Inter Partes Reexamination No. 95/001,453
`Second Declaration of Pramod Ravindran
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Examiner: DIAMOND, ALAN D
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`Group Art Unit: 3991
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`Confirmation No: 2755
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`In Inter Partes Reexamination of:
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`BULLET AL.
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`Reexamination Control No. 95/001,453
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`Patent No. 7,601,662
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`Issued: October 13, 2009
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`For: COPPER CHA
`ZEOLITE CATALYSTS
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`Mail Stop Inter Partes Reexam
`Central Reexamination Unit
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-14 5 0
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`SECOND DECLARATION OF PRAMOD RA VINDRAN UNDER 37 C.F.R. § 1.132
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`I, Pramod Ravindran, do declare and say as follows:
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`1. I am currently the Manager, Application Engineering North America, for BASF
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`Corporation, the successor in interest to Engelhard Corporation, later known as BASF Catalysts
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`LLC, the patent owner of United States Patent Number 7,601,662 ("the 1662 patent"). I make the
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`following statements based on personal knowledge.
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`2. This is my second declaration in the above-identified reexamination.
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`I previously
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`submitted a declaration dated January 31, 2011 in this matter ("First Declaration").
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`3. I have read the '662 patent. Thus, as stated in my First Declaration, I am familiar with the
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`specification and claims of the '662 patent. I understand that the patent contains claims amended
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`during reexamination directed to a catalyst comprising an aluminosilicate zeolite having the
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`CHA crystal structure, a silica to alumina ratio of about 15 to 150 and an atomic ratio of copper
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`to aluminum from about 0.25 to about 1, with specific claims directed to silica to alumina ratios
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`in the range of 15 to 40 and copper to aluminum ratios in the range of about 0.25 to 0.50.
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`1
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`Exhibit 2004.001
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`Inter Partes Reexamination No. 95/001,453
`Second Declaration of Pramod Ravindran
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`4. Sometime after February 27, 2006, I delivered to Ford Motor Company a core sample
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`with a washcoat Cu-zeolite for evaluation by Ford. A core sample is a honeycomb substrate
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`containing washcoat.
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`5. After delivery of the first Cu-zeolite core sample to Ford, in 2006 and 2007, I sent
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`multiple Cu-zeolite core samples to Ford. All of the samples were delivered to Ford were
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`labeled with the same designation numbers. Those designation numbers were REX-2.XXX. The
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`designation "REX-2XXX" is not the complete designation, as BASF's formulation numbers are
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`proprietary. The fact that all samples that I provided to Ford in 2006 and 2007 were labeled with
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`the same designation numbers means that all samples I provided to Ford were made according to
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`the same formulation. Thus, all of the samples that I provided to Ford were cores having a
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`washcoat of aluminosilicate zeolite with the CHA crystal structure having a silica to alumina
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`ratio of about 30 and a copper to aluminum ratio of about 0.45. These catalyst samples did not
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`contain any materials besides the zeolite, copper, and binder, and thus did not contain any other
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`active components such as platinum.
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`6. I am familiar with the process by which the REX-2XXX formulations were prepared. All
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`samples provided to Ford were prepared by calcining SSZ-13 in air at 640 °C for a period of 16
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`hours, followed by an ammonium nitrate exchange. The samples were then further exchanged
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`five times with copper sulfate solution, with washing between exchanges. After the fifth
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`exchange, each sample was calcined at 640 °C in air.
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`7. The samples were provided to Ford under a secrecy agreement and an agreement that
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`Ford would not analyze the samples. Ford was not told the composition of the zeolite material,
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`and Ford only knew the samples were a Cu-zeolite for evaluation. However, as described above,
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`each catalyst sample provided to Ford was prepared according to the REX-2.XXX formulation to
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`provide aluminosilicate zeolites with the CHA crystal structure having a silica to alumina ratio of
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`about 30 and a copper to aluminum ratio of about 0.45.
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`8. On or about December 17, 2010, I received an e-mail from one of the authors of the Ford
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`SAE publication 2008-01-1025 that was attached as Exhibit B to my First Declaration. In thee(cid:173)
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`mail correspondence, the author confirmed that the sample referred to in the Ford SAE
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`publication 2008-01-1025 in the sample preparation section as ria state-of-the-art Cu/zeolite
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`based SCR formulation[] obtained from a catalyst supplier in 2007 11 was a sample according the
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`REX-2XXX formulation.
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`2
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`Exhibit 2004.002
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`Inter Partes Reexamination No. 95/001,453
`Second Declaration of Prarnod Ravindran
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`I hereby declare that all statements made herein of my own knowledge are true and that all
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`statements made herein on information and belief are believed to be true; and further that these
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`statements were made with the knowledge that willful false statements and the like so made are
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`punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code, and that such willful false statements may jeopardize the validity of the above-identified
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`patent.
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`Respectfully submitted,
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`Dated: December 14, 2011
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`By: ---+-=-z::-'---. )~~~~ ""--
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`Pramod Ravindran
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`(
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`3
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`Exhibit 2004.003