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`EXPERT DECLARATION OF NICHOLAS SHEWCHENKO
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`Case No. IPR2016-01649
`Patent No. 8,813,269
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`
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`
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`Riddell Exhibit 2001
`Kranos Corp. v. Riddell, Inc.
`IPR2016-01649
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`
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`Declaration of Nicholas Shewchenko
`IPR2016-01649
`
`I.
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`INTRODUCTION & SUMMARY OF OPINIONS
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` My name is Nicholas Shewchenko. I have been engaged by Riddell,
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`Inc. in connection with IPR number 2016-01649, which relates to U.S. Pat. No.
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`8,813,269 (“the ’269 patent”). In this declaration I provide my opinion that
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`Petitioner Kranos Corporation d/b/a/ Schutt Sports (“Kranos”) has not shown that
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`the instituted claims of the ’269 patent are obvious in view of the instituted
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`references and grounds.
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`II.
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`PROFESSIONAL QUALIFICATIONS
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`A. Background and Experience
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`
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`I am currently the President of Biokinetics and Associates Ltd. in
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`Ottawa, Ontario and have been since June of 2002. I have been employed by
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`Biokinetics and Associates in various capacities since 1984.
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`
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`I have a Bachelor of Engineering, Mechanical from Carleton
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`University in Ottawa, Ontario.
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` My professional affiliations and memberships (past and present)
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`include the following: I am and have been a member of the Society of Automotive
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`Engineers (SAE) since 1986. I am and have been a member of the Association of
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`Professional Engineers of Ontario (APEO) since 1989. I was a member of The
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`Canadian Association of Road Safety Professionals (CARSP) from 1999 to 2009. I
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`was a member of the Canadian Advisory Council, CAC/TC22/SC10 from 2001 to
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`2005. I was a member of Motorcycles −Test and analysis procedures for research
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`evaluation of rider crash protective devices fitted
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`to motorcycles, ISO
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`TC22/SC22/WG22, participant status, from 2001 to 2005. I am and have been a
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`member of the Canadian Association of Defence and Security Industries (CADSI)
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`since 2002. I was a member of the American Association of Automotive Medicine
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`(AAAM) from 2002 to 2007. I was a member of the American Society for Testing
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`and Materials (ASTM) from 2002 to 2009. I was a member of the Sporting Goods
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`Manufacturing Association (SGMA) from 2002 to 2004. I am and have been a
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`member of the Ontario Society of Professional Engineers (OSPE) since 2003. I am
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`and have been a member of the Consulting Engineers of Ontario (CEO) since
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`2004. I was a member of the Survival and Flight Equipment Association (SAFE)
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`from 2005 to 2014. I was a member of the Canadian Association of Defence and
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`Security Industries (CADSI) Events Planning Committee from 2014 to 2015.
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`
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`I have presented at or attended seventeen workshops related to
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`protective headgear or personal protective equipment, injury analysis and test
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`methodology development. I have authored or co-authored 45 publications in the
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`field of injury biomechanics. I have also prepared at least 117 research and
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`professional reports involving injury analysis and assessment, test surrogate and
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`methodology development, and injury reduction solutions.
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`Attached hereto is a true and correct copy of my curriculum vitae,
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`updated to November 2016. As detailed in my CV, I am a named inventor on
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`numerous patents.
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`B. Compensation
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`
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`I am being compensated for my time in this case at the rate of $300
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`per hour (plus expenses) for analysis, depositions, and, if necessary, trial
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`testimony. My compensation for this matter is not determined by or contingent on
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`the outcome of this case.
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`C. Materials Relied Upon
`
`
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`In the course of preparing this expert declaration, I have considered
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`the ’269 patent, its file history, the Petition and related exhibits (including the
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`Declaration of Mr. Float), the Patent Owner’s Preliminary Response, the Board’s
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`Institution Decision, the transcript of the deposition of Mr. Float, as well as the
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`additional documents I cite or refer to in this declaration.
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`III. THE BOARD’S INSTITUTION DECISION
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`
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`I understand the Board granted review of the ‘269 patent on two
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`grounds: (a) alleged obviousness of claims 1, 4-8, 13 and 15-19 in view of Ide and
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`Szendel, and (b) alleged obviousness of claims 1, 2, 4-8, 13 and 15-19 in view of
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`Ide and Jadoul.
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`IV. LEGAL STANDARDS APPLIED
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`
`
`I am not an expert in patent law, and I am not purporting to provide
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`any opinions regarding the correct legal standards to apply in these proceedings. I
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`have been asked, however, to provide my opinions in the context of the following
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`legal standards that have been provided to me by Riddell’s attorneys.
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` Obviousness in General: I have been informed that a patent can be
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`invalidated through obviousness if the subject matter of a claim as a whole would
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`have been obvious at the time of the invention to a person of ordinary skill in the
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`art. I understand that obviousness allows for the combination of prior art
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`references. I have been informed that there are three basic inquiries that must be
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`considered for obviousness:
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`a. What is the scope and content of the prior art?
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`b. What are the differences, if any, between the prior art and each claim
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`of the patent?
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`c. What is the level of ordinary skill in the art at the time the invention
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`of the patent was made?
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`
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`I also understand that a claim composed of several elements is not
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`proved obvious merely by demonstrating that each of its elements was
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`independently known in the prior art. I understand that when prior art references
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`require selective combination to render a patent obvious, there must be some
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`reason to combine the references other than hindsight. I further understand that an
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`assertion of obviousness cannot be sustained by mere conclusory statements, and
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`that there must be some articulated reasoning with some rational underpinning to
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`support a finding of obviousness. In particular, a person of skill in the art had to
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`have had a motivation to combine the prior art in the way claimed in the claim and
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`had a reasonable expectation of success in doing so. I understand that features
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`from prior art references need not be physically combinable (i.e., a combination
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`may be obvious if one of ordinary skill in the art would know how to make any
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`necessary modifications to combine features from prior art references), but that this
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`concept does not negate the requirement of a reasonable expectation of success.
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`
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`I understand that one must also consider the evidence from secondary
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`considerations including commercial success, copying, long-felt but unresolved
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`needs, failure of others to solve the problem, unexpected results, and whether the
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`invention was made independently by others at the same time of the invention. I
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`understand that these secondary considerations can overcome a finding of
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`obviousness.
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`
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`I also understand that a combination of references does not render a
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`claim obvious if a reference teaches away from its combination with another
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`reference. I understand that a reference may teach away when (1) the teachings of
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`a prior art reference undermine the reason being proffered as to why a person of
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`ordinary skill would have combined elements of the reference with another prior
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`art reference, (2) a proposed modification to a prior art reference’s device would
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`render the device inoperable for its intended purpose, or (3) when a person of
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`ordinary skill, upon reading the reference, would be led in a direction divergent
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`from the path that was taken by the applicant.
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`
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`I further understand that in performing an obviousness analysis, it
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`may be necessary to construe the one or more terms that are recited in the claims. I
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`have been informed that in an Inter Partes Review, claims are given their broadest
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`reasonable interpretation in light of the claims and specification. I have been
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`informed that this means that the broadest reasonable construction of a term is not
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`simply one which covers the most embodiments but one that is reasonable in light
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`of the claims and specification.
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART
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`
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`I understand that a person of ordinary skill in the art (“POSITA”) is
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`considered to have the normal skills and knowledge of a person in a certain
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`technical field, as of the time of the invention at issue. I understand that factors
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`that may be considered in determining the level of ordinary skill in the art include:
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`(1) the education level of the inventor; (2) the types of problems encountered in the
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`art; (3) the prior art solutions to those problems; (4) the rapidity with which
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`innovations are made; (5) the sophistication of the technology; and (6) the
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`education level of active workers in the field.
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`
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`I understand that Kranos’ expert, Mr. Float, has defined the relevant
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`art as “the field of coupling and release mechanisms” generally and opined that a
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`POSITA “would have [a] bachelor's degree in engineering or more than three years
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`of experience in product design, with specific experience in attachment and release
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`mechanism design.” Ex. 1028; Float Decl. at ¶ 18.
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` The ‘269 patent generally relates to connecting a faceguard to a
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`protective helmet for use in contact sports, such as football. As such, the faceguard
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`must be rigidly secured to the shell of the helmet by a plurality of connectors so
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`that it stays connected despite numerous (and sometimes violent) impacts during
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`the course of a game.
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` Football players are subject to significant levels of impact during
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`game play with non-concussive head acceleration levels of around 60 G and
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`concussive levels of 89 G, translating to 600-900 pounds of force that the helmet
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`and components must withstand on a routine basis. Pellman E., Viano D.C. et al.,
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`“Concussion in Professional Football: Reconstruction of Game Impacts and
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`Injuries”, Journal of Neurosurgery, Vol. 53, No. 4, October 2003; a copy of this
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`reference is submitted as Exhibit 2002.
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` Given the potential for significant injury, football (and other contact
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`sports) has instituted rigid safety standards for helmets. For example, the National
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`Operating Committee on Standards for Athletic Equipment (“NOCSAE”)
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`maintains safety guidelines for athletic equipment. I have reviewed Exhibit 2003
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`in this proceeding, which is a copy of NOCSAE document Standard Method of
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`Impact Test and Performance Requirements for Football Faceguards (Rev. July 10,
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`1990), which outlines some of NOCSAE’s standards for facemasks for football
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`helmets manufactured up to 2009. Section 4 of this NOCSAE document identifies
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`the requirements for the materials, finishes and attachment systems used for
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`facemasks. Section 6 outlines the details of the drop test procedure for testing the
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`durability of a facemask, while Section 4.1.1 outlines
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`the performance
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`requirements (e.g., the Severity Index (SI) shall not exceed 1200 and the faceguard
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`shall not contact the face region during a drop height of 36 inches) necessary to
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`ensure the integrity and safety of a faceguard.
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`
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`In view of these potential safety hazards and stringent performance
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`requirements associated specifically with the design of helmets for contact sports,
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`in my opinion a person of ordinary skill in the art with respect to the ‘269 patent
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`would have a degree in a relevant technical, physics, or engineering field and at
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`least two years of experience designing and engineering sports helmets.
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`Alternatively, one could be considered a person of ordinary skill in the art without
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`IPR2016-01649
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`the relevant technical degree with at least five years of experience designing sports
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`helmets.
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`
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`I have 30 years of combined experience in the design of protective
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`helmets and a degree in Mechanical Engineering. Therefore, in view of my
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`education and background, it is my opinion that I am qualified to opine as to the
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`knowledge, understanding, and perspective of a person of skill in the art in the
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`relevant time frame. Accordingly, my opinions concerning the application of the
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`references to the claimed subject matter of the ’269 patent and the state of the art
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`are based on what a POSITA would have understood at the time of the invention of
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`those patents, which I understand to be on or about the priority date of the ‘269
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`patent, April 16, 2007.
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`VI. CLAIM CONSTRUCTION
`
` Petitioner did not provide any constructions for any disputed terms in
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`the ‘269 IPR.
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`
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`In its Institution Decision, the Board construed the claim limitation
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`“releasable coupler mechanism” to mean: a coupler mechanism that does not
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`employ a threaded connector, such as a screw, that is rotated to attach or detach a
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`component, such as a faceguard. The Board also construed the claim limitation
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`“actuation force” to mean: a force that lacks a rotational component.
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` Based on the Board’s construction, it is clear that these claim
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`limitations do not cover a conventional threaded screw/nut connector, such as the
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`one disclosed in one of Riddell’s prior patents (U.S. Patent No. 6,934,971 to Ide.
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`
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`I understand that Petitioner’s expert, Mr. Float, testified that the
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`claimed “actuation force” includes a rotational component. (Ex. 2004, Dep. Tr. of
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`Jamison Float, at 73:16-23 (stating that when reading the actuation force limitation,
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`“I read it to include the rotational component.”). While I agree that the ‘269 claims
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`do not cover a conventional threaded screw/nut connector (which requires
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`significant time to detach), I believe that the ‘269 claims may cover a connector
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`with an “actuation force” having a rotational component, provided that the
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`connector can be quickly detached.
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`VII. OPINIONS REGARDING ASSERTED OBVIOUSNESS GROUNDS
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`
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`In my opinion, the combination of Ide and Szendel/Jadoul does not
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`render obvious the claims of the ‘269 patent because: (1) a POSITA would not
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`have considered either the Szendel or the Jadoul connector as being suitable for
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`connecting a facemask to a football helmet; and (2) the proposed combinations fail
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`to disclose each of the limitations of the challenged claims.
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`A. The Secondary References Are Not Analogous Art
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`
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`1.
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`Szendel is not analogous art
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` First, A POSITA would not have considered Szendel analogous art. I
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`understand that to qualify as prior art, a reference must either have been in the
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`same field of endeavor as the claimed invention or been a reference that a POSITA
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`would have logically considered in attempting to solve the problem addressed by
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`the inventors.
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` Szendel generally relates to a connector for an in-line skate. It is
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`completely unrelated to football helmets (or, for that matter, sports helmets in
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`general).
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` Szendel discloses a dual-axle connector that includes a bearing spacer
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`6 (shown in orange below) that is placed in the inner opening of the tire portion 10
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`(shown in gray):
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`The Szendel connector includes axle assemblies on both sides of the tire 10 that
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`connect to the bearing spacer 6, thereby securing the tire portion 10. As shown
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`above, the components on the left side of the wheel are labelled “A,” while the
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`identical components on the right side are labelled “B.” These axle assemblies
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`include, among other things: (1) two axle shafts 8A and 8B (shown in red); (2) two
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`axle shaft release pins 9A and 9B (shown in blue); and (3) multiple locking balls
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`12 (shown in green).
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` Petitioner cites to the first and fourth embodiments of Szendel
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`(generally Figures 3, 7, 10 and portions of the corresponding text). Each of these
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`embodiments disclose a connector have two axle assemblies – one on each side of
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`the in-line skate wheel requiring access to each side for connection and removal.
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`
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`In my opinion, when considering which of the many types of
`
`connectors to use to attach a facemask to a helmet, a POSITA would not have
`
`considered a dual-axle connector of Szendel.
`
` While the dual-axle connector of Szendel may be appropriate for
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`connecting an item such as in-line skate wheel, which can be accessed from two
`
`different sides, it would not suffice for attaching a facemask to a helmet. It is
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`beneficial to have a facemask that can be quickly disengaged should a player be
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`injured. If such an injury occurs, the player will be wearing the helmet, meaning
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`that medical personnel will only have access to the outside of the helmet. Medical
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`personnel would not be able to apply the requisite inward or outward force
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`necessary to disengage the axle shaft release pin of Szendel’s connector on the
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`inside of the helmet. Nor would medical personnel want to reach inside the helmet
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`to disengage the connector for fear that they could cause further injury to the
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`player by sticking their hands inside the helmet to jostle the connector.
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` Moreover, the Szendel connector cited by Petitioner includes two axle
`
`shafts that extend significantly from the bearing spacer. The space between the
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`outer surface the right and left skate rails typically exceeds an inch and may be as
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`Declaration of Nicholas Shewchenko
`IPR2016-01649
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`large as two inches. By contrast, the width of a football helmet at the point where
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`the facemask is attached is typically less than an inch.
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` Neither Petitioner nor its expert has provided any basis for modifying
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`the Szendel connector to be operable with a football helmet. It is my opinion that
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`even if one attempted to scale down the Szendel connector to fit within the
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`confines of a football helmet it would likely not result in an operable connector and
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`protrude from the inner and/or outer shell surfaces. Moreover, it would present
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`safety concerns to the wearer and other players and may render the helmet to be
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`non-compliant with NOCSAE standards. For example, Section 4.2.4 of Exhibit
`
`2003 requires that all components of the facemask be finished and free from edges
`
`or other irregularities that could cut or scratch the wearer of an opposing player.
`
`
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`I understand that Petitioner’s expert suggested that substituting the
`
`Szendel connector for the Ide connector would be a “straightforward design
`
`modification.” While it may be relatively easy for a POSITA to swap out
`
`connectors, Petitioner’s expert’s statement ignores that a POSITA would not have
`
`considered Szendel a viable alternative for attaching a facemask to a football
`
`helmet. In view of the required one-sided removal requirement, durability and
`
`safety concerns discussed above, any run-of-the-mill connector would not suffice
`
`for use with a football helmet.
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`2.
`
`Jadoul is not analogous art
`
`
`
`Jadoul generally relates to a device for assembling two parts, each part
`
`having a detachable fastener attached to it.
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` As shown in Figure 1 below, the two fasteners are referred to as the
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`“retaining component” 1 (in red) and the “reception component” 2 (in blue). The
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`“retaining component” includes deformable tongues 11, while the “reception
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`component” has a recess 23 that is complimentary in shape to the end of the
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`deformable tongues. To engage the fastener, the “retaining component” is inserted
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`in the “reception component.” As shown in Figure 4, as the user presses down on
`
`the “retaining component,” the tongues deform until the end of the tongue mates
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`with the recess on the “reception component.” The spring-loaded plug 3 (in green)
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`exerts a force on the end of the tongue, holding it into place.
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` To release, the user presses down on the plug 3, which pushes the end
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`of the plug through the bottom 25 of the “reception component.” It also
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`disengages the plug from the “retaining component,” allowing the tongues to again
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`deform and, with the assistance of the spring, move up and out of the “reception
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`component.”
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` The only application for this device disclosed by Jadoul is to connect
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`a battery to a radiotelephone with emphasis on achieving an accurate connection
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`without any play. The emphasis of the connector for football applications does not
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`include removing excess play of the connection but rather quick removal and
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`robustness of the mechanisms to withstand large impact forces. If one were able to
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`strengthen the mechanism of Jadoul, with metal construction for example, the need
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`for flexible tabs and close interference fit of the retaining component would result
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`in high activation/release forces and/or poor lateral and bending strength of the
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`retaining component due to the shallow seating depth into the reception
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`component. These pose safety concerns during emergency removal where a large
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`force may be required to flex the tabs of the retaining component for removal after
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`depressing the plug, which could cause the medical personnel to jostle the head of
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`the injured player (something that should be avoided at all cost if there is a
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`potential neck or spinal injury). It would also pose safety concerns during game
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`play where separation of the faceguard can exacerbate injuries from facial contact
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`or being dislodged.
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`
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`Jadoul also discloses that the fasteners (e.g., the component shown in
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`red above) are securely fixed to the parts (e.g., the phone battery) using, for
`
`example, a screw/nut connector, welding, or by glue. This connection is meant to
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`be more permanent than the connection between the two fasteners (e.g., the red and
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`blue components above)
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` Because the fasteners are deformable, they must be made of flexible
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`material. Jadoul suggests that the fasteners may be made of plastic.
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` While a plastic fastener attached by glue may be sufficient for holding
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`a phone battery in place, it is woefully deficient for connecting a facemask to a
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`football helmet. A POSITA at the time of the invention would have realized that
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`the Jadoul fastener would not have been durable enough to withstand the axial and
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`lateral forces generated from substantial facemask contact during a football game,
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`and would likely have failed to meet the stringent safety standards required for
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`football facemasks.
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`
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`B.
`
`The Proposed Combinations Do Not Disclose All Of The Claim
`Limitations
`
` The Board has already rejected
`
`that
`
`the “releasable coupler
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`mechanism” of the ‘269 patent covers a conventional threaded screw/nut
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`connector, such as disclosed by Ide. Nevertheless, the only basis that Petitioner
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`has provided for its obviousness argument is that Ide discloses the claimed
`
`“releasable coupler mechanism.” Petitioner has come forth with no evidence that
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`either Szendel or Jadoul discloses the claimed “releasable coupler mechanism,” or
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`that it would have been obvious to modify either the Szendel or Jadoul connector
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`to come up with the claimed invention.
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`
`
`It is my opinion that neither Szendel nor Jadoul discloses the
`
`“releasable coupler mechanism.” Moreover, because neither Szendel nor Jadoul is
`
`sufficient for attaching a facemask to a helmet (per my discussion above), a
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`POSITA would not have attempted to modify either Szendel or Jadoul to come up
`
`with the claimed invention.
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`I reserve the right to supplement my opinion to provide further detail
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`about my opinions in this Section should Petitioner provide attempt to supplement
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`its position.
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`VIII. CONCLUSION
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` For the reasons discussed, in my opinion, the instituted claims would
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`not have been rendered obvious by the combination of Ide and Szendel or Jadoul.
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`
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further that these statements are 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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`under Section 1001 of Title 18 of the United States Code.
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`
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`Dated: May 24, 2017
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`_____________________________
`Nicholas Shewchenko
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