
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`nonfunctioning state.” Id. at pg. 12. “[I]f the detection results for the seating
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`posture of the occupant correspond to [the occupant riding in a standing
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`state] or [a seating posture on only the front end part of the seat cushion 6a],
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`the second inflator 20 that is set to have a smaller amount of gas generation
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`than the first inflator 19 is used.” Id.
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`27. As discussed above, Audi discloses allowing deployment if the sum of the
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`front sensor force F1 and the rear sensor force F2 is greater than or equal to a
`
`“constant X,” i.e., “F1+ F2 ≥ X.” Ex. 1004 (Audi) at 3:61-4:15, FIG. 2. Thus,
`
`deployment is allowed when a local force in the front seat area, front seat
`
`force F1, is greater than constant X, regardless of the value of the rear seat
`
`force F2.
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`28. Ohishi discloses a system for controlling an airbag, similar to Audi’s, having
`
`a seating arrangement with front seat area sensors 23 that output a front seat
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`force w2 and rear seat area sensors 24 that output a rear seat force w3. Ex.
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`1005 (Ohishi) at pg. 8-10 and FIG. 1. The front seat area sensors 23 and rear
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`seat area sensors 24 are “provided in the front end part and the back end part
`
`of the seat cushion 13a of the passenger side seat.” Id. at pg. 8. Ohishi’s
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`system additionally includes floor sensors 27 that output a force value w1. Id
`
`at pg. 8 and 10.
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`29. Ohishi explains that “[i]f w1 < 3 kg weight, w2 < 3 kg weight, and w3 < 5 kg,
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`no occupant is assumed,” and the airbag is “maintained in a nonfunctioning
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`state.” Id. at pg. 11-12. However, “[i]f w1 < 3 kg weight, w2 < 3 kg weight,
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`and w3 ≥ 5 kg, a proper seating posture is assumed,” then “the airbag 18” is
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`set to “inflate[] and deploy[] to protect the head and chest of the occupant.”
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`Id. In other words, upon determining the existence of a local pressure area
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`where the total force is concentrated in the rear seat area, i.e., “w2 < 3 kg
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`weight and w3 ≥ 5 kg,” the airbag is allowed to deploy if the local force
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`measured in the rear seat area, w3, is greater than a fixed, predefined seat
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`area threshold force, 5 kg.
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`30. Applying the comparison of a seat area local force to a fixed, predefined seat
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`area threshold force, as taught by Ohishi, to Audi renders a system in which
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`Audi allows deployment when either the sum of forces is greater than
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`constant X, i.e., F1+ F2 ≥ X, or when the total force is concentrated in the
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`rear seat area, allowing deployment when the local force in the rear seat
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`area, F2, is greater than a fixed, predefined seat area threshold, e.g., 5 kg or
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`some other value.
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`31. Modifying Audi to allow deployment based in part on a comparison of a seat
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`area local force to a fixed, predefined seat area threshold force, as taught by
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`Ohishi, amounts to nothing more than combining prior art elements
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`according to known methods to yield predictable results.
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`32. Also, one of ordinary skill in the art would have been motivated to modify
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`Audi’s system to allow deployment based in part on a comparison of a seat
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`area local force to a fixed, predefined seat area threshold force, as taught by
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`Ohishi, because the modification would result in addition control options
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`over the deployment of the airbag. For example, the modified system would
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`enable allowing deployment of the airbag at a different threshold value than
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`constant X if the passenger’s force is concentrated in a local area of the seat.
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`33. Such a modification does not change the function of Audi’s system, in that
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`the modified system would still instruct the system to allow airbag
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`deployment using a weight and weight distribution on the seat.
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`34. Allowing deployment, in Audi’s system, based in part on a comparison of a
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`seat area local force to a fixed, predefined seat area threshold force would
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`produce the predictable result of allowing deployment if the total weight
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`applied to the seat is greater than or equal to the threshold constant X, as
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`well as if the weight applied to a seat area is over another fixed threshold
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`force.
`
`V.
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`Zeidler
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`35. Zeidler discloses a method of airbag control in a vehicle having an array of
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`force sensors on the passenger seat coupled to a controller for determining
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`whether to allow airbag deployment based on sensed force and force
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`distribution. For example, Zeidler describes a “device for detecting seat
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`occupancy in a motor vehicle, especially for inhibiting airbag release when a
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`seat is unoccupied.” Ex. 1006 (Zeidler), Abstract. Zeidler has “a seat
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`occupancy sensor, which is integrated in a seat cushion, and an associated
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`evaluation circuit.” Id. at 1:10-12. Zeidler describes “[t]he front sensing
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`region 3.1 detects seat occupancy on the front region of the seat, close to the
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`seat edge, and emits a corresponding signal V’.” Id. at 2:41-49. “In an
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`analogous manner, the rear sensing region 3.2 detects seat occupancy in the
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`rear region, close to the backrest 2, and emits a corresponding signal H’.” Id.
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`at 2:41-49. Zeidler explains that the occupancy sensor has “a first pressure
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`sensor 10.1 for the front sensing region and a second pressure sensor 10.2
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`for the rear sensing region.” Ex. 1006 (Zeidler) at 4:56-59, FIG. 3. The
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`‘375 Patent uses “pressure sensors” as force sensors. Ex. 1001 (‘375 Patent)
`
`at 3:11-32. The ‘375 Patent can do this, because pressure is a measure of
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`force per unit area (pressure = force / area), and thus pressure sensors
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`provide an indication of the amount of force applied to the seat. Similarly,
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`Zeidler uses pressure sensors as force sensors. Ex. 1006 (Zeidler) at 2:53-56
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`and 4:29-42.
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`Ex. 1006 (Zeidler) at FIG. 3.
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`
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`36. Zeidler has a controller having an “evaluation circuit,” and in some instances
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`an additional “initial evaluation circuit.” Id. at 2:64-3:3, 5:12-19, FIGS. 1-3.
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`The sensors supply the inputs V and H into the evaluation circuit 4 shown in
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`FIG. 2. Id. at 2:64-3:3 (“V and H are provided [] by signals V’ and H’
`
`respectively”) and 5:17-19 (V” and H” can drive, for example, the two
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`inputs 4.1, 4.2 of the evaluation circuit 4 in FIG. 2”). While Zeidler
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`contemplates controlling based on the actual values of V and H, the primary
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`example in Zeidler is described using “logic signals having the occupancy
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`status “1” for an occupied sensing region and “0” for an unoccupied sensing
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`region.” Id. at 3:37-39. In the example using logical signals, the occupancy
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`status of the sensors is representative of the force applied to the sensor and
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`describes the front-rear seating position, or force distribution, of the
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`occupant. Id. at 1:55-59, 2:64-3:3, 4:37-42.
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`Id. at FIG. 2.
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`
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`37. Zeidler’s controller allows airbag deployment based on the input from each
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`sensing region. Id. at 3:45-65. Zeidler further describes that its system can
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`determine the seating position of the occupant from the sensors, including
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`whether the occupant is sitting in the front or back of the seat. Id. at 1:55-
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`59. Zeidler includes the following chart indicating the algorithm performed
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`by its controller for different inputs V and H. For Measures A and C, the
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`airbag deployment is inhibited. For Measure B, the airbag deployment is
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`allowed. Id. at 3:34-4:5.
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`
`
`
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`Ex. 1006 (Zeidler) at 3:45-50.
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`38. Zeidler discloses measuring the force detected by each sensor. Zeidler’s
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`controller measures the output of each sensor in its array to determine the
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`occupancy state, occupied or unoccupied, of the seating areas. Id. at 2:42-
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`47, 3:33-55. Even if Zeidler merely determines whether the sensors are
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`registering a zero (unoccupied) or a non-zero (occupied) value, Zeidler is
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`“measuring the force detected by each sensor.”
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`39. Zeidler speaks in terms of occupancy status of an “occupant” and their
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`“sitting position.” Id. at 1:55-59, 2:57-61, 3:19-23, 4:6-28. In my opinion, it
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`would be clear to one of ordinary skill in the art that Zeidler is concerned
`
`with determining that the seat is occupied by a person, and particularly a
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`person of an appropriate weight for the airbag to deploy. Ex. 1007
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`(Webster’s New World Dictionary), defining occupant as “a person who
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`occupies a house, post, etc.” (emphasis added). To determine occupancy by
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`a person using pressure sensors, Zeidler is determining whether or not the
`
`sensors read a force (or pressure indicative of a force) of a magnitude
`
`corresponding to a person in the sensing region. To make this
`
`determination, Zeidler must read the magnitude output by the sensors, i.e.,
`
`measure the force detected by each sensor.
`
`40.
`
` Zeidler discloses calculating the total force of the sensor array. Zeidler’s
`
`controller calculates the total force of its sensor array by calculating whether
`
`each of the sensors is outputting a zero or non-zero value (e.g., the
`
`magnitude of an occupant) and assigning them an occupied or unoccupied
`
`status. Id. at 3:34-67. Determining whether the sensor output is zero or non-
`
`zero is a “calculation,” performed by the processor of the controller. The
`
`determination represents the “total force of the sensor array,” as recited in
`
`the claims, in that it uses input from the totality of the sensors, i.e. all of the
`
`sensors. Id. In my opinion, a person of ordinary skill in the art would not
`
`read the claim to require that the “total force of the sensor array” be a
`
`numerical sum of the force measurements. Rather, I see nothing in the
`
`context of the claim that requires the word “total” to be a sum of values. For
`
`example, “calculating the total force of the sensor array” could be read as
`
`requiring the force to be calculated for each sensor in the array.
`
`Page 21 of 34
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`

`
`41.
`
` Zeidler discloses allowing deployment if the total force is above a total
`
`threshold force. “Measure B”, marked below, occurs when Zeidler’s
`
`controller determines the total force of both seat sensors as occupied, i.e. 1
`
`and 1.
`
`
`
`Ex. 1006 (Zeidler) at 3:45-50 (Annotated).
`
`42. The total threshold force, in this instance, is when both sensors are
`
`determined to be occupied (a value of “1”). While displayed in this chart as
`
`a logical values, as mentioned above, these logical values correspond to an
`
`actual force, either the sensor reading a non-zero force value or a magnitude
`
`corresponding to occupancy by a person.
`
`43. Zeidler discloses defining a plurality of seat areas, at least one sensor located
`
`in each seat area. As explained above, Zeidler describes a front sensing
`
`region and a rear sensing region. Id. at Abstract. The sensing regions define
`
`seat areas. Each seat area includes at least one sensor. As Zeidler describes,
`
`“FIG. 3 shows a plan view of the membrane pressure sensor according to the
`
`Page 22 of 34
`
`

`
`invention, having a first pressure sensor 10.1 for the front sensing region and
`
`a second pressure sensor 10.2 for the rear sensing region.” Id. at FIG. 3,
`
`4:56-59.
`
`Front
`Seat Area
`
`Rear
`Seat Area
`
`Ex. 1006 (Zeidler), FIG. 3 (annotated)
`
`
`
`44. Zeidler discloses determining the existence of a local pressure area when the
`
`calculated total force is concentrated in one of said seat areas. Based on the
`
`Page 23 of 34
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`

`
`outputs of the sensors from each sensing region, signals H and V, Zeidler’s
`
`controller determines the occupant’s position in the seat. Id. at 2:64-3:14.
`
`For example, Zeidler discloses a situation in which the front sensing region,
`
`or signal H, does not register an occupant while the rear sensing region, or
`
`signal V, does, and vice versa. Id. at 3:45-50. In the former situation, the
`
`evaluation circuit determines that the occupant is sitting in the back of the
`
`seat, while in the latter, the evaluation circuit determines that the occupant is
`
`sitting in the front of the seat. Id. at 1:60-2:8. Both are examples of Zeidler
`
`determining the existence of a local pressure area when the total force is
`
`concentrated in one of said seat areas.
`
`45. Zeidler discloses calculating a local force as a sum of forces sensed by each
`
`sensor located in a seat area in which the total force is concentrated. Zeidler
`
`describes that each sensing region is represented by a single signal, V or H.
`
`Id. at 2:36-49. However, FIG. 3 of Zeidler shows two distinct sets of
`
`“meandering double cables” in each seating region. Ex. 1006 (Zeidler) at
`
`3:29-42, 3:56, FIG. 3. Each pair of meandering double cables represents
`
`two sensors electrically coupled in series. I view each set of meandering
`
`double cables as a discrete sensor, in part because most of the seat area
`
`between the sets of meandering double cables would not register force,
`
`except along the trace connecting the sets of meandering double cables. The
`
`Page 24 of 34
`
`

`
`annotated FIG. 3 from Zeidler below shows the four sensors.
`
`Ex. 1006 (Zeidler), FIG. 3 (annotated)
`
`
`
`46. Since the sensors work by resistance and are coupled in series, where
`
`resistance is additive, the single signal for each sensing region, V or H, is
`
`representative of the sum of the outputs of the two sensors in that region.
`
`Zeidler’s controller calculates the local force of each seat area in its sensor
`
`array by calculating whether each set of sensors is outputting a zero or non-
`
`zero value (e.g., the magnitude of an occupant) and assigning them an
`
`occupied or unoccupied status. Ex 1006 (Zeidler) at 3:34-67.
`
`Page 25 of 34
`
`

`
`47. Yet, even if Zeidler provided only one sensor per seating area, the output of
`
`that one sensor represents “the sum of forces sensed by each sensor located
`
`in the seat area in which the total force is concentrated,” because that one
`
`sensor is the only sensor located in the seat area.
`
`48. Zeidler discloses allowing deployment if the local force is greater than a
`
`predefined seat area threshold force. Zeidler describes one scenario where
`
`the evaluation circuit allows deployment if the rear sensing region (signal
`
`“H”) registers an occupant, even if the front sensing region (signal “V”) does
`
`not. Id. at 3:47, 63-65. The determination that the rear sensing region is
`
`occupied is a determination that the local force is greater than a predefined
`
`seat area threshold, i.e., the threshold for determining occupancy. As
`
`discussed above, the threshold for determining occupancy is whether the
`
`sensing region has a non-zero value (e.g., a magnitude corresponding to a
`
`person).
`
`Ex.
`
`1006 (Zeidler) at 3:45-50 (Annotated).
`
`Page 26 of 34
`
`

`
`49. Zeidler’s arrangement of seat sensors define a front area, a rear area, a right
`
`area and a left area. Ex. 1006 (Zeidler) at FIG. 3. Each of these seat areas
`
`includes a sensor and each overlap so that some sensors are included in more
`
`than one seat area. For example, the illustration below depicts sensors 10.1
`
`in both the front seat area and the left and right seat areas.
`
`
`
`Ex. 1006 (Zeidler), FIG. 3 (annotated).
`
`VI. Zeidler in view of Blackburn
`
`50. As discussed above, Zeidler discloses a method of airbag control that relies
`
`
`
`on a relatively small number of pressure sensors.
`
`Page 27 of 34
`
`

`
`51. Blackburn describes controlling the airbag deployment enable/disable
`
`decision using a more populous array of sensors, in particular an 8 X 8 array
`
`of sensors in the passenger seat. Ex. 1007 (Blackburn) at 9:39-43, 10:21-27,
`
`FIGS. 9-10. Of those 64 sensors, 32 are “weight sensors 302” using a “force
`
`sensing resistor film” that, like the pressure sensors of Zeidler, varies
`
`resistance as force is applied to the film. Id. at 10:66-11:9; see also Ex. 1006
`
`(Zeidler) at 4:37-42. Blackburn describes that “[b]y monitoring the sensors
`
`302, the weight of the occupant on the seat 234 can be determined. Based
`
`upon this determined weight, the controller 250 can control deployment of
`
`the airbag.” Id. at 11:18-21, 14:55-15:48, FIG. 22. While Blackburn’s
`
`particular array of 8

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