throbber
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 IPR2016-00041
`Patent 8,099,823
`
`DECLARATION OF DAVID PECK
`
`
`
`
`
`
`
`
`
`
`
`Costco Exhibit 1100, p. 1
`
`

`
`Case IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`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 IPR2016-00041
`
`DECLARATION or 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
`
`reserve those same rights.
`understanding is incorrect,
`28.
`I understand [that
`this declaration will be filed as evidence in a
`
`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.
`
`1, DAVID PECK, hereby declare under the penalty of perjury that the foregoing is
`
`true and correct.
`
`Datedzfiuaféz Z0/6
`
`David Peck
`
`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

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket