IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Attorney Docket No.: 063544.010700
`
`Fortune et al.
`In re Patent of:
`U.S. Patent No.:
`6,012,007
`January 4, 2000
`Issue Date:
`Appl. Serial No.: 08/868,338
`Filing Date:
`June 3, 1997
` OCCUPANT DETECTION METHOD AND APPARATUS
`Title:
`FOR AIR BAG SYSTEMS
`
`
`
`
`
`
`DECLARATION OF DR. KIRSTEN CARR
`
`I, Kirsten Carr, of Ann Arbor, Michigan, declare that:
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`1.
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`I have attached my curriculum vitae as Exhibit 1 to this report. I have
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`summarized my educational and professional background below.
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`2.
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`I received my B.S. degree in Mechanical Engineering from the University of
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`Michigan, Ann Arbor, in 1987 and my M.S. and Ph.D. in Mechanical Engineering
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`from the University of Illinois, Urbana, in 1990 and 1995, respectively.
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`3.
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`I joined Ford Motor Company in 1992, working a variety of assignments,
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`including manufacturing research, powertrain quality, occupant safety research, and
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`advance safety sensors. My work in advance safety sensors (2000-2004) included
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`front impact, side impact, rollover, pre-crash, and occupant classification sensor
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`systems. Among other tasks, I was responsible for evaluating occupant classification
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`sensor technologies at various stages of development and delivering sensor systems
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`capable of meeting the new FMVSS regulations with proven implementation
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`readiness to vehicle programs.
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`KMA-1003
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`4.
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`I joined Packer Engineering in 2006 as an expert in mechanical and
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`manufacturing engineering with expertise in forensic analysis of mechanical
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`components, vehicular accidents, industrial equipment, vehicle safety restraint and
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`seat systems, and electromechanical systems. I was responsible for managing and
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`performing mechanical and manufacturing engineering investigations and analyses
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`for legal, insurance, and industrial firms.
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`5.
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`I created Carr Analysis, LLC in 2011, where I am the President and Principal
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`Consultant and continuing my consulting work.
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`6.
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`I have been awarded ten (10) patents in the area of vehicle safety systems.
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`7. My other achievement (publications, presentations, reports, and lectures) are
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`listed on my curriculum vitae.
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`8.
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`9.
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`I am a professional engineer registered in the State of Michigan.
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`In writing this Declaration, I have considered the following: my own
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`knowledge and experience, including my work experience in the fields of vehicle
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`safety systems; my industry experience with those subjects; and my experience in
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`working with others involved in those fields. In addition, I have analyzed the
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`following publications and materials, in addition to other materials I cite in my
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`declaration:
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`●
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`U.S. Patent No. 6,012,007 and its accompanying prosecution history
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`(“the ’007 Patent”, Ex 1001)
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`●
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`●
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`U.S. Patent No. 5,474,327 (“Schousek”, Ex. 1004)
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`U.S. Patent No. 5,232,243 (“Blackburn”, Ex. 1005)
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`10. Although for the sake of brevity this Declaration refers to selected portions of
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`the cited references, it should be understood that one of ordinary skill in the art
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`would view the references cited herein in their entirety, and in combination with
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`other references cited herein or cited within the references themselves. The
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`references used in this Declaration, therefore, should be viewed as being
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`incorporated herein in their entirety.
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`11.
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`I am not currently and have not at any time in the past been an employee of
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`Kia Motors America, Inc. I have been engaged in the present matter to provide my
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`independent analysis of the issues raised in the petition for inter partes review of the
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`’007 patent. I received no compensation for this declaration beyond my normal
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`hourly compensation based on my time actually spent studying the matter, and I will
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`not receive any added compensation based on the outcome of this inter partes review
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`of the ’007 patent.
`
`I.
`
`Person of Ordinary Skill in the Art
`
`12.
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`I am familiar with the content of the ’007 patent, which, I have been informed
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`by counsel, has an earliest possible filing date of December 1, 1995 (hereinafter “the
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`Critical Date”). Additionally, I have reviewed the other references cited above in
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`this declaration. Counsel has informed me that I should consider these materials
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`through the lens of one of ordinary skill in the art related to the ’007 patent at the
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`time of the invention. I believe one of ordinary skill around December 1, 1995
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`would have had a Bachelor of Science in Mechanical Engineering with experience in
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`computer programming and several years of experience in vehicle safety systems or
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`the like. Alternatively, this individual could have a Bachelor of Science Degree in
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`Electrical Engineering, Computer Engineering, or Computer Science with experience
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`in the mechanical arts in addition to the experience described above. Individuals
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`with additional education or additional industrial experience could still be of
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`ordinary skill in the art if that additional aspect compensates for a deficit in one of
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`the other aspects of the requirements stated above. I base my evaluation of a person
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`of ordinary skill in this art on my own personal experience, including my knowledge
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`of students, colleagues, and related professionals at the time of interest.
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`13. My findings, as explained below, are based on my education, experience, and
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`background over the last 30 years as discussed above.
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`II. Claim Construction
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`14.
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`I understand that, for the purposes of my analysis in this matter, the claims of
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`the ‘007 Patent must be given their broadest reasonable interpretation consistent with
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`the specification. Stated another way, it is contemplated that the claims are
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`understood by their plain and ordinary meanings except where construed in the
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`specification. I also understand that this “plain and ordinary meaning” is with
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`respect to how one of ordinary skill in the art would interpret the claim language. I
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`have followed these principles in my analysis. In a few instances, I have discussed
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`my understanding of the claims in the relevant paragraphs below.
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`III. Schousek
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`15. Schousek teaches a vehicle restraint system having a controller for deploying
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`air bags that selectively allows deployment according to the outputs of seat sensors
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`responding to the weight of an occupant. Schousek describes an “air bag restraint
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`system [that] is equipped with [a] seat occupant sensing apparatus for a passenger
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`seat which detects both infant seats and adults and distinguishes between and
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`forward facing infant seats.” Ex. 1004, Abstract. Schousek states that “the sensing
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`apparatus comprises eight variable resistance pressure sensors in the seat cushion.”
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`Id. A “microprocessor” monitors “the response of each sensor to occupant pressure,”
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`and calculates a “total weight and weight distribution” for an occupant of the seat.
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`Id. Schousek describes that the detected weight from the seat sensors “is used to
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`discriminate between an occupied infant seat, an adult and no occupant,” and that the
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`“weight distribution is used to distinguish between forward and rear facing infant
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`seats.” Id.
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`16. Schousek further describes that if the microprocessor determines that “the total
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`weight parameter is greater than the maximum infant seat weight <72> this indicates
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`that a larger occupant is present and a decision is made to allow deployment <74>.”
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`Id. at 5:32-35. If the microprocessor determines that “the total weight parameter is
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`less than the minimum weight threshold for an occupied infant seat <76> it is
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`determined that the seat is empty and a decision is made to inhibit deployment
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`<78>.” Id. at 5:36-39. This process is shown in FIG. 5A of Schousek, which is
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`reproduced below:
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`Ex. 1004, FIG. 5A
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`17. Schousek also teaches determining measures represented by individual sensor
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`outputs and calculating from the sensor outputs a relative weight parameter.
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`Schousek states that “the sensing apparatus comprises eight variable resistance
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`pressure sensors in the seat cushion.” Id. A “microprocessor” monitors “the
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`response of each sensor to occupant pressure,” and calculates a “total weight”
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`parameter for an occupant of the seat from these sensor outputs. Id. This total
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`weight parameter is calculated by reading the “current voltage” produced by each
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`individual sensor, “subtract[ing]” this voltage “from [a] calibration voltage” set for
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`each sensor that represents the “voltage for an empty seat condition” (a baseline
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`voltage), and summing these “measured voltage differences.” Id. at 4:51-59.
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`Schousek describes that “[t]he difference voltage then is a function of the pressure
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`exerted on the sensor and is empirically related to actual occupant weight” and that
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`“the sum of measured voltage differences. . . . represents occupant weight[.]” Id. at
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`4:56-60. Hence, the total weight parameter is a measure of the force applied to the
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`sensor relative to a calibrated value representing the amount of force detected when
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`the seat is unoccupied. This baseline amount of force may be a product of, for
`
`example, the tension created by the seat cover fabric stretched over the seat cushion
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`and sensor creating a pressure on them or other forces. Therefore, the total weight
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`parameter is calculated from the sensor outputs and is a relative representation of the
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`seat occupant’s weight.
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`18. Schousek further discloses establishing a first threshold of the relative weight
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`parameter. Schousek details how to establish a “minimum weight threshold” based
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`on “the minimum weight of an occupied infant seat (about 10 pounds)[.]” Id. at
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`5:36-37, 2:31-34. The reference further states that the minimum weight threshold is
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`“compared to the measured total weight parameter” (as described above) “to
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`determine whether the vehicle seat is holding an occupied infant seat . . . or has no
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`occupant.” Id. at 2:34-38.
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`19. Schousek also teaches allowing deployment when the relative weight
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`parameter is above the first threshold. As previously discussed, Schousek teaches a
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`relative weight parameter (the total weight parameter) and a first threshold (the
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`minimum infant seat weight threshold). Schousek describes at least two cases in
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`which deployment of the air bag is allowed when the total weight parameter is above
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`the minimum infant weight threshold, both of which are discussed below.
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`20.
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`In the first case, Schousek describes that “[i]f the total weight parameter is
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`greater than the maximum infant seat weight . . . this indicates that a larger occupant
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`is present and a decision is made to allow deployment[.]” Id. at 5:32-35. FIG. 5A
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`from Schousek shows this process:
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`Ex. 1004, detail of FIG 5A
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`The “maximum infant seat weight” represents the “maximum weight of an occupied
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`infant seat (50 pounds)” and is greater than the minimum infant seat weight threshold
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`defined by Schousek as “about 10 pounds.” Id. at 2:31-34. Hence, a total weight
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`parameter greater than the maximum infant seat weight threshold would be above the
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`minimum infant seat weight threshold and would result in a decision to allow
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`deployment.
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`21.
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`In the second case, Schousek teaches “[i]f the total weight parameter is
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`between” the two weight thresholds described above, “the occupant is identified as
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`an occupied infant seat or a small child[.]” Id. at 5:42-44. Schousek describes that
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`“[i]f the center of weight distribution is not forward of the reference line, a forward
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`facing infant seat is detected and a decision is made to allow deployment of the air
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`bag[.]” Id. at 5:47-50. This process is shown in FIG. 5A:
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`Ex. 1004, detail of FIG. 5A
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`
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`22. Schousek thus describes that if the total weight parameter is greater than the
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`minimum infant seat weight but less than the maximum infant seat weight,
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`deployment of the airbag is selectively allowed according to the weight distribution
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`detected by the sensors.
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`23. Schousek also teaches establishing a lock threshold above the first threshold.
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`As described above, Schousek describes a “maximum infant seat threshold” that is
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`greater than a “minimum infant seat threshold.” See Id. at 2:31-32, 5:32-39. This
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`maximum infant seat weight is a lock threshold because of the allow/inhibit
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`deployment decision locking procedure (described in detail below). See Id. at 5:55-
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`58.
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`24. Schousek teaches setting a lock flag when the relative weight parameter is
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`above the lock threshold and deployment has been allowed for a given time.
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`Schousek describes that the allow/inhibit deployment decision “made in each
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`execution loop is stored in an array” and if less than five decisions have been stored,
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`“a decision counter is incremented” until a total of five consecutive decisions have
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`been made and stored. Id. at 5:53-56. Once the decision counter reaches five, “the
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`counter is cleared <96> and the decisions are compared [.]” Id. at 5:55-58. If all five
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`values in the decision array “are the same, the current decision is transmitted to” a
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`supplemental inflatable restraint (SIR) module controlling airbag deployment, and
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`“the current decision is labelled as the previous decision[.]” Id. at 5:59-62. If all five
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`decisions in the array “are not the same, the previous decision is retransmitted to the”
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`SIR module. Id. at 5:61-63. The previous decision, therefore, functions as a lock
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`flag for the allow/inhibit deployment decision since the previous decision persists
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`(i.e., is locked) until five consecutive opposite decisions are stored together in the
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`decision array. Accordingly, Schousek teaches setting the previous decision (a lock
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`flag) if the same allow/inhibit deployment decision from five consecutive cycles has
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`been stored together in the decision array. See Id. at 5:53-61. One of the
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`allow/inhibit deployment decisions stored in the array is the decision to allow
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`deployment if the total weight parameter (the relative weight parameter) is above the
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`maximum infant weight threshold (the lock threshold). See Id. at 5:53-55. Hence, a
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`lock flag is set when the total weight parameter is above the lock threshold
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`(maximum infant weight threshold) and deployment allowed for a given time.
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`25. Schousek also discloses establishing an unlock threshold at a level indicative
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`of an empty seat. In particular, Schousek describes that the “minimum infant seat
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`threshold” is used to determine whether the seat is empty, stating that “if the total
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`weight parameter is less than the minimum weight threshold for an occupied infant
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`seat <76> it is determined that the seat is empty[.]” Id. at 5:36-39.
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`26. Schousek teaches clearing the flag when the relative weight parameter is
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`below the unlock threshold for a time. As previously described above at ¶ 24,
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`Schousek describes that each allow/inhibit deployment decision is stored in an array
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`and the decision is locked once five consecutive matching decisions are present. One
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`of the allow/inhibit deployment decisions stored in the decision array is the decision
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`to inhibit deployment if the total weight parameter (the relative weight parameter) is
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`below the minimum infant weight threshold (the unlock threshold). See Id. at 5:36-
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`39. Accordingly, Schousek teaches updating the previous decision to “inhibit
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`deployment” (clearing the lock flag) if a decision to inhibit deployment (i.e., because
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`the total weight parameter is less than the minimum infant seat weight threshold) has
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`been made during five consecutive cycles and stored together in the decision array.
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`See Id. at 5:53-61. Hence, the lock flag is cleared when the total weight parameter is
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`below the unlock threshold (minimum infant seat weight threshold) for a given time.
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`27. Schousek discloses allowing deployment while the lock flag is set. As
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`discussed above, Schousek describes that the previous decision (the lock flag) will be
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`set to “allow deployment” until five consecutive “inhibit deployment” decisions are
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`stored together in the decision array, and that if all five decisions in the array “are not
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`the same, the previous decision is retransmitted to the” SIR module. Id. at 5:61-63.
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`Accordingly, the previous decision of “allow deployment” will be sent to the SIR
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`module, thereby allowing deployment, while the previous decision (the lock flag) is
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`set to the value of “allow deployment” (i.e. until an “inhibit deployment” decision is
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`received for five consecutive cycles that are stored together).
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`28. Schousek discloses establishing a second threshold of the relative weight
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`parameter. Schousek describes that the “minimum infant seat threshold” is used to
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`determine whether the seat is empty, stating that “if the total weight parameter is less
`
`than the minimum weight threshold for an occupied infant seat <76> it is determined
`
`that the seat is empty[.]” Id. at 5:36-39.
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`29. Schousek discloses inhibiting deployment when the relative weight parameter
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`is below the second threshold. As previously discussed, the total weight parameter
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`of Schousek is a relative weight parameter and the minimum infant seat weight
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`threshold is the second threshold. Schousek describes that “if the total weight
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`parameter is less than the minimum weight threshold for an occupied infant seat
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`<76> it is determined that the seat is empty and a decision is made to inhibit
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`deployment <78>.” Id. at 5:36-39. Hence, deployment is inhibited when the weight
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`parameter is below the second threshold.
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`30. Schousek discloses that the relative weight parameter is the total force
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`detected by all the sensors. Schousek describes a process of “determin[ing] a force
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`for each sensor” and “summ[ing] to obtain a total force or weight parameter.” Id. at
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`5:30-31.
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`31. Schousek discloses that the relative weight parameter is a load rating obtained
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`by calculating a load rating for each sensor as a function of the difference between
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`the sensor output and a base value. Schousek describes that the total weight
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`parameter (the relative weight parameter) is calculated by reading a “current voltage”
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`produced by each sensor and “subtract[ing]” the current voltage “from [a] calibration
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`voltage” set for each sensor representing a base value of the “voltage for an empty
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`seat condition.” Id. at 4:51-56. This voltage difference is a calculated load rating for
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`each sensor.
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`32. Schousek discloses summing the load rating for all the sensors to derive a total
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`load rating. Schousek states that for each sensor, “[t]he difference voltage then is a
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`function of the pressure exerted on the sensor and is empirically related to actual
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`occupant weight,” and that “the sum of measured voltage differences. . . . represents
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`occupant weight[.]” Id. at 4:58-60.
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`33. Schousek discloses that a step of allowing deployment is a preliminary allow
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`decision and final deployment consent is attained by long term filtering of the allow
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`decision. As previously discussed, Schousek describes that a previous allow/inhibit
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`deployment decision is used until five consecutive matching decisions are stored
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`together in a decision array. Therefore, if the previous decision is to inhibit
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`deployment, each decision to allow deployment stored in the decision array is a
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`preliminary allow decision until five consecution decisions to allow deployment are
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`present together in the decision array, after which the decision to allow deployment
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`will take effect. See Id. at 5:51-63. Schousek comments on how this program filters
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`out occasional spurious decisions. See Id. at 6:2-5.
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`IV. Schousek in view of Blackburn
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`34. Blackburn teaches an occupant seat including a resilient pad (bottom cushion)
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`that supports the occupant on its top surface and is itself supported by a mounting on
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`its bottom surface. Blackburn describes the preferred “occupant seat 234 with which
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`the occupant restraint system 220 is used” as “a passenger seat in the vehicle.” Ex.
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`1005, 9:39-43. The occupant seat 234 shown in FIG.9 includes a bottom cushion
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`and a support mounting positioned below the bottom surface of the bottom cushion
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`262. FIG. 9 of Blackburn shows the occupant seat 234:
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`Ex. 1005, detail of FIG. 9 (annotated)
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`
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`35. Blackburn discloses the sensors arranged in an array on the bottom surface of
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`the bottom cushion. Blackburn details “a passenger seat in the vehicle” that includes
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`“an occupant position and weight sensor 260 located in the bottom cushion 262 of
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`the seat 234.” Ex. 1005, 9:39-43. Blackburn describes “the occupant position and
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`weight sensor 260” as including “an N X M array of individual position sensors 300
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`and individual weight sensors 302.” Id. at 10:21- 23 (emphasis added). FIG 9,
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`shown in the above section, shows the sensor located on the bottom surface of the
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`cushion. FIG. 10 shows the array:
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`Ex. 1005, FIG. 10
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`
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`36. Blackburn discloses another support mounting for the bottom surface of the
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`bottom cushion. Blackburn describes the sensor as including a housing with a “top
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`cover plate” and “a bottom support plate 92” that “is rigidly mounted to a
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`substantially inflexible bottom portion of the seat[.]” Ex. 1005, 3:66-4:2.
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`Additionally, “[t]he bottom plate 92 is rigidly secured relative to the vehicle floor.”
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`Id. at 4:56-58, FIG. 3. FIG. 3 of Blackburn shows this configuration:
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`Ex. 1005 (Blackburn), FIG. 3.
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`
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`As discussed in the previous section, the sensor is located on the bottom surface of
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`the bottom cushion. Hence, the bottom support plate of the sensor is a support
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`mounting for the cushion
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`37. Blackburn further discloses including a panel in the support for the bottom
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`surface of the bottom cushion and arranging the array of seat sensors between the
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`cushion bottom surface and the panel. Although the above disclosure and FIG. 3
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`describe features of the occupant sensor 60, Blackburn describes that the sensor array
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`260 includes a “bottom plate 312” that is configured identically to the bottom plate
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`92 of the sensor 60, and that supports each of the occupant sensors 300 and weight
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`sensors 302 in the array. See Id. at 10:30-67. FIG. 11 shows the array including the
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`bottom plate 312:
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`Ex. 1005, detail of FIG. 11 (annotated)
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`
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`The weight sensors 302 are mounted to the bottom plate 312, which provides the
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`support required for the sensors to respond to the downward force of an occupant’s
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`weight. See Blackburn at 10:66-68, 11:23-35. Further, the bottom plate 312 is
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`rigidly secured relative to the vehicle floor and positioned beneath the bottom surface
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`of the seat cushion 262. See Id. at 4:56-58, 10:30-67. Hence, the bottom plate 312
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`of the sensor 260 is a panel that supports the bottom surface of the seat cushion.
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`Additionally, the array of sensors mounted onto the top of the bottom plate, are
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`located between the bottom plate (panel) and the cushion bottom surface.
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`38.
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`In my opinion, one of skill in the art as of the Critical Date would have
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`modified the occupant sensing air bag control system of Schousek to implement the
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`sensor configuration of Blackburn, because the combination amounts to simple
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`substitution of one known element for another to obtain predictable results.
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`Blackburn describes “[a]n occupant sensing apparatus for use in an occupant
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`restraint system” including “an array of sensors located” on the bottom surface of a
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`seat cushion connected to a “controller.” Id. at Abstract, FIG 9, 9:41-43, 10:21-23,
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`10:3-6. This is similar to the “air bag restraint system [that] is equipped with [a] seat
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`occupant sensing apparatus” including “eight variable resistance pressure sensors in
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`the seat cushion” of Schousek. See Ex. 1004, Abstract. Blackburn teaches the
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`particular configuration of seat sensors described above. One of skill in the art
`
`would have been motivated to use the techniques described in Blackburn to allow
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`Schousek to enable airbag deployment based on weight measurements from an array
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`of sensors on the bottom surface of a seat cushion. See, e.g., Ex. 1005, FIG. 10. The
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`results of such a combination would have been predictable, because the sensor array
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`and its location in the seat of Blackburn would perform the same function (detecting
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`occupant weight) in the same way (by measuring downward force exerted by the
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`occupant of the seat) as the seat sensor configuration described in Schousek. See Ex.
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`1004, 3:64-4:22, 5:26-50; Ex. 1005, 9:39-43,14:55-15:48.
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`V. LEGAL PRINCIPLES
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`A. Anticipation
`
`39.
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`I have been informed that a patent claim is invalid as anticipated under 35
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`U.S.C. § 102 if each and every element of a claim, as properly construed, is found
`
`either explicitly or inherently in a single prior art reference. Under the principles of
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`inherency, if the prior art necessarily functions in accordance with, or includes the
`
`claimed limitations, it anticipates.
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`NY 245483725v2
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`20
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`40.
`
`I have been informed that a claim is invalid under 35 U.S.C. § 102(a) if the
`
`claimed invention was known or used by others in the U.S., or was patented or
`
`published anywhere, before the applicant’s invention. I further have been informed
`
`that a claim is invalid under 35 U.S.C. § 102(b) if the invention was patented or
`
`published anywhere, or was in public use, on sale, or offered for sale in this country,
`
`more than one year prior to the filing date of the patent application (critical date).
`
`And a claim is invalid, as I have been informed, under 35 U.S.C. § 102(e), if an
`
`invention described by that claim was described in a U.S. patent granted on an
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`application for a patent by another that was filed in the U.S. before the date of
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`invention for such a claim.
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`B. Obviousness
`
`41.
`
`I have been informed that a patent claim is invalid as “obvious” under 35
`
`U.S.C. § 103 in light of one or more prior art references if it would have been
`
`obvious to a person of ordinary skill in the art, taking into account (1) the scope and
`
`content of the prior art, (2) the differences between the prior art and the claims, (3)
`
`the level of ordinary skill in the art, and (4) any so called “secondary considerations”
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`of non-obviousness, which include: (i) “long felt need” for the claimed invention, (ii)
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`commercial success attributable to the claimed invention, (iii) unexpected results of
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`the claimed invention, and (iv) “copying” of the claimed invention by others.
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`NY 245483725v2
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`21
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`42.
`
`I have been informed that a claim can be obvious in light of a single prior art
`
`reference or multiple prior art references. To be obvious in light of a single prior art
`
`reference or multiple prior art references, there must be a reason to modify the single
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`prior art reference, or combine two or more references, in order to achieve the
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`claimed invention. This reason may come from a teaching, suggestion, or motivation
`
`to combine, or may come from the reference or references themselves, the
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`knowledge or “common sense” of one skilled in the art, or from the nature of the
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`problem to be solved, and may be explicit or implicit from the prior art as a whole. I
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`have been informed that the combination of familiar elements according to known
`
`methods is likely to be obvious when it does no more than yield predictable results. I
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`also understand it is improper to rely on hindsight in making the obviousness
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`determination.
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`VI. ADDITIONAL REMARKS
`
`43.
`
`I currently hold the opinions set expressed in this declaration. But my analysis
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`may continue, and I may acquire additional information and/or attain supplemental
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`insights that may result in added observations.
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`44.
`
`I hereby declare that all statements made of my own knowledge are true and
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`that all statements made on information and belief are believed to be true. I further
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`declare that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`NY 245483725v2
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`22
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`

`

`US. Patent No. 6,012,007
`under Section 1001 of the Title 18 of the United States Code and that such willful
`
`false statements may jeopardize the validity of the application or any patents issued
`
`thereon.
`
`Dated: October 28, 2015
`
`By: W ,7
`
`roll/l % $3,?!er -;...,C{//\,’L
`
`Dr. Kirsten Carr
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`NY 245483 725v2
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`23
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`
`CARR ANALYSIS, LLC
`
`4957 High Meadow Lane
`Ann Arbor, MI 48103
`Phone: (734) 730-3589
`www.CarrAnalysis.com
`
`
`
`
`
`
`
`Kirsten M. Carr, Ph.D., P.E.
`KCarr@CarrAnalysis.com
`
`PROFESSIONAL EXPERIENCE
`
`
`Carr Analysis, LLC – Ann Arbor, MI
`May, 2011-present
`
`
`
`
`
`President and Principal Consultant
`Expert in mechanical and manufacturing engineering, with specific expertise in forensic
`analysis of mechanical components, vehicular accidents, industrial equipment, vehicle
`restraint and seat systems, and electromechanical systems. Additional expertise in
`manufacturing quality control, failure analysis, durability and fatigue analysis, statistical
`data analysis, and vehicular component testing.
`
`
`Packer Engineering, Inc. – Ann Arbor, MI
`2006-May, 2011
`Director
`Responsible for managing and performing mechanical and manufacturing engineering
`investigations and analyses for legal, insurance, and industrial firms.
`
`
`Ford Motor Company – Dearborn, MI
`2004-2006
`Supervisor, Powertrain Forward Model Quality
`Lead engine and transmission engineering teams in the technical design robustness
`evaluation of new designs and design changes. Developed and taught a full-day technical
`course on design robustness to nearly 1,500 engineers.
`
`
`
`
`
`
`2000-2004
`Supervisor, Core and Advance Safety Sensors
`Responsible for creating, staffing, and directing a team of mechanical and electrical
`engineers tasked with managing the safety sensors (front impact, occupant classification,
`side impact, rollover, and pre-crash) available to vehicle programs, including performance
`requirements and specifications, electrical architecture, testing and delivering new sensor
`technologies, providing vehicle program support, and supporting corporate-level
`interactions with government agencies and consortia. Delivered occupant classification
`capability to meet new FMVSS regulations, including authoring performance specifications
`and delivering multiple sensor technologies using Six Sigma methods. Communicated Ford’s
`state of technology in occupant classification to NHTSA. Integrated pre-crash and occupant
`sensors into vehicle for live demonstrations of controlling seatbelt and airbag systems
`
`
`
`
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`Page 1 of 5
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`January 2015
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`
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`based on these sensor inputs. Co-invented and patented advanced rollover sensor
`algorithm.
`
`
`1997-2000
`Technical Specialist, Occupant Safety Research
`Invented new vehicle safety devices for the occupant compartment with a focus on seat
`belt technology and seat technology.
`
`1996-1997
`Technical Specialist, Manufacturing Research
`Developed and validated machining simulation models and dimensional management and
`tolerancing technologies.
`
`
`
`
`1995
`Product Engineer, Automatic Transmission
`Responsible for testing regarding the contribution of the automatic transmission to vehicle
`noise-vibration-harshness and powertrain temperature management of thermal loads.
`
`
`1995
`Prototype Build Manager, F-Series Prototype Build
`Responsible for the assembly of prototype vehicle interiors at the prototype vehicle plant,