Petitioner Kawasaki Rail Car, Inc.’s
`Demonstrative Exhibits
`
`Kawasaki Rail Car, Inc. v. Scott Blair, IPR2017–01036
`U.S. Patent No. 6,700,602
`Jameson Lee, Scott A. Daniels and Kevin C. Trock,
`Administrative Patent Judges
`July 9, 2018
`
`Sheila Mortazavi
`Mark A. Chapman
`Zaed M. Billah
`Armin Ghiam
`HUNTON ANDREWS KURTH LLP
`
`
`Demonstrative Exhibits
`
`Kawasaki Rail Car, Inc. v. Scott Blair, IPR2017–01036
`U.S. Patent No. 6,700,602
`Jameson Lee, Scott A. Daniels and Kevin C. Trock,
`Administrative Patent Judges
`July 9, 2018
`
`Sheila Mortazavi
`Mark A. Chapman
`Zaed M. Billah
`Armin Ghiam
`HUNTON ANDREWS KURTH LLP
`
`
`
`Overview
`
`“Mounted at the junction”
`“Substantially flush” / “Flush” /
`“Substantially contiguous”
`“Cover unit” / “Enclosure”
`“Structural member”
`“Back lit panel”
`“Self-contained wiring-cabling system”
`
`1
`
`
`
`HUNTON
`ANDREWS KURTH
`
`“Mounted at the junction”
`
`“Mounted at the junction”
`
`2
`
`
`
`“Mounted at the junction” → ’602 Patent
`
`“[W]hen the monitor is mounted at
`the junction of the wall and ceiling of
`the subway car, where there is
`commonly provided a concavely
`curved segment of internal wall . . . .”
`
`“Suitable locations for video
`monitors 22 in accordance with the
`invention are at the junction of wall
`and ceiling of subway car 10 . . . .”
`
`’602 Patent (Ex. 1001), Fig. 2.
`
`’602 Patent (Ex. 1001), 3:67–4:3, 4:64–66.
`
`Malo Fourth Supplemental Declaration (Ex. 1041), ¶¶ 9–10.
`
`3
`
`
`
`“Mounted at the junction” → Namikawa
`
`’602 Patent (Ex. 1001), Fig. 2.
`
`Namikawa (Ex. 1005), Fig. 1.
`
`Malo Declaration (Ex. 1015), ¶ 41; Malo Fourth
`Supplemental Declaration (Ex. 1041), ¶¶ 9–10.
`
`4
`
`
`
`“Mounted at the junction” → Namikawa
`
`Final Written Decision, IPR2017–00117 (May 2, 2018)
`(Ex. 1042) at 19; Supplemental Reply at 11–12.
`
`5
`
`
`
`“Mounted at the junction” → Miyajima
`
`’602 Patent (Ex. 1001), Fig. 2.
`
`Miyajima (Ex. 1007), Fig. 23.
`
`Namikawa (Ex. 1005), Fig. 1.
`
`6
`
`
`
`HUNTON
`ANDREWS KURTH
`
`“Substantially flush” / “Flush” /
`“Substantially contiguous”
`“Substantially flush” / “Flush” /
`
`“Substantially contiguous”
`
`7
`
`
`
`“Substantially flush” → ’602 Patent
`
`“An alternative embodiment is
`illustrated in FIG. 4A . . . . In this
`alternative embodiment, CRT video
`monitor 22 is replaced with an LCD-
`based video monitor 22A which is of
`thin, rectangular cross-section, and
`occupies less space in the ceiling
`structure of the car. Accordingly, it
`can be moved towards the ceiling so
`that its viewing screen is
`substantially flush with or even
`behind the light panel 40.”
`
`’602 Patent (Ex. 1001), Figs. 4, 4A.
`
`’602 Patent (Ex. 1001), 5:35–42.
`
`8
`
`
`
`“Substantially flush” → Sasao
`
`“[T]he screen 3 protrudes forward
`from the cabinet 12 so that the front
`face 3a of the screen and the wall
`surface 15a in the room 14 are
`substantially flush.”
`
`Sasao (Ex. 1011), Figs. 3, 4, ¶ 10;
`Malo Declaration (Ex. 1015), ¶ 49.
`
`9
`
`
`
`“Substantially flush” → Sasao
`
`Final Written Decision, IPR2017–00117 (May 2, 2018)
`(Ex. 1042) at 22–23; Supplemental Reply at 18.
`
`10
`
`
`
`“Substantially flush” → JTOA
`
`“As an in-car guidance device, a nine inch liquid crystal monitor is provided
`above the side doors in each car . . . . Consideration has been given to
`making this monitor easy to see from the seats as well, by mounting on the
`lintel inspection cover, which is formed from fiber-reinforced plastic (FRP),
`and tilting it at an angle of 30 degrees from the vertical.”
`
`JTOA (Ex. 1002) at 1, (Ex. 1003) at 4; Malo Declaration
`(Ex. 1015), ¶¶ 55–56; Supplemental Reply at 18–20.
`
`11
`
`
`
`“Substantially flush” → Motivations
`
`Motivations to flush-mount screens (or cover units)
`of LCD monitors:
`• Conserve space
`• Flush-mounting was norm in industry
`– FRA proposed rule to flush-mount interior fittings
`• More aesthetically pleasing
`• Reduce vandalism
`• Easier to clean
`
`Malo Declaration (Ex. 1015), ¶¶ 26–31, 48, 50–54, 57, 60–61, 70–71, 95–
`96, 98, 108–109; Malo Second Supplemental Declaration (Ex. 1034), ¶ 34;
`Malo Fourth Supplemental Declaration (Ex. 1041), ¶¶ 12–15.
`
`12
`
`
`
`“Substantially flush” → Motivations
`
`Final Written Decision, IPR2017–00117 (May 2, 2018)
`(Ex. 1042) at 28; Supplemental Reply at 15–16.
`
`13
`
`
`
`“Substantially flush” → Space Behind Wall
`
`’602 Patent (Ex. 1001), 3:55–61; Malo Second
`Supplemental Declaration (Ex. 1034), ¶¶ 28–32.
`
`Zicherman Deposition (Ex. 1038) at 16:5–9.
`
`14
`
`
`
`“Substantially flush” → Space Behind Wall
`
`Malo Second Supplemental Declaration (Ex. 1034), ¶ 30.
`
`15
`
`
`
`“Substantially flush” → Space Behind Wall
`
`Final Written Decision, IPR2017–00117 (May 2,
`2018) (Ex. 1042) at 27; Supplemental Reply at 13.
`
`16
`
`
`
`“Substantially flush” → Fire safety for Namikawa
`
`Fire safety concerns would not have discouraged a
`POSITA from flush-mounting the screens (or cover
`units) of the LCD monitors of Namikawa:
`• LCD monitors of Namikawa would not have overheated
`• Even if they would have, a POSITA would have identified
`and addressed any fire safety risk by dissipating and
`ventilating excess heat
`
`Malo Second Supplemental Declaration (Ex. 1034), ¶¶ 4–27.
`
`17
`
`
`
`“Substantially flush” → Fire safety for Namikawa
`
`Zicherman Deposition (Ex. 1035) at 150:21–151:13.
`
`18
`
`
`
`“Substantially flush” → Fire safety for Miyajima
`
`Fire safety concerns would not have discouraged a
`POSITA from flush-mounting the screens (or cover
`units) of the LCD monitors of Miyajima:
`• Miyajima already has a cooling air passage and fan to
`cool the LCD backlights
`• A POSITA would have ensured that the cooling provided
`by the cooling air passage and fan would remain
`adequate
`
`Malo Fourth Supplemental Declaration (Ex. 1041), ¶¶ 5–8.
`
`19
`
`
`
`“Substantially flush” → Fire safety for Miyajima
`
`Miyajima (Ex. 1007), Fig. 23.
`
`20
`
`
`
`“Substantially flush” → Combination
`
`Final Written Decision, IPR2017–00117 (May 2, 2018)
`(Ex. 1042) at 30; Supplemental Reply at 5.
`
`21
`
`
`
`HUNTON
`ANDREWS KURTH
`
`“Cover unit” / “Enclosure”
`
`“Cover unit” / ”Enclosure”
`
`22
`
`
`
`“Cover unit” / “Enclosure” → Yamada
`
`Yamada (Ex. 1028), Figs. 1, 2; Malo
`Declaration (Ex. 1015), ¶¶ 66–67, 73, 83.
`
`23
`
`
`
`“Cover unit” / “Enclosure” → Sedighzadeh
`
`Sedighzadeh (Ex. 1025), Figs. 1, 2; Malo
`Declaration (Ex. 1015), ¶¶ 66–67, 73, 84.
`
`24
`
`
`
`“Cover unit” / “Enclosure” → Motivations
`
`Motivations to add cover unit:
`• Protect screen from damage, dust and debris
`
`Motivations to add enclosure:
`• Facilitate mounting and assembly
`• Simplify removal, repair and maintenance
`• Protect from damage during shipping and handling
`
`Motivations to make enclosure and monitor
`removable as a unit:
`• Facilitate assembly and disassembly
`• Facilitate handling for repair
`
`Malo Declaration (Ex. 1015), ¶¶ 66–67, 73, 83–85, 91.
`
`25
`
`
`
`HUNTON
`ANDREWS KURTH
`
`“Structural member”
`
`“Structural member”
`
`26
`
`
`
`“Structural member” → POSITA
`
`Malo Declaration (Ex. 1015), ¶¶ 87–88; Malo Second
`Supplemental Declaration (Ex. 1034), ¶¶ 35–37.
`
`27
`
`
`
`“Structural member” → “Typical subway car”
`
`’602 Patent (Ex. 1001), 4:36–40, 4:43–45, 4:57–58, 5:8–12, Figs. 1,
`3; Malo Second Supplemental Declaration (Ex. 1034), ¶¶ 35–36.
`
`28
`
`
`
`“Structural member” → “Typical subway car”
`
`’602 Patent (Ex. 1001), Fig. 3; Malo Second
`Supplemental Declaration (Ex. 1034), ¶ 36.
`
`29
`
`
`
`“Structural member” → POSITA
`
`Malo Second Supplemental Declaration (Ex. 1034), ¶ 37.
`
`30
`
`
`
`HUNTON
`ANDREWS KURTH
`
`“Back lit panel”
`
`”Back lit panel”
`
`31
`
`
`
`“Back lit panel” → POSITA
`
`’602 patent (Ex. 1001), 5:15–17;
`Malo Declaration (Ex. 1015), ¶ 75.
`
`32
`
`
`
`“Back lit panel” → Schwenkler
`
`Schwenkler (Ex. 1026), Figs. 1, 3;
`Malo Declaration (Ex. 1015), ¶ 75.
`
`33
`
`
`
`“Back lit panel” → Mo(cid:415)va(cid:415)ons
`
`Motivations to add back lit panels:
`• Provide proper illumination
`• Maximize effective advertising area
`
`Malo Declaration (Ex. 1015), ¶¶ 76–77, 79–80.
`
`34
`
`
`
`“Self-contained wiring-
`cabling system”
`
`35
`
`
`
`“Self-contained wiring-cabling system” → ’602 Patent
`
`’602 patent (Ex. 1001), 2:59–3:4, 6:58–60; Malo
`Second Supplemental Declaration (Ex. 1034), ¶ 39.
`
`36
`
`
`
`“Self-contained wiring-cabling system” → POSITA
`
`Malo Declaration (Ex. 1015), ¶ 63.
`
`37
`
`
`
`“Self-contained wiring-cabling system” → Maekawa
`
`Maekawa (Ex. 1009), Fig. 1; Malo Declaration
`(Ex. 1015), ¶ 65; Supplemental Reply at 22–23.
`
`38
`
`
`
`“Self-contained wiring-cabling system” → Maekawa
`
`Maekawa (Ex. 1009), Fig. 1 (annotated); Malo Declaration
`(Ex. 1015), ¶ 65; Supplemental Reply at 22–23.
`
`39
`
`
`
`“Self-contained wiring-cabling system” → Amano
`
`Amano (Ex. 1021), Fig. 2; Malo Declaration
`(Ex. 1015), ¶ 64; Supplemental Reply at 23–24.
`
`40
`
`
`
`“Self-contained wiring-cabling system” → Amano
`
`Amano (Ex. 1021), Fig. 2 (annotated); Malo Declaration
`(Ex. 1015), ¶ 64; Supplemental Reply at 23–24.
`
`41
`
`
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