UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`Filed: October 24, 2016
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`COSTCO WHOLESALE CORPORATION,
`Petitioner,
`
`v.
`
`ROBERT BOSCH LLC,
`Patent Owner.
`____________
`
`Case IPR2016-00038
`Patent 6,292,974
`
`DECLARATION OF DAVID PECK
`
`
`
`
`
`
`
`
`
`
`
`Costco Exhibit 1100, p. 1
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`INTRODUCTION
`I.
`
`I, David Peck, hereby declare the following:
`
`1.
`
`I have been asked by Petitioner Costco Wholesale Corporation to
`
`review: (i) Patent Owner Robert Bosch LLC’s (“Bosch’s”) Responses to the
`
`Petitions for Inter Partes Review, submitted in IPR2016-0034 (Paper No. 26);
`
`IPR2016-0036 (Paper No. 28); IPR2016-0038 (Paper No. 28); IPR2016-0039
`
`(Paper No. 31); IPR2016-00040 (Paper No. 28); IPR2016-00041 (Paper No. 32)
`
`(collectively, the “Responses”); (ii) the patents at issue in each of the six
`
`proceedings, respectively: U.S. Patent Nos. 6,973,698 (the “’698 Patent”),
`
`6,944,905 (the “’905 Patent”), 6,292,974 (the “’974 Patent”), 7,228,588 (the “’588
`
`Patent”), 7,484,264 (the “’264 Patent”), and 8,099,823 (the “’823 Patent”)
`
`(collectively, the “Bosch Patents”); and, (iii) the Declaration of Mr. Martin
`
`Kashnowski, which I understand was submitted by Patent Owner as Exhibit 2007
`
`to the Responses.
`
`2.
`
`I am currently employed as an Advanced Technology Subject Matter
`
`Expert by Mahindra North American Technical Center, Inc. in Troy, Michigan.
`
`3.
`
`From April 1997 through July 2013, I was employed as a Manager of
`
`Advanced Products and Processes Research and Development by Trico Products,
`
`Inc. (“Trico”). As part of my responsibilities at Trico, I worked on advanced wiper
`
`projects, including an advanced direct drive wiper motor and the Innovision
`
`2
`
`Costco Exhibit 1100, p. 2
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`windshield wiper product. During part of my tenure at Trico, I also managed the
`
`test and materials laboratories.
`
`4.
`
`In my present position, I continue to provide engineering consultation
`
`services relating to wiper systems. A copy of my curriculum vitae is attached
`
`hereto as Appendix A.
`
`II. DESIGN AND MANUFACTURE OF FLAT-SPRING WIPERS
`
`5. While at Trico, in the course of my employment, I became familiar
`
`with the windshield wiper product design and development process.
`
`6.
`
`It is my opinion that there are numerous technical aspects that are
`
`accounted for in design and manufacture, all of which contribute to an ultimate
`
`commercial product. None of the Bosch Patents describe or disclose the
`
`engineering or manufacturing methods that would be required to develop a
`
`commercially successful windshield wiper.
`
`7.
`
`By no later than 1997, development of flat-spring wipers would begin
`
`with a generalized design. Preliminary choices such as material and sizing would
`
`be made first. If a flat-spring wiper was to have a spoiler to, for example,
`
`counteract wind-lift, its geometry would have to be determined before calculating
`
`the flat-spring’s required curvature.
`
`8.
`
`By no later than 1997, it was the practice at Trico to design a spoiler
`
`in three stages. First, we would model a spoiler cross-section using commercially
`
`3
`
`Costco Exhibit 1100, p. 3
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`available Computational Fluid Dynamics (“CFD”) software such as FLUENT or
`
`EXA. These computer programs were capable of predicting forces imparted to a
`
`structure by impinging airflow and eddy currents produced in its wake. We would
`
`choose as a spoiler cross-section in the first instance an arbitrarily sloped triangle
`
`that was approximately as tall as the entirety of the structure below it (i.e. the wiper
`
`and wiping element). A CFD simulation would yield the pressures (or suctions)
`
`applied to the various faces of the wiper structure caused by the airflow, the
`
`maximum of which would occur at a wipe angle position of approximately 45-
`
`degrees. We would then vary the curvature, slope, and height of the spoiler until
`
`we were satisfied with the wiper’s performance. The goal was to maximize the
`
`velocity at which the wiper would lift from the glass—in many cases around 120
`
`miles per hour. Second, we would build a prototype and road test it to confirm the
`
`CFD predictions generally. Third, because laboratory testing is very expensive, we
`
`would take actual wind-lift force measurements in a wind-tunnel at various speeds
`
`and angles of wipe to ensure the general design met functionality requirements.1
`
`
`1 Trico’s internal requirements were a composite of those of various vehicle
`
`manufacturers. These covered everything from minimum duty cycles, to wipe
`
`quality across temperatures, to maximum vehicle speed without lift, etc.
`
`4
`
`Costco Exhibit 1100, p. 4
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
` Once the general design of a flat-spring wiper was complete, the next
`9.
`
`step would be to determine the appropriate curvature of the flat blade. This step
`
`would begin with the windshield. For aftermarket wipers, a composite, or
`
`generalized windshield approximating several similar vehicle models, would be
`
`used. After scanning the windshields, a singular, representative curvature profile
`
`would be created.
`
`10. A designer would then seek to conform the wiper blade to this
`
`composite profile for a desired force-intensity distribution. The ’698 Patent, for
`
`example, illustrates some possible variations. See ’698 Patent, figs. 5–7. Using
`
`elementary beam equations, it would be possible to calculate the curvature required
`
`to yield the chosen force distribution. Commercially available, iterative-analysis
`
`computer programs, such as finite-element-analysis (“FEA”) programs, which
`
`applied those equations efficiently, were available from at least as early as 1997.
`
`Since 1997, Trico utilized VariFlex—a custom computer program created by
`
`Adriaan Swanepoel and used by him for some time prior to 1997—which enabled
`
`such calculations to be made very quickly and to account for a greater complexity
`
`of geometries, such as the taper-taper design (discussed below).
`
`11. Any method that can determine which geometry will yield a particular
`
`force profile when pressed against a surface is equally capable of accounting for
`
`non-metal components, such as a rubber wiping strip or superstructure. In fact, by
`
`5
`
`Costco Exhibit 1100, p. 5
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`no later than 1997, the VariFlex program was capable of determining the proper
`
`geometry for a flat-spring wiper with or without a spoiler attached. As long as a
`
`designer knew the properties of the materials to be used, the program could adjust
`
`the output accordingly. In other words, a wiper designer in 1997 would find it
`
`equally simple to run the calculation for a flat-spring wiper alone as it would to run
`
`the calculation for a flat-spring wiper with an attached spoiler. By no later than
`
`1997, designers were quite capable of combining flat-spring wipers with spoilers
`
`and accounting for any effect the structure would have had on wiper’s curvature.
`
`12. Once a final geometry was selected, there were several manufacturing
`
`methods that could have been employed, all of which were available because the
`
`bending process was independent from the geometry selection process. The first
`
`process, which I am familiar with based on my personal experience at Trico, is
`
`known as temper-quench-bending (“TQB”) and used ceramic-quartz molds of the
`
`desired shape to precisely heat and quench the beams. This process was used for
`
`the Trico Innovision Wiper (discussed in detail below), and was fairly advanced in
`
`1997. A second process, known as far back as the late 1980s, used steel strip stock
`
`fed between three rollers—two on one side and one on the other. In this this
`
`process, known as Computer Numerical Controlled, three-roller bending (“CNC
`
`bending”), a computer varies the distance among the rollers as the steel travels
`
`through to result in a particular bend. A third option (never implemented, as far as I
`
`6
`
`Costco Exhibit 1100, p. 6
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`know, but available since the industrial revolution) would have been to press-form
`
`a beam in a form-die.
`
`13. By no later than 1997, the production of a flat-spring wipers entailed
`
`numerous steps requiring design, computer simulation, testing (both road and
`
`laboratory), and engineering know-how. However, none of the Bosch Patents
`
`explain how Bosch designed, manufactured, or imparted curvature to its original
`
`flat-spring wiper products. Nor do any of the Bosch Patents even hint at how to
`
`engineer a successful flat-spring wiper. Furthermore, I have no knowledge of the
`
`means by which Bosch would have determined the appropriate geometry for a
`
`given design (i.e., whether they used CFD for wind-lift, FEA for curvature, or
`
`other computer programs), but I believe that any capable designer at the time
`
`would have had access to and used a similar iterative-design method.
`
`III. THE TRICO INNOVISION PRODUCT
`
`14. While at Trico, I personally participated
`
`in
`
`the design and
`
`development of Trico’s Innovision aftermarket wiper blade product (the
`
`“Innovision Wiper”) and the production lines used to manufacture it. The
`
`Innovision Wiper had a tapered-width, tapered-thickness, variable-curvature flat-
`
`spring support structure that was made by running ribbon coil steel through a
`
`tapered rolling mill and laser-cutting it (a “taper-taper” design). It did not have end
`
`caps because the wiping element was glued to the support structure.
`
`7
`
`Costco Exhibit 1100, p. 7
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`15. Contrary to Mr. Kashnowski’s opinion, the Trico Innovision Wiper
`
`did not “fail[] in the marketplace.” Ex. 2007 ¶ 7. In fact, it was a success. Trico
`
`launched the Innovision Wiper in 2004 and within a year was unable to meet its
`
`customers’ supply demands. Large orders placed by distributors in early 2005
`
`forced Trico to increase its manufacturing capacity in its Brownsville, Texas and
`
`Matamoros, Mexico plants, including by adding extra shifts on the factory floor.
`
`Much of the demand came from NAPA, a U.S. retailer, and Canadian Tire, an
`
`automotive products retailer based in Canada. In my experience, demand this high
`
`constitutes a success.
`
`IV. TESTING AND NOISE PERFORMANCE OF WIPERS
`
`16. From 1997 to 2002, I directly participated in the design and
`
`development of Trico’s flat-spring wiper products. I tracked the progress of the
`
`flat-spring wiper projects through the duration of my employment at Trico
`
`concluding in 2013.
`
`17.
`
`It is my opinion that there are numerous technical aspects that are
`
`accounted for in design, all of which contribute to an ultimate commercial product.
`
`This is true at least as far back as 1997. None of the Bosch Patents describe or
`
`disclose the testing that would be required to develop a commercially successful
`
`flat-spring wiper.
`
`8
`
`Costco Exhibit 1100, p. 8
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`I am not surprised that Mr. Kashnowski writes that the Bosch
`18.
`
`Aerotwin and Icon wiper products were “tested . . . extensively” for, among other
`
`things, “noise.” Ex. 2007 ¶ 6. As of at least 1997, Trico’s aftermarket wiper
`
`products were routinely and comprehensively tested before their market release.
`
`However, this sort of testing is usually performed in artificially quiet conditions.
`
`Testing in a wind tunnel is usually conducted with a vehicle’s engine powered off,
`
`and without road noise, air conditioning or radio. Microphones are fitted to
`
`dummies inside the vehicle that do not distinguish among the various noise
`
`contributions. While such testing is typically “extensive,” its purpose is to provide
`
`a vehicle that is quiet overall. Furthermore, tests directed to mechanical wiper
`
`noise specifically are conducted in a windless, anechoic chamber (i.e. sound-proof
`
`room). I doubt that there would be any way to attribute the “customer demand”
`
`(Ex. 2007 ¶ 6) to the noise testing routinely conducted on aftermarket wiper
`
`products.
`
`19. Mr. Kashnowski states that the Aerotwin and Icon wiper products
`
`were “quiet in operation” when they reversed direction, and suggests that the result
`
`was “great customer demand” for these products. Ex. 2007 ¶ 6. Through the course
`
`of my employment at Trico, I became familiar with the sources of noise associated
`
`with wiper operation. Wiper noise during general operation is a function of many
`
`technical factors including: the design of the motor, the design of the motor linkage
`
`9
`
`Costco Exhibit 1100, p. 9
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`clearances, the rubber selection of the wiping element, and the tendency of the
`
`wiper to enter a failed wiping mode (e.g., chatter), among others. It is difficult to
`
`pinpoint any one factor as the reason a wiper is, or is not, quiet in operation, as all
`
`of the factors influence noise level. It has been my experience that among the most
`
`important and prominent factors is whether a reversing motor is used; a reversing
`
`motor substantially decreases the noise associated with wiper blade reversal.
`
`20. Wiper noise that occurs specifically when “the wiper strip flips from
`
`one side to the other” (Ex. 2007 ¶ 6) is also influenced by many technical factors.
`
`In particular, the clearances in the connection at the coupler between a wiper and
`
`arm, as well as between the various parts of a wiper, arm, and linkages can cause
`
`noise as the wiper reverses. Also, electronically adjusting the speed of the wiper
`
`before reversal can have a tremendous impact on reversal noise.
`
`21. One of the most important sources of noise—and the one most
`
`important to customers—is a blade reversal failure. Wiping elements must
`
`typically perform at an angle of 45 ± 5 degrees relative to the windshield. Thus,
`
`proper reversal requires the element to flip over 90 degrees. If a wiping element
`
`does not flip over during reversal (usually on the down stroke), the blade may
`
`make a distinctive chattering noise and will jump along the windshield, preventing
`
`it from properly clearing the glass. This failure to reverse can be caused by many
`
`factors, including improper wiper material selection and excessive pressure against
`
`10
`
`Costco Exhibit 1100, p. 10
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`the glass. Under such circumstances, the rubber wiping element can develop a
`
`permanent set and become biased more than the 5-degree tolerance required of it.
`
`22.
`
`In my experience, reducing noise in the operation of a wiper blade
`
`product requires evaluating and addressing all the sources of noise. It would be
`
`very difficult to prove that any one of the multitude of factors is responsible for a
`
`wiper being “quiet in operation.”
`
`23. One source of wiper noise that has been uniformly ignored since at
`
`least 1997 is that caused by wind. The wind noise attributable to the more
`
`obtrusive vehicle components, such as rear-view mirrors, far exceeds the noise
`
`attributable to any wiper structure. In fact, mechanical wiper noise is generally
`
`tested in an anechoic chamber—completely ignoring any wind noise for the
`
`purposes of noise testing. Further, when the wipers are in the parked position
`
`(where they spend most of their time) they experience the lowest effects from wind
`
`because of deflection by a vehicle’s hood. I would be very surprised if anyone
`
`could notice wind noise attributable to wipers given all of the other more
`
`substantial contributions.
`
`24. The Bosch Patents’ attribution of wiper noise to more than one source
`
`is consistent with my experience that noise in wiper operation is attributable to a
`
`variety of sources. While the ’698 Patent attempts to reduce reversing noise by
`
`changing the pressure distribution along the length of the blade (’698 Patent, 1:57–
`
`11
`
`Costco Exhibit 1100, p. 11
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`2:4), the ’974 Patent suggests that the addition of a spoiler could reduce
`
`“undesirable noise buildup,” from “friction” (’974 Patent, 1:41–52). I note,
`
`however, that in the ’974 Patent the specific source of noise is not identified and,
`
`as discussed above, wiper wind-noise is generally ignored by designers.
`
`25. On the other hand, none of the disclosures of the ’905, ’588, ’264, and
`
`’823 Patents, discuss (or even mention) noise or the methods of reducing it. Upon
`
`review of these four patents, it is my opinion that the claimed subject matter is not
`
`directed to a wiper that will be “quiet in operation.”
`
`26. As I’ve discussed, prior to 1997, a person with my experience would
`
`have understood how to design a wiper that is quiet in operation based on the
`
`factors that were known to influence wiper noise; that knowledge is not a result of
`
`the disclosures of the ’905, ’588, ’264, and ’823 Patents, nor is it attributable to the
`
`features they claim. Therefore, it cannot be the case that consumer demand for
`
`quiet wipers is related solely—or even marginally—to the features described in
`
`any or each of these four patents. In other words, any success that the Aerotwin or
`
`Icon products enjoyed was the product of engineering, testing, and design that is
`
`not described in the Bosch Patents.
`
`V. CONCLUSION
`
`27.
`
` I reserve the right to elaborate and/or amend the opinions expressed
`
`herein in response to positions taken by or on behalf of Robert Bosch LLC. To
`
`12
`
`Costco Exhibit 1100, p. 12
`
`

`
`Case IPR2016-00038
`DECLARATION OF DAVID PECK
`
`amplify what is stated above, where necessary, and especially in view of
`
`information not presently known to me, I reserve the right to supplement and/or
`
`amend this declaration should additional information be brought to my attention
`
`during the course of this proceeding. It is my understanding that Bosch may not
`
`submit any new information in this proceeding, but in the event that my
`
`understanding is incorrect, I reserve those same rights.
`I
`I understand that this declaration will be filed as evidence in a
`
`28.
`
`contested case before the Patent Trial and Appeal Board of the United States Patent
`
`and Trademark Office. I acknowledge that I may be subject to cross-examination
`
`in the case and that cross-examination will take place within the United States. If
`
`cross-examination is required of me, I will appear for cross-examination within the
`
`United States during the time allotted for cross-examination.
`
`29.
`
`I declare further that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true.
`
`I, DA YID PECK, hereby declare under the penalty of perjury that the foregoing is
`
`true and correct.
`
`David Peck
`
`13
`
`Costco Exhibit 1100, p. 13
`
`

`
`
`
`APPENDIX A
`
`APPENDIX A
`
`Costco Exhibit 1100, p. 14
`
`

`
`David E. Peck
`1349 Kingspath Dr.
`Rochester Hills, Mich. 48306
`(248) 370-9116 (Home)
`(248) 396-1844 (Cell)
`davidepeck@comcast.net
`
`
`
`
`Innovative problem solver with a proven track record of new product development & field problem
`resolution
`
` Highly experienced in managing engineers, designers & technicians to build a goal oriented team
`
` Strong understanding of manufacturing & processes; & how they relate to new products
`
` Ability to work with scientists by finding & defining the commercialization path to new product
`opportunities
`
`
`
`EDUCATION
`
`Detroit Institute of Technology
`Detroit, Michigan
`Bachelor of Science in Mechanical Engineering
`
`Wayne State University
`Detroit, Michigan
`Post-Graduate Courses
`Plates & Shells Analysis, Advanced Calculus, Vehicle / Advanced Vehicle Dynamic & Collision Analysis
`
`Seminars / Training
`
`Ethics (instructors Training & Instructor), Basic Supervisors Training, Manage the Manager, World Class
`Management, Senior Engineering Executive Development Program, Finance for the Non-Financial
`Manager, OPC / SPC, Quality Functional Deployment, Total Quality Management, ISO/QS-9000, Jit,
`Kaizen Gemba, Kanban, Poka Yoke, Lean Manufacturing, Lean Cell, Design for Six Sigma & Public
`Speaking
` 
`
`
`
`
`
`July 16, 2013 – Present
`
`
`
`EMPLOYMENT EXPERIENCE
`Mahindra North American Technical Center
`
`Advanced Technology Subject Matter Expert
`
`Responsible for hydraulic brake systems; rear drive axles; & advanced electric motor design
`
`Supported Mahindra genZe in designing a 2 wheel EV Scooter for the systems battery chargers; battery
`management system; chassis; rear suspensions; front fork; & the adjustable seat systems
`
`TRICO Products Corporation
`
`Manager Advanced Product & Process, R & D
`
`Responsibility is managing the R&D Dept. Past responsibility were managing the Test Lab; Materials Lab;
`
` 1997 – July 2013
`
`Rochester Hills, Mich.Tem;
`
`Warranty; and Document Control Departments. Current R&D project, are for advanced wiper blade
`
`development & a direct drive wiper motor concept. The wiper blade project is in the process of building a
`
`radically new wiper blade product, on a new custom designed production line. The production line uses
`
`
`
`Costco Exhibit 1100, p. 15
`
`

`
`
`
`2
`
`state of the art manufacturing methods, which includes a rolling mill that makes a long thin taper
`
`thickness metal beam, a twin beam cutting solid state diode pumped laser w / fiber optic delivery & a
`
`direct diode laser thermal forming. The line employs a continuous flow concept that is totally software
`
`controlled w / o any hard tools (“virtual tooling”) & started production in March 2002. The motor is a DC
`
`Brushless motor with a planetary gear & on motor electronics. The Direct Drive is currently being
`
`developed for Hyundai & VW, with production scheduled for MY 2011. Other potential applications for the
`
`technology include radiator fans, water pumps, oil pumps, window lifts & etc. Currently working on the
`
`organizing committee for USAutoPARTs, a newly formed pre competitive technology transfer center to
`
`commercialize technologies from the US National Labs for Tier Suppliers to the automotive industry.
`
`TEAM Resources, Incorporated
`
`Consultant
`
`
`1995–1997
`
` Auburn Hills, Mich.
`
`Work with various Tier 1 & 2 automotive suppliers. Current projects include seat mechanisms, wiper /
`
`door systems. Primarily worked on solving various design / manufacturing problems at Johnson Controls
`
`for various seat systems. This involved working with suppliers, the JCI Mechanism/Seat Complete
`
`Groups, Ford Motor Co (PN96, UN93, UN173 & VN127) & Chrysler Corp (JX27). The projects required
`
`working with fine blanking, conventional stamping, automatic assembly w / poka yoke, investment
`
`casting, semi solid injection molded aluminum & injection molded powered metal.
`
`Rockwell International, Automotive Operations
`Chief Eng. Applied Research
`Automotive
`
`1986–1995 Troy, Mich.
`
`Eng. Mgr. Driving Axles
`
`On Hwy. Axles
`
`1982–1985 Troy, Mich.
`
`Mgr. Product Planning & Value Analysis
`
`Brake Div
`
`1980–1982 Troy, Mich.
`
`Mgr. Eng. & Quality Control
`
`Supervisor Brake Eng.
`
`Supervisor, Product Eng. & Specs
`
`
`Brake Div
`
`Brake Div
`
`1979–1980 W. Germany
`
`1977–1979 Troy, Mich.
`
`Trailer Axle Div
`
`1975–1977 Kenton, Ohio
`
`Managed the research department from 1986 to early 1995 for both light and heavy vehicle groups. The
`
`total worldwide sale for these groups in 1995 was $ 3.1 Billion.
`
`Organized, funded and ran various technology transfer projects from Rockwell and non-Rockwell
`
`aerospace organizations to assess the impact of technology synergism’s on products and manufacturing
`
`
`
`Costco Exhibit 1100, p. 16
`
`

`
`
`
`3
`
`methods. Managed various programs that required strong problem solving skills for research projects,
`
`field performance issues and safety concerns.
`
` Brakes–disc / drum (air & hydr), ABS (air), vehicle proportioning (air & hydr) & Brake-by-Wire
`
` Body components–advanced door latches, seat mechanisms and sunroofs
`
` Power trains–clutches, man/auto trans, hubs, drums, rotors, wheels, and single / tandem drive axles
`
` Plastics–injection molded, compression molded (valve cover) & mold fab from 3-D models
`
` Lasers–cutting, welding, heat treating, surface alloying & direct metal deposition
`
`Rockwell Engineer of the Year 1982 – Total Cost Reduction for Axle Housing Design and Manufacture
`
`Franklin University, Columbus, Ohio
`
`1976–1977
`
`Part-time College Instructor–Machine Design A & B
`
`Ford Motor Company, Truck Operations
`
`1971–1975
`
`Engineer–tandem and single axle suspensions, hydraulic brakes, steering and front non-drive axles
`
`Eaton Corporation, Spring and Stamping Division
`
`1969–1971
`
`Engineer / Designer–hot & cold coil springs, bumper guards, filler necks, radiator/gas caps
`
`ASECO Incorporated
`
`1967–1969
`
`Cost Estimator / Purchasing Agent – car doors, Quarter panels and military utility/water tank trailers
`
`Field Performance Issues and Safety Investigations
`
`1971–Present
`
`Heavy truck steering column, motor home brake pedal package, medium truck front axle suspension
`
`bracket, heavy truck 4 spring suspension, school bus axle brake flange, various medium/heavy/school
`
`bus axle spindle welds, transit coach brakes (service/parking), European truck/transit coach brakes, India
`
`truck drive axle, Brazilian drive axle, Australian truck drive axle suspension bracket, truck tandem drive
`
`axle input shaft, various truck/transit coach drive axle suspension brackets, off highway drive axle
`
`carriers, off highway disc brake, mass transit transom arm, various seat recliners and seat tracks. Legal
`
`cases including: 3 heavy truck accidents, air brake dryer quality, aircraft disc brake quality, air actuated
`
`disc brake patent infringement/buss fire & 2 seat belt investigations.
`
`
`
`
`
`
`
`Costco Exhibit 1100, p. 17
`
`

`
`
`
`
`
`PATENTS
`
`Brake Shoe
`
`Method of Manufacturing a Drive Axle Housing
`
`Drive Axle Housing Blank
`
`Modified Fast Fade Drive Axle Housing
`
`Modified Fast Fade Drive Axle Housing
`
`Diametrical Runout Reducer for Rotating Shaft
`
`Unitary Rotational Speed Sensor
`
`4
`
`4,209,084
`
`June 1980
`
`4,756,466
`
`July 1988
`
`4,760,755
`
`Aug 1988
`
`4,841,802
`
`June 1989
`
`4,921,159
`
`May 1990
`
`5,107,158
`
`Apr 1992
`
`5,111,098
`
`May 1992
`
`Antilock Brake System and Method Incorporating a Pressure Feedback
`
`5,171,069
`
`Dec 1992
`
`Wheel Speed for Drive Axles
`
`Diametrical Runout Reducer for Driving a Rotary Sensor
`
`Safety Edge Switch for Detection of Obstructions Encountered by Moving
`Object
`
`5,223,760
`
`5,252,872
`
`5,296,658
`
`June 1993
`Oct 1993
`Mar 1994
`
`Method & Apparatus for Flexible Manufacturing a Discrete Curved
`Product from Feed Stock
`
`6,622,540
`
`Sept 2003
`
`Method & Apparatus for Flexible Manufacturing a Discrete Curved
`Product from Feed Stock
`
`6,813,923
`
` Nov 2004
`
`Direct Drive Wiper System Motor
`
`6,944,906
`
`7,171,718
`
`7,389,561
`
`7,392,565
`
`7,676,880
`
`Sept 2005
`
`Feb 2007
`
`June 2008
`
`July 2008
`
`Mar 2010
`
`
`
`Two patents pending on Disc Brake Rotor Design & Styling
`
`
`
`PROFESSIONAL ORGANIZATIONS / PUBLICATIONS
`
`Member of the SAE Functional Safety Committee; Chassis Controls Committee; & Functional Hybrid
`
`J2954 Task Force. NHTSA, a Vehicle Safety Forum composed of knowledgeable and critically thinking
`
`individuals who are willing to identify, critique, and debate vehicular safety issues and concerns. Member
`
`of SAE (The Engineering Society for the Advancing Mobility Land, Sea, Air and Space), SAE Anti-Lock
`
`Brake Sub-Committee Member (1987-1990), SAE Exposition Presenter on Brake Drum Structural
`
`Integrity for Heavy Trucks (1981); member of Laser Institute of America; Truck Maintenance Council
`
`Presenter on Anti-Locks Impact on Life Cycle Costs (1989); published 2 Papers / made 2 Presentations
`
`on a Flexible with Taper Thickness, Tapered Width & Curved Beam Manufacture at ICALEO
`
`
`
`Costco Exhibit 1100, p. 18
`
`

`
`
`
`5
`
`(International Congress on Applications of Lasers & Electro-Optics) 2000/2001 Conferences; & quoted in
`
`an article in Photonics magazine May 2002; Article in Industrial Laser Solutions for Manufacturing Oct
`
`2002; Article in Automotive Engineering February 2003; & a paper / presentation was at the GPC 2003,
`
`ALAC 2004 & ICALEO 2004; quoted in an article in Engineering Casting Solutions March 2005; Finalist
`
`for 2006 PACE Award for Product Innovation - Direct Drive Wiper Motor.
`
`References Upon Request
`
`
`
`
`
`
`
`Costco Exhibit 1100, p. 19