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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`U.S. Patent No. 7,601 ,662
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`U.S. Patent No. 8,404,203
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`Filed:
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`Feb. 27, 2008
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`Filed:
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`Jun. 8, 2009
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`Issued:
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`Oct. 13, 2009
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`Issued:
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`Mar. 26, 2013
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`Inventors:
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`Ivor Bull, et al.
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`Inventors:
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`Ivor Bull, et al.
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`Title: Copper CHA Zeolite Catalysts
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`Title: Processes for Reducing Nitrogen
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`Oxides Using Copper CHA Zeolite
`Catalysts
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`DECLARATION OF DR. AI-INIAD MOINI IN IPR2015—01 121,
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`IPR2015-01123, IPR2015-01124, & IPR2015-01125
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`I, Dr. Ahmad Moini, make this declaration in connection with the above
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`referenced Inter Partes Reviews of U.S. Patent Nos. 7,601,662 and 8,404,203.
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`I.
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`Introduction
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`(cid:9)
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`1.
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`I am a Senior Expert and Research Fellow at BASF Corporation.
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`I
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`received a B.S. in Chemistry from Eastern Washington University in 1982 and a
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`Ph.D. in Chemistry from Texas A&M University in 1986. I have been employed
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`by BASF as a scientist for 9 years.
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`2.
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`(cid:9)
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`I am a co~inventor of the patented subject matter that is described and
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`claimed in both the 662 and 203 Patents.
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`Exhibit 2019.001
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`Exhibit 2019.001
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`3.
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`In the course of the previous Inter Partes Reexamination of the 662
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`Patent, I submitted two declarations in support of the patentability of the ‘662
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`patent. My first declaration was submitted to the United States Patent and
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`Trademark Office (“USPTO”) on February 9, 2011. My second declaration was
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`submitted to the USPTO on December 18, 2011.
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`II.
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`BASF’s CuCHA SCR Catalyst
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`4.
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`BASF Corporation sells a copper loaded aluminosilicate CHA
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`(“CuCHA”) zeolite catalyst for use in the selective catalytic reduction of nitrogen
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`oxides in the exhaust treatment system of diesel engines.
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`I am familiar with the
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`product specification for the commercially available CuCHA catalyst sold by
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`BASF. The product specification details the minimums, maximums, and targets
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`for the CHA content, SiO2/A1203 molar ratio (“SAR”) and the copper content,
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`expressed as weight percentage CuO. _The final CuCHA catalyst product that is
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`sold by BASF to customers is made according to the product specification.
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`5.
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`The product specification for the CuCHA catalyst requires that the
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`final zeolite product, prior to Cu exchange, have a % crysta11inity(from X-ray
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`diffraction), relative to a reference CHA material, between‘ This
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`tolerance shows that the zeolite is preferably a pure, highly. crystalline CHA
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`zeolite, which is an aluminosilicate zeolite.
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`Exhibit 2019.002
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`Exhibit 2019.002
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`6.
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`The product specification for the CuCHA catalyst requires that the
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`final product have a SAR between_ with a target SAR of-
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`A7.
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`The product specification for the CuCHA catalyst requires that the
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`final product have a copper content, expressed as weight percentage CuO between
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`— With a target Of-
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`8.
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`The Cu/Al ratio of the product can be computed based on the SAR
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`and copper weight percentage. For example, with a SAR ofI and CuO weight
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`percentage of- the Cu/Al ratio is- The calculation for this Cu/Al ratio is
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`detailed below:
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`0 Since the copper content has been expressed as CuO, this value is first
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`converted to the corresponding amount of Cu. This is done by dividing
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`- CuO by 79.55, thus obtaining moles CuO, and then multiplying by
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`63.55, thus obtaining- Cu.
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`0 Assuming 100 grams of the filter cake, there would be- of copper
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`and -of Si3.Al2O55. -of Cu divided by 63.55 g/mol for Cu
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`results in- mol of Cu in the sample.
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`0 Since Si3;Al2O55 has a molar mass of 1980.44, -of Si31Al2055
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`results in- mol Si3.Al2O65. Therefore, there would be- mol
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`of A1 in this sample.
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`Exhibit 2019.003
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`Exhibit 2019.003
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`0 Dividing the- mol of Cu by 0.0984 mol ofAl, gives the Cu/Al ratio I
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`0
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`It should be noted that the molar mass of the zeolite is an approximation,
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`since there may be small amounts of H+ and/or alkali ions that charge
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`balance the aluminum sites not satisfied by the copper content. These
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`residual amounts will not have a significant impact in the above
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`calculations.
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`9.
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`A final product that meets the “target” specifications includes an
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`’ aluminosilicate CHA zeolite that has a SAR of. and a Cu/A1 ratio 0-
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`10. Utilizing the same chemical and mathematical formulas as detailed
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`above, adjusted as appropriate for different SAR or copper weight percent, the
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`following table shows the calculated Cu/A1 contents of various embodying filter
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`cakes that can be made according to the product specification.
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`11.
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`The CuCHA catalyst is sold as a substrate that is coated with the
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`CuCHA material. The type of substrate on which the CuCHA catalyst is coated
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`includes both flow through substrates and wall flow filters. The CuCHA catalyst is
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`Exhibit 2019.004
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`Exhibit 2019.004
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`specifically made and intended for use in the selective catalytic reduction of
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`nitrogen oxides in the presence of ammonia (i.e., NHg SCR of NOX) in the exhaust
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`treatment system of a diesel engine. The catalyst is disposed downstream of an
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`injector that adds urea to the gas stream (and the urea is then converted to
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`ammonia). The customers who purchase the CuCHA catalyst product do so
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`because of the excellent properties of CuCI-IA material coated on the substrate.
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`(cid:9)
`III. Availability for Cross-Examination
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`12.
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`(cid:9)
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`I realize that this signed declaration Will be filed as evidence in a
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`contested case before the Patent Trial and Appeal Board of the United States Patent
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`and Trademark Office. I also realize that I may be subject to cross examination in
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`the case Within the United States. If such cross examination is required, I Will
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`appear for cross examination within the United States during the time allotted.
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`IV.
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`(cid:9)
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`Jurat
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`13.
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`(cid:9)
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`14.
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`(cid:9)
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Exhibit 2019.005
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`Exhibit 2019.005
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`Executed on February 12, 2016
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`x/’(“~I/K M "*1
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`Dr. Ahmad Moini
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`Exhibit 2019.006
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`Exhibit 2019.006
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