UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`COSTCO WHOLESALE CORPORATION,
`Petitioner,
`
`v.
`
`ROBERT BOSCH LLC,
`Patent Owner.
`____________
`
`Case IPR2016-00038
`Patent 6,292,974
`
`SECOND DECLARATION OF DR. GREGORY W. DAVIS
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`Costco Exhibit 1101, p. 1
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`

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`I.
`
`INTRODUCTION
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`I, Dr. Gregory W. Davis, hereby declare the following:
`
`1.
`
`I previously prepared a declaration in support of the unpatentability of
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`U.S. Patent No. 6,292,974 (the “’974 Patent”), which I understand was submitted
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`as Exhibit 1008 to Costco Wholesale Corporation’s Petition for Inter Partes
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`Review of U.S. Patent No. 6,292,974 (Paper No. 1) (the “Petition”).
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`2.
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`I understand that inter partes review was instituted on claims 1, 2, and
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`8 of the ’974 Patent on the following grounds:
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`• Obviousness under 35 U.S.C. § 103(a) over U.S. Patent No. 3,192,551 to
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`Appel (Ex. 1005; “Appel”) and GB 2,106,775 to Prohaska (Ex. 1004;
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`“Prohaska”)
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`• Obviousness under 35 U.S.C. § 103(a) over DE 1,028,896 to Hoyler
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`(Ex. 1006; “Hoyler”) and Prohaska
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`See Institution Decision (Paper No. 16) (the “Decision”).
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`3.
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`I have reviewed the Board’s Institution Decision (Paper No. 16) (the
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`“Decision”), Patent Owner’s Response to the Petition (Paper No. 28) (the
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`“Response”), as well as the Exhibits to that Response, including the Declaration of
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`Dr. Dubowsky (Ex. 2003).
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`4.
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`In performing my analysis I have considered the claims of the ’974
`
`Patent, any differences between the claimed subject matter and the prior art patents
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`Costco Exhibit 1101, p. 2
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`and printed publications identified in my first declaration (Ex. 1008 ¶¶ 2–3), and
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`the level of ordinary skill in the art of the ’974 Patent as of not later than August
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`21, 1997, which I understand is the filing date of the German application to which
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`the ’974 Patent claims priority.
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`5.
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`Furthermore, in forming my opinions, I considered and relied upon
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`the contents of the patents and printed publications discussed below. In interpreting
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`and explaining the contents of these patents and printed publications, I relied on
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`my educational background, industry work experience, and teaching experience as
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`set forth in an appendix to my earlier declaration. See Ex. 1008 ¶¶ 4–12, p. 27
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`(App’x A). An updated version of my curriculum vitae is attached hereto as
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`Appendix A. Even under Patent Owner and Patent Owner’s expert’s definition, I
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`believe I qualify as a person of ordinary skill in the art.
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`II. ANALYSIS AND OPINIONS
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`6.
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`I have the following comments in response to Dr. Dubowsky’s
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`declaration (Ex. 2003) and Patent Owner’s Response.
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`A. A Person of Ordinary Skill in the Art Would Have Understood
`that Wind-Lift is Created by the Inverted Triangular Profile of a
`Wiper Strip Common to Flat-Spring and Conventional Wipers
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`7.
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`In my earlier declaration, I discussed the teachings of Appel,
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`Prohaska, and Hoyler, and expressed my opinion that claims 1, 2, and 8 of the ’974
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`Patent would have been obvious to a person of ordinary skill in the art over the
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`Costco Exhibit 1101, p. 3
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`combinations of either (a) Appel and Prohaska or (b) Hoyler and Prohaska. See
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`Ex. 1008 ¶¶ 17, 37–63.
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`8.
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`As I discussed in my first declaration, wind-lift poses the same
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`problem for flat-spring wipers as it does for conventional ones. See id. ¶ 27. The
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`’974 Patent describes the problem of “liftoff tendency” as resulting from
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`overpressure on the “front” side of the wiper (i.e., the side “exposed to the wind”)
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`and negative pressure on the back side of the wiper. ’974 Patent, 1:7–10, 25–34,
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`34–40, 64–67. U.S. Patent No. 3,418,679 to Barth et al. (Exs. 1007, 2009;
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`“Barth”), granted in 1966, teaches that the “liftoff tendency” referred to in the ’974
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`Patent is caused by the point-down triangular shape of a wiper’s rubber wiper strip:
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`FIGS. 3 and 4 respectively illustrates the theory of air flow and
`lift-off forces as it pertains to the prior-art;
`* * *
`Discussing now these figures in detail, it will be seen that FIG.
`3 shows the air flow and the static pressure conditions with respect to
`a wiper having the customary so-called “pine tree” profile. It is clearly
`evident that in the direction of air flow-impingement a zone of static
`overpressure is generated on that lateral side of the blade which faces
`the air flow, whereas a zone of static underpressure is present on the
`lateral side facing away from the air flow as well as on the back of the
`blade which is located remote from the windshield. The arrows
`indicating air flow clearly show how the forces generated in this
`construction tend to lift the blade away from the windshield.
`
`Costco Exhibit 1101, p. 4
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`This is shown in still more detail in FIG. 4 where for purposes
`of simplicity the profile, which has been identified in FIG. 3 as a
`“pine tree” profile has been shown as a triangle standing on edge with
`its base remote from the windshield. It is evident from FIG. 4 how the
`lift-off forces act against the lateral faces of the blade. The zone of
`static overpressure located on the lateral side onto which the air flow
`impinges results in an upwardly directed pressure P1, while the zone
`of underpressure on the other lateral side of the blade results in a
`downwardly directed pressure P2 of approximately
`the same
`magnitude. A third force, the lift-off force P3, acts on the back of the
`blade. For the purposes of the present consideration only the vertical
`components of the forces P1 and P2 are of importance and a
`consideration of these vertical components readily establishes that
`they negate one another. Thus, the force acting to lift the wiper away
`from the Windshield is the force P3 acting on the back of the wiper.
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`
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`
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`Barth, 2:52–53, 4:8–39 (emphasis added). Barth not only describes
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`the
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`underpressure and overpressure affecting wipers in a manner that is essentially
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`identical to the ’974 Patent, it specifically describes the “lift-off force” as resulting
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`from the wiper strip’s “pine tree” or “inverted triangle” profile.
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`Costco Exhibit 1101, p. 5
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`9.
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`In light of the Barth teachings described above, as of more than one
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`year prior to the filing date of the ’974 Patent, it was known in the art of that patent
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`that a wiper whose wiper strip has an inverted triangular cross-section generates
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`pressures at high vehicle speeds that cause it to lift off from a windshield. See
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`Barth, 1:33–54 (“Such pressure differences become effective on the windshield
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`wiper in the form of a force whose action on the type of windshield wiper known
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`from the prior art, namely the type whose cross section decreases in direction
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`towards the windshield, results in a tendency to lift the wiper from the windshield.”
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`(emphasis added)).
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`10. As of more than one year prior to August 21, 1997, it would have
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`been clear to a person having ordinary skill in the art that Barth’s analysis of wind-
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`lift forces applies generally to wiper strips having an inverted-triangle profile, and
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`that those forces are generated irrespective of whether such wiper strips are carried
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`by a flat-spring or a conventional-style support structure.
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`11. The ’974 Patent’s inventors were not, therefore, the first to recognize
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`the problem of wind-lift in wipers with this wiper strip profile. The inverted-
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`triangle wiper strip profile is illustrated in all the prior art flat-spring and
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`conventional wiper patents I reviewed in connection with this proceeding, and a
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`person of ordinary skill would have recognized that wind-lift would be generated
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`in each of these wipers. See Appel, figs. 7–8, 10–15 (flat-spring); Hoyler, fig.1,
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`Costco Exhibit 1101, p. 6
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`cross-sections A-A, B-B, C-C (flat-spring); Prohaska, figs. 1–5 (conventional);
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`Barth, figs. 2–13 (conventional); see also U.S. Patent No. 3,317,945 to Ludwig
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`(Ex. 1009), figs. 3, 4, 7, 10.
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`12. Dr. Dubowsky expresses his view that a person of ordinary skill
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`“would have thought the lift off problem is a result of having too high a profile,”
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`and states that “Prohaska ’775 states that the lift results from the yoke.” Ex. 2003
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`¶60 (citing Prohaska, 1:8–11). But the section of Prohaska cited by Dr. Dubowsky
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`(“As is known the air stream striking the wiper blade laterally produces a lifting
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`force at the supporting structure . . .” (emphasis added)) is consistent with the
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`analysis in Barth, and a person of ordinary skill would understand that liftoff is
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`applied at the supporting structure, not produced by that structure. Furthermore,
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`nothing in Prohaska suggests that the yoke is the source of the liftoff tendency—in
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`fact, Prohaska describes the prior art as including yokes modified to solve the
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`liftoff problem. Prohaska, 1:16–29.
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`13. A person of ordinary skill in the art seeking to solve the well-known
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`problem of wind-lift would have turned to the well-known method of solving that
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`problem, namely adding a spoiler.
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`B. A Person of Ordinary Skill in the Art Could Have Combined the
`Teachings of Prohaska with those of Appel or Hoyler and Would
`Have Expected Them to Perform According to Their Established
`Functions
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`14. Hoyler taught that a flat-spring wiper should be designed so that that a
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`Costco Exhibit 1101, p. 7
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`“rubber or elastic plastic” component can be used above the metal flat springs.
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`Hoyler, cols. 1, 2.
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`15. Appel teaches that “it is the combination of [rubber and metal
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`components] which determines the final pressure characteristic.” Appel, 3:22–30.
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`16. Prohaska teaches that a spoiler should be “flexible enough in order to
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`enable an adaptation of the rubber wiper element to different pane curvatures, and
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`on the other hand it has enough stiffness not to be deformed by the attacking air
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`stream.” Prohaska, 3:110–14.
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`17. U.S. Patent No. 3,317,945
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`to Ludwig (“Ludwig”; Ex. 1009)
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`(reproduced below) discloses a flat-spring wiper with a triangular rubber “spine”
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`provided above the spring and “homogeneous” with the wiper strip.
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`Ludwig, fig. 7, 3:24–67. During the prosecution of the ’974 Patent, Bosch
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`overcame a rejection over Ludwig by adding the limitation, “a component which is
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`separate from said wiper strip so as to form a leading-edge face extending in a
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`Costco Exhibit 1101, p. 8
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`longitudinal direction of the support element and forming, as seen crosswise to its
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`longitudinal extension, an acute angle with a plane which extends parallel to a
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`plane formed by said convex surface. . . .” ’974 Patent, 4:26–32 (emphasis added);
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`Ex. 1002, p. 97, 117, 124–129. In my view, this difference from Ludwig is trivial.
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`18. Thus, there is nothing to support Dr. Dubowsky’s statements (Ex.
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`2003 at ¶¶ 25, 58, 65) that the prior art teaches that flat-spring wipers were so
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`sensitive that adding structures would have been difficult or beyond the capabilities
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`of a person of ordinary skill, and the ’974 Patent teaches that it can be done
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`without explaining how to account for this alleged sensitivity. I expect this is
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`because such an explanation was unnecessary, as persons of ordinary skill would
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`have understood that the metal flat springs of a flat-spring wiper would behave like
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`any similarly sized and shaped metal structures, which were commonly analyzed,
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`understood, and used in design. In my view, a person of ordinary skill in the art
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`would have understood and been able to calculate the relative stiffness, and
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`bending behavior under load, of the various components of wipers based on their
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`cross sections and material properties using elementary beam equations that were
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`widely known in the engineering disciplines.
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`19.
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`In particular, a person of ordinary skill would have known how to
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`calculate the relative stiffness and bending properties of different spoilers and
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`springs and, given the teachings of Prohaska and Hoyler or Appel, would have
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`Costco Exhibit 1101, p. 9
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`been able to select their materials and cross-sections in designing a wiper.
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`20.
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`I agree with the Board that a person of ordinary skill “would know
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`how to vary the spring element when incorporating the added stiffness of the
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`spoiler so that the desired force distribution is achieved.” Decision, 14. Nothing in
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`Dr. Dubowsky’s declaration convinces me to disagree with the Board’s view.
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`III. CONCLUSION
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`21.
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`I reserve the right to elaborate and/or amend the opinions expressed
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`herein in response to positions taken by Robert Bosch LLC and by experts retained
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`on its behalf. To amplify what is stated above, where necessary, and especially in
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`view of information not presently known to me or new information presented by
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`Robert Bosch LLC’s experts prior to the Board’s decision, I reserve the right to
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`supplement and/or amend this declaration should additional information be brought
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`to my attention during the course of this proceeding.
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`22.
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`In signing this declaration, I understand that the declaration will be
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`filed as evidence in a contested case before the Patent Trial and Appeal Board of
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`the United States Patent and Trademark Office. I acknowledge that I may be
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`subject to cross-examination in the case and that cross-examination will take place
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`within the United States. If cross-examination is required of me, I will appear for
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`cross-examination within the United States during the time allotted for cross-
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`examination.
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`Costco Exhibit 1101, p. 10
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`23.
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`I declare further that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true.
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`I, DR. GREGORY W. DAVIS, hereby declare under the penalty of perjury that the
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`foregoing is true and correct.
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`
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`Dated: 10/24/2016
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`
`
`
`Dr. Gregory W. Davis
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`
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`Costco Exhibit 1101, p. 11
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`

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`
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`APPENDIX A
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`APPENDIX A
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`Costco Exhibit 1101, p. 12
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`

`
`Gregory W. Davis, Ph.D., P.E.
`Department of Mechanical Engineering
`Kettering University
`formerly known as
`GMI Engineering & Management Institute
`1700 University Ave.
`Flint, MI 48504
`(810) 309-9886/dr.gregory.w.davis@gmail.com
`
`
`Education & Credentials
`♦ Ph. D. in Mechanical Engineering, The University of Michigan, Ann Arbor, 1991
`Thesis: "Comprehensive Diagnostic Software for Engine Cycle Analysis"
`♦ Master of Science in Mechanical Engineering, Oakland University, 1986
`♦ Bachelor of Science in Mechanical Engineering, The University of Michigan, Ann Arbor,
`1982
`
`♦ Licensed Professional Engineer in the State of Michigan, License # 35473
`
`
`
`
`Professional Experience
`Fall 1997
`Professor of Mechanical Engineering & Director-Advanced Engine Research
`to Present
`Laboratory (AERL), Kettering University. Responsibilities include leading and
`coordinating automotive engineering curriculum including faculty and graduate
`research. Teaching graduate and undergraduate mechanical engineering
`courses along with directing all research and development activities in the
`AERL. The AERL specializes in the design, development and testing of
`automotive systems including both laboratory and on-road data acquisition &
`control.
` Additional
`responsibilities
`include developing and
`teaching
`Mechanical & Automotive Engineering curriculum and laboratories. Serve as
`faculty advisor to the SAE Student Branch and Clean Snowmobile Challenge
`where we have developed alternative vehicles, including designing extensive
`modifications of
`the Powertrain and Body/Chassis systems,
`including
`calibrations and controls. Supervised over 80 graduate and undergraduate
`theses in engineering.
`
`Developer & Instructor, Continuing Professional Development Programs.
`Develop & Teach continuing education short courses for industrial clients.
`Courses include, “Introduction to Heat Transfer with Applications Related to
`Vehicle Passenger Compartment Cooling,” and “Application of Fluid
`Mechanics to Vehicle Cooling Systems.”
`
`Instructor, SAE Continuing Professional Development Programs. Develop,
`Teach, and co-teach short courses in continuing professional development
`directed to automotive powertrain systems and controls, braking, handling,
`chassis, and exterior body systems for SAE at its headquarters and at company
`locations. Clients include engineers and managers from all major original
`equipment managers and suppliers, governmental regulatory agencies, and other
`professionals involved in the automotive industry world-wide.
`
`
`
`Spring 2003
`to Present
`
`Fall 2009
`to Present
`
`Costco Exhibit 1101, p. 13
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`

`
`Summer 1991
`To Present
`
`Winter 1995
`to Fall 1997
`
`
`Fall 1992
`to WI 1995
`
`
`Summer 1991
`to WI 1995
`
`
`Fall 1986
`to Summer
`1991
`
`
`Winter 1988
`to Fall 1988
`
`
`Spring 1987
`to 1999
`
`Engineering Consultant. As a licensed Professional Engineer in the State of
`Michigan (35473), I am actively engaged in a variety of engineering
`consultations with both governmental and industrial clients.
`Director, Master of Automotive Engineering Program and Associate Professor,
`Mechanical Engineering Department, Lawrence Technological University.
`Coordinated and taught graduate and undergraduate mechanical engineering
`courses. Master of Automotive Engineering program accomplishments include
`a complete restructuring of the program, moving from a “lockstep” model to a
`more traditional prerequisite model to better meet the needs of students.
`Advisor for 145 graduate and undergraduate project students. Faculty advisor
`to the FutureCar Program where we developed alternative vehicles capable of
`achieving dramatically higher fuel economy and lower emissions. This was
`accomplished
`through extensive Powertrain and Body/Chassis system
`modifications to an existing vehicle. Developed automated mechanical
`transmission (AMT) system for the hybrid electric powertrain. Also served as
`Laboratory manager for the Vehicle Dynamics Laboratory.
`
`Lecturer, Whiting School Evening Programs in Engineering & Applied Science,
`Johns Hopkins University. Taught mechanical engineering courses in the
`undergraduate program.
`
`Assistant Professor, Mechanical Engineering Department, United States Naval
`Academy. Coordinated and taught courses in the fluid and thermal sciences
`areas of mechanical engineering. Past Chairman (1994) of the dept. curriculum
`development committee. Laboratory manager for the Internal Combustion
`Engines and Power Systems laboratories. Faculty advisor for the USNA
`Society of Automotive Engineers (SAE). Project director for the following
`student projects: 1991-5 Hybrid Electric Vehicle (HEV) Challenge Vehicles,
`1996 Formula. The Hybrid Vehicles were developed by extensively modifying
`the Powertrain and Body/Chassis systems.
`
`Ph.D. Candidate & Graduate Asst., College of Engrg., U. of Michigan, Ann
`Arbor. Successfully defended Ph.D. dissertation (July 1991). Thesis:
`"Comprehensive Diagnostic Software for Engine Cycle Analysis". Minority
`Engineering Program Office Engineering tutor. Taught courses in Mechanical
`Engineering and mentored graduate student teaching assistants.
`
`Engineering Co-Op., Advanced Engineering, AC-Rochester Div., General
`Motors Corp. Developed IC engine models used to conduct parametric studies
`of the influence of EGR on emissions, valve timing effects, etc.
`
`Consulting Engineer & Partner, Intellec Systems, Inc. Developed computer
`software for industrial clients.
`
`Costco Exhibit 1101, p. 14
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`

`
`
`Summers 1986
`to 1987
`
`
`Winter 1985
`to Spring
`1986
`
`Summer 1982
`to Winter
`1985
`
`
`Winter 1979
`to WI 1980
`
`
`Summer Intern, Advanced & Plant Engineering, AC-Rochester Div., General
`Motors Corporation. Developed computer-aided
`software system for a
`manufacturing plant. Developed software combustion model to predict flame
`temperature, pressure, and resultant NOx formation in a SI engine.
`
`Graduate Research Asst. with Drs. Bhatt and Wedekind, School of Engineering,
`Oakland University. Developed & utilized computer -aided data acquisition
`control and analysis software for heating system research.
`
`Associate Engineer, Production Dept., St. Clair Power Plant Detroit Edison Co.
`Responsible for operation and maintenance of two 150 MW turbo-generating
`units. Promoted to Plant Thermal Performance Engineer; duties included
`performance testing, analyzing results, and conducting monthly plant & area
`staff meetings.
`
`Engineering Technician, Testing & Evaluation Section, Motor Vehicle
`Emissions. Lab., EPA. Supervised testing, collected & analyzed data, and
`drove vehicle tests.
`
`
`Awards and Honors
`Patents
`♦ ENERGY CONSERVATION SYSTEMS AND METHODS, Jeffrey N. Yu, James W.
`Hill, Gregory W. Davis, U.S. Patent 8,639,430 B2, Publication date January 28, 2014.
`♦ ENERGY CONSERVATION SYSTEMS AND METHODS, Jeffrey N. Yu, Gregory W.
`Davis, Gwynn R. Williams, U.S. Patent 9,063,829 B2, Publication date June 23, 2015.
`
`
`Teaching Awards
`♦ 2004 Outstanding Teacher Award-Kettering University,
`♦ 1995 U. S. Naval Academy Mechanical Engineering Department Teaching Excellence
`Award,
`♦ 1994 SAE International Ralph R. Teetor Educational Award in Recognition of
`Significant Contributions to Teaching, Research and Student Development,
`♦ Outstanding Teaching Assistant Fellowship (U of Michigan, 1990),
`♦ Minority Engineering Program Tutor (U of Michigan, 1990),
`♦ Letters of Commendation from College of Engineering Dean for Excellence in Teaching
`(U of Michigan, 1990)
`
`
`Professional Society Honors
`♦ 2009 Small Engine Technology Conference, SAE and SAE of Japan, Certificate of
`Appreciation for significant contributions at the SETC conference,
`♦ 2006 SAE International Outstanding Section Member Award-Mid-Michigan Section in
`Recognition of Extraordinary Achievement by a Mid-Michigan Section Member,
`♦ 2006 American Society of Mechanical Engineers (ASME) recognition of long term
`membership
`
`Costco Exhibit 1101, p. 15
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`

`
`♦ 2002 SAE International Award for Excellence in Oral Presentation- Powertrain & Fluid
`Systems Conference,
`♦ 1994 SAE Baltimore Section Recognition of Service Award for Outstanding Leadership
`as Section Activities Chair
`
`
`Advisory Boards & Directorships
`♦ Elected to the Society of Automotive Engineers (SAE) International Board of Directors
`(2007-2010),
`♦ Member of the Advisory Board, National Institute for Advanced Transportation
`Technology, Center for Clean Vehicle Technology, University of Idaho-Moscow, (2007-
`Present),
`♦ Chair, SAE International Engineering Education Board (2002-2005),
`♦ Member, SAE International Education Board (2010-2014),
`♦ Director, SAE International Publications Board (2005-2008)
`
`
`Professional Society Membership & Activities
`Tau Beta Pi, Pi Tau Sigma, American Society of Engineering Educators (Author and Reviewer),
`American Society of Mechanical Engineers (Author and Reviewer), Triangle Fraternity, Trustee
`and Vice-President-Triangle Fraternity Education Foundation (2001-2003), Institution of
`Mechanical Engineers (Reviewer- Journal of Automobile Engineering)
`Society of Automotive Engineers:
`♦ SAE International Board of Directors (Director, 2007-2010);
`♦ Education Board (Chair, 2002-2005; Member, 1994-present);
`♦ Publications Board of Directors (Director, 2005-2008);
`♦ Collegiate Design Series (formerly University Programs Committee) (Chair, 1998-2004,
`2011-2014; member, 1994-2009),
`♦ SAE Faculty Advisor (1992-95, 1998-present);
`♦ Ralph Teetor Committee (Chair-2012, 2004-present);
`♦ Member of Excellence in Engineering Education Award Committee;
`♦ Clean Snowmobile Challenge Faculty Advisor (2000-present),
`♦ A World in Motion Program Office (Member, 2003-2009);
`♦ Student Relations Chairman (1995-96),
`♦ Project Director for the 1991-5 Hybrid Electric Vehicle Challenges,
`♦ and the 1996 Formula Competition,
`♦ FutureCar Faculty Advisor (1996-97),
`♦ Ethanol Challenge Faculty Advisor (1998-2000),
`♦ Technical Paper Reviewer and Session Moderator
`
`
`Professional Consulting in Engineering Legal Proceedings:
`The following list summarizes my testimony with regard to professional consulting for engineering legal
`proceedings over the last four years.
`
`
`♦ Consulting Expert, Westerman Hattori Daniels & Adrian, LLP, 2015 to 2016, provided Hearing
`& Deposition testimony
`o Hired expert witness on behalf of Complainants Trico Corporation, Trico Products Corp.
`
`Costco Exhibit 1101, p. 16
`
`

`
`§
`
`In the Matter of CERTAIN WINDSCREEN WIPERS AND COMPONENTS
`THEREOF, Inv. No. 337-TA-964, before the Honorable David P. Shaw,
`Administrative Law Judge of the United States International Trade Commission,
`Washington, D.C.
`♦ Consulting Expert, Hughes Hubbard & Reed LLP, 2015 to present, provided Declarations &
`Deposition Testimony
`o Hired on behalf of Defendants, CostCo Wholesale Corp.
`§ Robert Bosch LLC, Plaintiff, v. Alberee Products, Inc., Api Korea Co., Ltd.,
`Saver Automotive Products, Inc., And Costco Wholesale Corporation,
`Defendants. C.A. No. 12-574 (LPS), The United States District Court for The
`District of Delaware
`§ Costco Wholesale Corporation, Petitioner, v. Robert Bosch LLC, Patent
`Holder, IPR Case Nos. Case IPR2016-00042; Case IPR2016-00035;
`IPR2016-00039; IPR2016-00038; IPR2016-00034; IPR2016-00036;
`IPR2016-00040; and IPR2016-00041
`♦ Consulting Expert, Howard & Howard, LLP, 2015, provided Hearing & Deposition testimony
`o Hired expert witness on behalf of Respondents Trico Corporation, Trico Products and
`Trico Components SA de CV
`§ Re: Certain Windshield Wipers and Components Thereof, Inv. No. 337-TA-
`928, 937 (consolidated), before the Honorable Thomas B. Pender,
`Administrative Law Judge of the United States International Trade Commission,
`Washington, D.C.
`
`♦ Consulting Expert, Fish & Richardson P.C., 2014 to Present, provided Declaration & Deposition
`testimony
`o Hired on behalf of the Petitioners Arctic Cat, Inc., USA, in support of the Petitions for
`Inter Partes Review of U.S. Patent Nos. 8,827,028 B2; 8,746,719 B2; and 8,596,405 B2.
`§ Arctic Cat Inc., Petitioner, V. Polaris Industries, Inc., Patent Holder, IPR Case
`Nos. 2014-001427 and 2014-001428 (8,596,405); IPR2015-01788 and IPR2015-
`01789 (8,746,719); IPR2015-01781 and IPR2015-01783 (8,827,028)
`♦ Consulting Expert, Brooks & Kushman, P. C., 2013 to 2016, provided Deposition testimony
`o Hired on behalf of the Petitioners Ford Motor Company, USA, in support of the Petitions
`for Inter Partes Review of U.S. Patent No. 7,318,414
`§ FORD MOTOR COMPANY, Petitioner, V. TMC FUEL INJECTION SYSTEM,
`LLC, Patent Holder, IPR Case Nos. 2014-00272, 2014-00273
`
`
`♦ Consulting Expert, Brooks & Kushman, P. C., 2013 to 2016, provided Deposition testimony
`o Hired on behalf of the Petitioners Ford Motor Company, USA, in support of the Petitions
`for Inter Partes Review of U.S. Patent Nos. 7,104,347 & 7,237,634:
`§
`IPR Case Nos. 2014-00571, 2014-00579, 2014-00884, 2014-00904, 2014-01416,
`2014-00800, 2015-00794, 2015-00795,2015-00758, 2015-00787, 2015-00722,
`2015-00784, 2015-0791, 2015-00790
`♦ Consulting Expert, Paul, Weiss, Rifkind, Wharton & Garrison, LLP, 2014, provided Deposition
`and Hearing testimony
`
`
`
`Costco Exhibit 1101, p. 17
`
`

`
`o Hired expert witness on behalf of Plaintiffs Trico Corporation, Trico Products and Trico
`Components SA de CV
`§ Re: Certain Windshield Wiper Devices and Components Thereof, Inv. No.
`337-TA-902, before the Honorable Charles E. Bullock, Chief Administrative
`Law Judge of the United States International Trade Commission, Washington,
`D.C.
`♦ Consulting Expert, Paul, Weiss, Rifkind, Wharton & Garrison, LLP, 2013 to 2014, provided
`Deposition & Hearing testimony
`o Hired expert witness on behalf of Respondents Trico Corporation, Trico Products and
`Trico Components SA de CV
`§ Re: Certain Windshield Wiper Devices and Components Thereof, Inv. No.
`337-TA-881, before the Honorable Charles E. Bullock, Chief Administrative
`Law Judge of the United States International Trade Commission, Washington,
`D.C.
`♦ Consulting Expert, Brooks & Kushman, P. C., 2011 to 2013, provided Deposition testimony
`o Hired on behalf of the Defendants Corea Autoparts Producing Corporation, CAP
`America Corporation, Inc., and PIAA Corporation, USA
`§ CERTAIN WIPER BLADES, Investigation No. 337-TA-816, before the Honorable
`Charles E. Bullock, Chief Administrative Law Judge of the United States
`International Trade Commission, Washington, D.C.
`Publications (Last ten years):
`
`Technical and Text Books
`♦ Davis, G. W., Hoff, C. J., Borton, Z., Ratcliff, M. A., “Legacy Vehicle Fuel System
`Testing with Intermediate Ethanol Blends,” National Renewable Energy Laboratory,
`Technical Report NREL/TP-5400-53606, March 2012
`♦ Davis, G. W., “Using E85 in Vehicles,” Chapter 9, Alcoholic Fuels, CRC Press Taylor &
`Francis Group, ISBN-10 0-8493-3944-8, ISBN-13 978-0-8493-3944-8, Minteer, S.
`Editor, 2006 (Invited Chapter).
`♦ Hoff, C. J., and Davis, G. W., “Introduction to Automotive Powertrains,” Kettering
`University, 2000.
`♦ Davis, G. W., Editor for World Book Encyclopedia, Various Automotive Articles, 2012-
`present.
`
`
`Refereed and Reviewed Publications
`♦ Davis, G. W., “Motivating Students with Bio-fuel Student Engineering Competition
`Projects,” Paper 2016.1196, 19th International Conference on Interactive Collaborative
`Learning and Engineering Pedagogy, also Published in ICL2016 "Advances in Intelligent
`Systems and Computing," Editor: M. Auer, et al, Springer, ISSN: 2194-5357, 2016.
`♦ Davis, G. W., “Addressing Concerns Related to the Use of Ethanol-Blended Fuels in
`Marine Vehicles,” Paper 2016.0321, 2nd Sustainable Development of Energy Water and
`Environment Systems (SDEWES), South East Europe (SEE) Conference, 2016.
`
`Costco Exhibit 1101, p. 18
`
`

`
`♦ Davis, G. W., “What Is The Role For Collegiate Design Competitions In A Multi-
`Discipline, Diverse World?” Paper No. 1216, EDUCON 2015, Global Engineering
`Education Conference, Institute of Electrical and Electronics Engineers (IEEE), 2015.
`♦ Birt, M., and Davis, G. W., “Developing Best Available Technology in a Flex-Fuel
`Snowmobile by Using a Lean-Burn Miller Cycle,” Paper No. JSAE 20139176 / SAE
`2013-32-9176, Society of Automotive Engineers, 2013.
`♦ Hoff, C. J., Aurandt, J., O’Toole, M. R., and Davis, G. W., “Motivating Student Learning
`Using Biofuel-based Activities,” Paper No. AC 2013-7533, American Society of
`Engineering Educators, 2013.
`♦ Hoff, C. J., Davis, G. W., and Hoff, K., “A Peer-Tutor’s Perspective On Peer-Tutoring In
`Thermodynamics,” Paper No. AC 2012-3581, American Society of Engineering
`Educators, 2012.
`♦ Hoff, K., Davis, G. W., and Hoff, C. J., “A Peer-Tutor’s Perspective On Peer-Tutoring In
`Thermodynamics,” Paper No. 174, World Engineering Education Forum (WEEF), 2012.
`♦ Davis, G. W., Hoff, C, J., Riffe, W.J., “Incorporating Entrepreneurship into Mechanical
`Engineering Automotive Courses: Two Case Studies,” Technical Paper No. 279,
`European Society for Engineering Education (SEFI), 1st World Engineering Education Flash
`Week, 2011.
`♦ Davis, G. W., Hoff, C, J., Riffe, W.J., “Incorporating Entrepreneurship into Mechanical
`Engineering Automotive Courses: Two Case Studies,” Paper No. AC2011-2443,
`American Society of Engineering Educators, 2011.
`♦ Davis, G. W., Lazorcik, G., “Development of a Flexible Fueled Snowmobile Operating
`on Ethanol Blended Gasoline for the 2010 SAE Clean Snowmobile Challenge,”
`Technical Paper No. 2010SETC-0157/2010-32-0083, Society of Automotive Engineers,
`2010.
`♦ Hoff, C. J., and Davis, G. W., “The Effect of Using Ethanol-blended Gasoline on the
`Performance and Durability of Fuel Delivery Systems in Classic Automobiles,”
`Technical Paper No. 2010-01-2135, Society of Automotive Engineers, 2010.
`♦ Baker, A., and Davis, G. W., “Development of the Kettering University Snowmobile for
`the 2009 SAE Clean Snowmobile Challenge,” Technical Paper No. 2009-32-0177 /
`20097177, Society of Automotive Engineers, 2009.
`♦ Davis, G. W., Wilson, F., Schickel, B., Baker, A., “Development of Clean Snowmobile
`Technology for Operation on High-Blend Ethanol for the 2008 Clean Snowmobile
`Challenge,” Technical Paper No. 08SETC-0045/2008-32-0053, Society of Automotive
`Engineers, 2008.
`♦ Davis, G. W., “Demonstrating the Use of High-Blend Ethanol (E85) in Snowmobiles,”
`ES2008-54189, Proceedings of Energy Sustainability 2008, August 10-14, 2008,
`Jacksonville, Florida USA.
`♦ Davis, G. W., and Hoff, C., “Promoting Professional Development in Undergraduate
`Engineering Using Laboratory Team Projects: A Case Study,” Proceedings of the 2008
`American Society of Engineering Educators Co