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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Sony Corporation,
`Petitioner
`
`Patent No. 6,934,148
`
`Issue Date: August 23, 2005
`
`Title: Electronic Chassis and Housing
`Having an Integrated Forced Air Cooling System
`
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT 6,934,148 UNDER
`35 U.S.C. § 312 AND 37 C.F.R. § 42.104
`
`Case No. IPR2017-01961
`
`
`
`
`
`
`V.
`
`TABLE OF CONTENTS
`
`I.
`Mandatory Notices .......................................................................................... 1
`Grounds for Standing ...................................................................................... 2
`II.
`Identification of Challenge and Precise Relief Requested ............................ 2
`III.
`IV. Overview of the ’148 Patent ........................................................................... 3
`A.
`The ’148 Patent .................................................................................... 3
`B.
`Prosecution History of the ’148 Patent ................................................ 6
`Patents and Printed Publications Relied On ................................................. 10
`A. U.S. Patent No. 6,317,319 (“Lewis,” Ex.-1003) ................................ 14
`B.
`Japanese Patent Application Publication No. 11-53061
`(“Hanaguchi,” Ex.-1004, including a certified translation, Ex.-
`1005) ................................................................................................... 17
`VI. Legal Standards ............................................................................................ 18
`A.
`Claim Construction ............................................................................ 18
`VII. How the Challenged Claims Are Unpatentable............................................ 19
`A.
`Claims 1, 2, and 4 Are Obvious Under 35 U.S.C. § 103(a) in
`View of the Combination of Lewis and Hanaguchi ........................... 19
`1.
`The Combination of Lewis and Hanaguchi discloses
`every limitation of claims 1, 2, and 4 ...................................... 19
`Claim Charts ............................................................................ 43
`Obviousness of Claims 1, 2, and 4 in view of Lewis and
`Hanaguchi ................................................................................ 58
`VIII. Conclusion .................................................................................................... 65
`
`
`
`2.
`3.
`
`
`
`
`
`i
`
`
`
`TABLE OF EXHIBITS
`
`1001
`
`1002
`
`Declaration of Mr. Richard A. Flasck
`
`1003
`
`US. Patent No- 6,317,319 (“Lewis”)
`
`1004
`
`Japanese Patent Application Publication No. 11-53061
`(Published February 26, 1999), Electronic Device Having
`an Air-Cooling Stmcture (“Hanaguchi”)
`
`1005
`
`Certified Translation of Ex.-1004
`
`US. Patent No. 6,934,148 (Issued August 23, 2005), Electronic
`Chassis and Housing Having an Integrated Forced Air Cooling
`System (“’ 148 Patent”)
`
`US. Patent No. 4,860,163 (“Sarath”)
`
`1006
`
`1007
`
`1008
`
`File Wrapper for US. Patent No. 6,934,148 (Application
`No. 10/414,346)
`
`US. Patent No. 6,914,779 (“Askeland”)
`
`ii
`
`
`
`
`
`I. MANDATORY NOTICES
`Real-Party-in-Interest:
`
`Sony Corporation; Sony Corporation of America; Sony Electronics Inc.;
`
`Sony Interactive Entertainment, Inc.; Sony Mobile Communications (USA), Inc.;
`
`Sony Interactive Entertainment LLC; Sony Visual Products Inc.; Sony Video &
`
`Sound Products Inc.; and Sony Interactive Entertainment America LLC.
`
`Related Matters:
`
`The following judicial matter may affect, or be affected by, a decision in this
`
`inter partes review: ARRIS Enters. LLC v. Sony Corp. et al., Case No. 3:17-cv-
`
`02669-NC (N.D. Cal., filed May 9, 2017).
`
`The following administrative matter may affect, or be affected by, a decision
`
`in this inter partes review: In re Certain Consumer Electronic Devices, Inv. No.
`
`337-TA-1060 (“ITC case”).
`
`Lead Counsel:
`
`Clifford A. Ulrich (Reg. No. 42,194).
`
`Backup Counsel:
`
`Petitioner requests authorization to file a motion for Mark A. Chapman to
`
`appear pro hac vice as backup counsel. Mr. Chapman is a litigation attorney
`
`experienced in patent cases, and is admitted to practice law in New York, in
`
`several United States District Courts, and the U.S. Court of Appeals for the Federal
`
`1
`
`
`
`
`
`Circuit. Mr. Chapman has an established familiarity with the subject matter at issue
`
`and represents Petitioner in the ITC case, identified above.
`
`Service:
`
`Petitioner agrees to electronic service at the following email address:
`
`culrich@andrewskurthkenyon.com
`
`Service may be made at the following address:
`
`Andrews Kurth Kenyon LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
`Facsimile: (212) 425-5288
`
`II. GROUNDS FOR STANDING
`Petitioner certifies that U.S. Patent No. 6,934,148 (“’148 patent”) is
`
`available for inter partes review, and that Petitioner is not barred or estopped from
`
`requesting inter partes review challenging the patent claims on the grounds
`
`identified in this petition.
`
`III.
`
`IDENTIFICATION OF CHALLENGE
`AND PRECISE RELIEF REQUESTED
`
`Claims 1, 2, and 4 of the ’148 patent are invalid under 35 U.S.C. § 103(a),
`
`and cancelation of claims 1, 2, and 4 is requested based on the following ground:
`
`Ground 1: Claims 1, 2, and 4 are obvious under 35 U.S.C. § 103(a) in
`
`view of the combination of U.S. Patent No. 6,317,319
`
`2
`
`
`
`
`
`(“Lewis”) and Japanese Patent Application Publication No.
`
`11-53061 (“Hanaguchi”).
`
`IV. OVERVIEW OF THE ’148 PATENT
`A. The ’148 Patent
`The ’148 patent issued on August 23, 2005 from U.S. Patent Application
`
`Serial No. 10/414,346 (“’346 application”), filed on April 15, 2003. The ’148
`
`patent describes a “chassis and housing having an integrated forced air cooling
`
`system that preserves the front panel and display appearance generally associated
`
`with a rack-mounted electronics chassis system.” Ex.-1001, 1:6-11; Declaration of
`
`Richard A. Flasck (Ex.-1002), ¶9.
`
`Figure 1 of the ’148 patent is a front perspective view of a chassis 10 with a
`
`front panel and display module in place. Ex.-1001, 1:54-56. Ex.-1002, ¶10.
`
`
`
`
`
`The chassis 10 includes a base 12 and a top 22, as well as rear 14, left 16, and right
`
`18 side walls. Ex.-1001, 2:37-40. A front panel 22 is also shown. Ex.-1002, ¶11.
`
`3
`
`
`
`
`
`Figure 5 of the ’148 patent shows “a top perspective view of the chassis
`
`without the front and top panels, but with the display module, showing the internal
`
`components and centrifugal blower.” Ex.-1001, 1:65-67, 2:32-34. Figure 5 of the
`
`’148 patent is reproduced below with colored annotations. Ex.-1002, ¶12.
`
`
`
`
`
`The chassis includes an inlet vent 30 (green), a centrifugal blower 74 (red), and
`
`“baffles” 78 and 79 (blue). See Ex.-1001, 2:41, 3:26-27, 3:37-40. Centrifugal
`
`blower 74 includes an inlet port 80 on the top-facing side. Ex.-1001, 3:48-49. Ex.-
`
`1002, ¶13.
`
`4
`
`
`
`Figure 6 of the ’148 patent is a “top plain view of the chassis illustrating the
`
`internal air flow through the chassis.” Ex.-1001, 2:1-2. Figure 6 of the ’148 patent
`
`is reproduced below with colored annotations. Ex.-1002, ¶14.
`
`
`
`
`
`
`
`Intake air flows into the air inlet vent 30 (green), and the path of air entering the
`
`chamber 60 is influenced by the blower 74. Ex.-1001, 3:17-19, 26-27. The blower
`
`74 “pulls the intake air into its intake port 80” (red), and “move[s] hotter air
`
`outwardly through the blower exhaust ports 82, 83 and into the RF PWA chamber
`
`62.” Ex.-1001, 3:48-51. The “final air egress from the RF PWA chamber 62 is
`
`through one or more exhaust vents 88, 91.” Ex.-1001, 3:60-61; Ex.-1002, ¶15. The
`
`’148 patent illustrates internal air flow with a dashed-line arrow path.
`
`5
`
`
`
`
`
`Prosecution History of the ’148 Patent
`
`B.
`The ’346 application was filed with twenty claims, including, in relevant
`
`part, application claims 1, 2, 4, and 5. Application claims 1 and 4 as filed are
`
`reproduced below:
`
`1. An electronic chassis and housing having an integrated force
`air cooling system, comprising:
`a) a housing having a top, a base and front, back, left and right
`side walls which define an interior space having a predetermined
`height, as measured between the top and the base, and an inlet vent in
`at least one side wall and an exhaust vent in an opposed side wall;
`b) a centrifugal blower assembly having defined top and bottom
`planes and perimeter walls, a second predetermined height measured
`between the top and bottom planes that is less than the predetermined
`height of the interior space and inlet and outlet ports defined in the
`perimeter walls; the blower assembly is mounted within the interior
`space such that its inlet port is in fluid communication with the
`exhaust vent; and,
`c) a baffle, positioned within the interior space so that it directs
`the flow of air from the inlet vent through a non-linear path to the
`blower inlet port.
`
`4. The invention of claim 1, wherein the baffle is comprised of
`at least one blower assembly side wall that extends upwardly beyond
`the top plane and contacts the top of the housing.
`
`Ex.-1006, pages 112-113.
`
`6
`
`
`
`
`
`On July 22, 2004, the Examiner issued an Office Action, rejecting claims 1,
`
`2, and 4 under 35 U.S.C. § 102(e) as anticipated by U.S. Patent No. 6,813,149
`
`(“Faneuf”) and rejecting claim 5 under 35 U.S.C. § 103(a) as obvious in view of
`
`the combination of Faneuf and U.S. Patent No. 6,525,935 (“Casebolt”).
`
`In response, on December 22, 2004, the Applicant filed a “Reply Pursuant to
`
`37 C.F.R. §1.111” (Ex.-1006, page 61), amending claim 1 as follows:
`
`1. An electronic chassis and housing having an integrated force
`air cooling system, comprising:
`a) a housing having a top, a base and front, back, left and right
`side walls which define an interior space having a predetermined
`height, as measured between the top and the base, and an inlet vent in
`at least one side wall and an exhaust vent in an opposed side wall;
`b) a centrifugal blower assembly having defined top and bottom
`planes and perimeter walls[[,]]; a second predetermined height
`measured between the top and bottom planes that is less than the
`predetermined height of the interior space; and inlet and outlet ports
`defined in the perimeter walls; the blower assembly is mounted within
`the interior space such that its inlet port is in fluid communication
`with the exhaust vent; and,
`c) a baffle, positioned within the interior space so that it directs
`the flow of air from the inlet vent through a non-linear path to the
`blower inlet port.
`Applicant argued that “Faneuf … fails to disclose a [sic] ‘a baffle, positioned
`
`within the interior space so that it directs the flow of air from the inlet vent through
`
`7
`
`
`
`
`
`a non-linear path to the blower inlet port.’” According to the Applicant, “the
`
`claimed non-linear path of air flow is directed along heat producing circuitry
`
`devices in area 60 of the chassis prior to entering the blower inlet 80, as shown in
`
`Figure 6.” Ex.-1006, page 69 (emphasis in original).
`
`The Examiner was not persuaded by these arguments and again rejected
`
`claims 1, 2, and 4 as anticipated by Faneuf and again rejected claim 5 as obvious in
`
`view of the combination of Faneuf and Casebolt. See Ex.-1006, pages 41-49 (Final
`
`Office Action dated January 19, 2005).
`
`In response, on March 18, 2005, the Applicant filed a “Reply Pursuant to 37
`
`C.F.R. §1.114” (Ex.-1006, pages 29-39), canceling claim 4, incorporating the
`
`limitations of claim 4 into claim 1, and further amending claim 1 as follows:
`
`1. An electronic chassis and housing having an integrated force
`air cooling system, comprising:
`a) a housing having a top, a base and front, back, left and right
`side walls which define an interior space having a predetermined
`height, as measured between the top and the base, and an inlet vent in
`at least one side wall and an exhaust vent in an opposed side wall;
`b) a centrifugal blower assembly having defined top and bottom
`planes and perimeter walls; a second predetermined height measured
`between the top and bottom planes that is less than the predetermined
`height of the interior space; and inlet and outlet ports; the blower
`assembly is mounted within the interior space such that its inlet port is
`in fluid communication with the exhaust vent; and,
`
`8
`
`
`
`
`
`c) a baffle, positioned within the interior space so that it directs
`the flow of air from the inlet vent through a horizontally non-linear
`path to the blower inlet port, wherein the baffle is comprised of at
`least one blower assembly side wall that extends upwardly beyond the
`top plane and contacts the top of the housing.
`
`Ex.-1006, pages 30-31.
`
`
`
`The Applicant repeated the previous arguments that “Faneuf … fails to
`
`disclose a [sic] ‘a baffle, positioned within the interior space so that it directs the
`
`flow of air form the inlet vent through a horizontally non-linear path to the blower
`
`inlet vent.’” Ex.-1006, page 37 (emphasis in original).
`
`Thereafter, the Examiner issued a Notice of Allowance, which included the
`
`following statement of reasons for allowance:
`
`The best prior art of record, Faneuf et al. … , Casebolt … ,
`Stalley (US 5,663,868), Frank, Jr. et al. (US 6,389,499 B1), and Moss
`et al. (US 6,144,549), taken alone or in combination, fails to teach or
`reasonably suggest a printed circuit board chassis comprising: a
`housing having a height of one rack-unit, a front wall including an
`inlet vent, a baffle, a display module, and a jack; wherein the baffle is
`comprised of at least one blower assembly side wall that extends
`upwardly beyond the top plane of a blower and contacts a top of the
`housing, and is positioned within an interior space of the housing so
`that it directs a flow of air from the inlet vent through a horizontally
`non-linear path to the blower inlet port as set forth in claim 1.
`
`Ex.-1006, page 12.
`
`9
`
`
`
`
`
`V.
`
`PATENTS AND PRINTED PUBLICATIONS RELIED ON
`
`The use of forced air cooling in an electronic components chassis, including
`
`the use of baffles to provide horizontally non-linear air flow paths from a housing
`
`inlet to a fan inlet, was well known before the April 15, 2003 filing date of the ’346
`
`application. Ex.-1002, ¶16.
`
`For example, U.S. Patent No. 4,860,163 (“Sarath,” Ex.-1007), which issued
`
`in 1989, discloses “an arrangement for cooling an electronic assembly of heat
`
`generating components mounted in an equipment cabinet.” Sarath, 1:7-9.
`
`According to Sarath, “a flow control baffle” is provided to “direct cooling gas
`
`entering the front of the cabinet to the rear of the circuit packs and thence around
`
`the backplane to a plenum formed by the backplane and a rear surface of the
`
`cabinet where the gas is exhausted by convention.” Sarath, 1:51-63. Figures 2 (a
`
`perspective view) and 3 (a top view) of Sarath, annotated and reproduced below,
`
`illustrates the flow control baffles 30, 31 (green) that provide a horizontally non-
`
`linear air flow path (blue) from the housing inlet 11 to an inlet of the fan 19. Ex.-
`
`1002, ¶17.
`
`10
`
`
`
`
`
`
`
`
`
`11
`
`11
`
`
`
`
`
`
`
`U.S. Patent No. 6,914,779 (“Askeland,” Ex.-1008), which has a filing date
`
`of February 15, 2002, discloses a computing device having “a housing with various
`
`electrical and/or mechanical components included therein.” Askeland, Abstract.
`
`According to Askeland, a carriage 24 accommodates a baffle 120, which is
`
`“adapted to control the movement of air as the air passes into the interior of
`
`housing 20 and exits from housing 20.” Askeland, 10:19-22. Figure 5 of Askeland,
`
`annotated and reproduced below, illustrates the baffle 120 (green) and the
`
`horizontally non-linear air flow path (blue) between housing inlet vent 36 and the
`
`inlet port of fan 80. Ex.-1002, ¶18.
`
`12
`
`
`
`
`
`
`
`Japanese Patent Application Publication No. 11-53061 (“Hanaguchi,” Ex.-
`
`1004; certified translation, Ex.-1005), which published on February 26, 1999,
`
`discloses an electronic device casing 3 that includes baffles 12 that direct air flow
`
`from an inlet vent 3b to an inlet port of a blower 1. Figure 3(a) of Hanaguchi,
`
`annotated and reproduced below, illustrates the baffles 12 (green) directing air
`
`flow through a horizontally non-linear flow path, indicated by arrows, from the
`
`inlet vent 3b and the inlet port of the blower 1. Ex.-1002, ¶19.
`
`13
`
`
`
`
`
`
`
`Thus, the claim features upon which patentability were apparently based
`
`were conventional and well-known before the April 15, 2003 filing date of the
`
`’346 application. And, it would have been obvious to utilize these conventional
`
`features in electronic devices, such as those disclosed by U.S. Patent No. 6,317,319
`
`(“Lewis,” Ex.-1003). See Ex.-1002, ¶20.
`
`A. U.S. Patent No. 6,317,319 (“Lewis,” Ex.-1003)
`Lewis issued on November 13, 2001 and therefore constitutes prior art
`
`against the ’148 patent under 35 U.S.C. § 102(b).
`
`Lewis notes that the “components of a computer, telecommunications switch
`
`or other microprocessor-based device are usually contained within an enclosure or
`
`housing” and that “[w]hen the device is powered up, these components become
`
`heated.” Lewis, 1:10-14. According to Lewis, “such devices invariably include
`
`14
`
`
`
`
`
`some means for circulating air through the enclosure to conduct heat away from
`
`these components.” Lewis, 1:17-19; Ex.-1002, ¶21.
`
`Lewis describes three classes of computers and devices: (1) those “having a
`
`relatively high profile enclosure;” (2) “thin computers and devices;” and (3) “low
`
`profile computers.” For computers and devices “having a relatively high profile
`
`enclosure,” Lewis states that “it may suffice to provide fans at the perimeter of the
`
`enclosure to circulate air through the enclosure;” for “thin computers and devices,”
`
`Lewis states that “it is usually necessary to supplement the perimeter fans with a
`
`fan or blower which conducts the cooling air directly to and from the CPU chip in
`
`the enclosure.” Lewis, 1:21-28. For “low profile computers,” Lewis observes that
`
`“such cooling means … do not suffice to cool higher rated chips in the low profile
`
`computers.” Lewis, 1:28-33. Thus, according to Lewis, its objectives include
`
`providing “a cooling assembly for efficiently cooling a high power-rated CPU chip
`
`in a low profile computer.” Lewis, 1:38-41; Ex.-1002, ¶22.
`
`Lewis’s cooling assembly includes “flexible air baffles which direct the
`
`outlet air from the heat sink smoothly around the corners to a tube-axial exhaust
`
`fan on the opposite wall of the enclosure from the inlet fans,” Lewis, 2:8-14, and
`
`“is easily installed in an enclosure less than two inches thick and, when installed, it
`
`can efficiently cool a CPU chip having a power rating of 80 watts or more,” Lewis,
`
`15
`
`
`
`2:15-18; Ex.-1002, ¶23. Figure 1, reproduced below, is a plan view of a low profile
`
`computer incorporating Lewis’s cooling assembly. Lewis, 2:26-28.
`
`
`
`
`As illustrated in Figure 1, a horizontally non-linear air flow path is provided
`
`between the inlet vent (e.g., at fans 24) and the inlet port of the blower 44, as
`
`indicated by the arrows “AIN.” Ex.-1002, ¶24.
`
`16
`
`
`
`
`
`B.
`
`Japanese Patent Application Publication No. 11-53061
`(“Hanaguchi,” Ex.-1004, including a certified translation, Ex.-
`1005)
`
`Hanaguchi was published on February 26, 1999 and therefore constitutes
`
`prior art against the ’148 patent under 35 U.S.C. § 102(b). Hanaguchi describes “a
`
`thin, portable electronic device” and “an electronic device having a heat-generating
`
`component requiring cooling, at the interior.” Hanaguchi, ¶[0001]; Ex.-1002, ¶25.
`
`Hanaguchi notes that thin, portable electronic devices, such as laptops,
`
`generate increasingly more heat as performance improves over the years.
`
`Hanaguchi, ¶[0002]. According to Hanaguchi, the increase of heat generated by
`
`CPUs has resulted in the increase in the size of cooling fan and heat dissipation
`
`components, e.g., heatsinks, heatpipes, etc., thereby “making it difficult to reduce
`
`the weight and reduce the thickness of the electronic device.” Hanaguchi, ¶[0005];
`
`Ex.-1002, ¶26.
`
`Thus, Hanaguchi states that one of its objectives “is to provide an electronic
`
`device having an air-cooling structure, which can increase the air-cooling effect in
`
`a simple manner, without changing the size of the cooling fan or the heatsink.”
`
`Hanaguchi, ¶[0006]. Hanaguchi achieves this improved cooling structure by using,
`
`for example, ribs and structural members in a casing to partition the space and
`
`control the flow of air. Hanaguchi, ¶[0007]. In this manner, heat generating
`
`components can be arranged in the flow path to be air cooled and to minimize air
`
`17
`
`
`
`resistance. Hanaguchi, ¶[0008]; Ex.-1002, ¶27. Figure 3(a), reproduced below, is a
`
`perspective view of the interior of the electronic device.
`
`
`
`
`
`
`
`As indicated by the arrows in Figure 3(a), baffle walls 12 provide for a
`
`horizontally non-linear air flow path from the inlet port 3b, to the fan 1, and then to
`
`the exhaust port 3c. Hanaguchi, ¶[0020]; Ex.-1002, ¶28.
`
`VI. LEGAL STANDARDS
`A. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are given their
`
`broadest reasonable construction in light of the specification of the patent in which
`
`they appear. 37 C.F.R. § 42.100(b). Under the broadest reasonable interpretation
`
`standard, and absent any special definitions, claim terms generally are given their
`
`18
`
`
`
`
`
`ordinary and customary meaning, as would be understood by one of ordinary skill
`
`in the art, in view of the specification. The specification of the ’148 patent does not
`
`present any special definition for any claim term, and the prosecution history does
`
`not include any claim construction arguments, such that all claim terms of the ’148
`
`patent should be given their ordinary and customary meaning.
`
`VII. HOW THE CHALLENGED CLAIMS ARE UNPATENTABLE
`A. Claims 1, 2, and 4 Are Obvious Under 35 U.S.C. § 103(a) in View
`of the Combination of Lewis and Hanaguchi
`1.
`
`The Combination of Lewis and Hanaguchi discloses every
`limitation of claims 1, 2, and 4
`
`As described below in detail, the combination of Lewis and Hanaguchi
`
`discloses all of the features claimed in claims 1, 2, and 4 of the ’148 patent, and it
`
`would have been obvious to utilize Hanaguchi’s baffle walls 12 in Lewis’s cooling
`
`assembly to direct the flow of air in a horizontally non-linear path to effectively
`
`and efficiently cool the heat-generating components located within Lewis’s
`
`enclosure 10. Ex.-1002, ¶29.
`
`
`
`
`
`
`
`Claim 1
`
`i.
`
`An electronic chassis and housing having an integrated
`force air cooling system, comprising:
`
`Lewis discloses an electronic chassis and housing having an integrated
`
`forced air cooling system. Lewis discloses, for example, “an enclosure housing at
`
`19
`
`
`
`
`
`least one CPU chip mounted to a motherboard within the enclosure,” Lewis, 1:55-
`
`57, i.e., an electronic chassis and housing. Ex.-1002, ¶30.
`
`Lewis further discloses a cooling assembly (force air cooling system)
`
`incorporated into the enclosure. Lewis, 2:38-40. The cooling assembly utilizes
`
`“force air cooling” via multiple tube-axial fans mounted on the perimeter of the
`
`enclosure, Lewis, 2:57-62, as well as a centrifugal blower, Lewis, 3:25-45. For
`
`example, according to Lewis, the blower assembly “draws air into the housing
`
`through opening 48” and “expels the air through the exit opening 52.” Lewis, 3:33-
`
`37; Ex.-1002, ¶31.
`
`Hanaguchi describes an electronic device that includes a casing (electronic
`
`chassis and housing) having an air-cooling structure (force air cooling system).
`
`Hanaguchi, ¶[0014]. For example, Hanaguchi discloses a cooling fan that
`
`“generates a flow of air, and this increases the cooling effect, by suctioning and
`
`discharging air.” Hanaguchi, ¶[0014]; Ex.-1002, ¶32.
`
`ii.
`
`a) a housing having a top, a base and front, back, left
`and right side walls which define an interior space
`having a predetermined height, as measured between the
`top and the base, and
`
`Lewis discloses a housing having a top, a base and front, back, left and right
`
`side walls which define an interior space having a predetermined height, as
`
`measured between the top and the base. Lewis discloses, for example, an enclosure
`
`(housing) that includes “a front wall 10a, a rear wall 10b, a pair of opposite side
`
`20
`
`
`
`
`
`walls 10c, 10c, as well as a top wall 10d and a bottom wall 10e.” Lewis, 2:38-45.
`
`The “front wall 10a” and “rear wall 10b” of Lewis correspond to the claimed front
`
`and back “side walls.” The “top wall 10d” and “bottom wall 10e” of Lewis
`
`correspond to the claimed “top” and “base.” Ex.-1002, ¶33. Lewis’s enclosure 10
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`is illustrated in Figures 1 and 2, reproduced below, highlighting the front wall 10a,
`
`rear wall 10b, opposite side walls 10c, top wall 10d, and bottom wall 10e.
`
`
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`21
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`
`
`
`
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`Lewis further discloses that the enclosure 10 is “a so-called low profile
`
`enclosure having a height or thickness in the order of only two inches or less, e.g.
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`1U.” Lewis, 2:43-45. The enclosure of Lewis has a predetermined height, e.g., of
`
`two inches or less, between the top wall 10d and the bottom wall 10e. Lewis, 1:33;
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`Ex.-1002, ¶34.
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`Hanaguchi discloses an electronic device having a casing 3, corresponding
`
`to the claimed housing. The casing 3 includes peripheral sidewalls (e.g.,
`
`Hanaguchi, ¶[0009]), corresponding to the claimed front, back, left, and right side
`
`walls, which define an interior space. The casing also includes a “ceiling 3e” and a
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`“bottom surface 3f” (e.g., Hanaguchi, ¶[0019]), which correspond to the claimed
`
`top and base. Ex.-1002, ¶35. As illustrated in Figure 3b, reproduced below, the
`
`22
`
`
`
`interior space of Hanaguchi’s casing has a predetermined height, as measured
`
`between the ceiling 3e and the bottom surface 3f.
`
`
`
`
`
`iii.
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`an inlet vent in at least one side wall and an exhaust vent
`in an opposed side wall;
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`Lewis discloses an inlet vent in at least one side wall and an exhaust vent in
`
`an opposed side wall. Ex.-1002, ¶36. Lewis discloses, for example:
`
`One or more tube-axial fans 24 are mounted to the enclosure front
`wall 10a for conducting cooling air into the enclosure 10 as shown by
`the arrows AIN and one or more exhaust or purging fans 26 are
`mounted to the enclosure rear wall 10b to conduct heated air out of
`enclosure 10 as shown by arrow AOUT.
`
`Lewis, 2:57-62. Lewis’s Figure 1, reproduced below, illustrates front wall 10a and
`
`rear wall 10b (both highlighted) being opposed and also illustrates airflow through
`
`front wall 10a and through rear wall 10b. The inlet vent is at tube-axial fans 24,
`
`and the exhaust vent is at purging fans 26. Ex.-1002, ¶37.
`
`23
`
`
`
`
`
`
`Hanaguchi’s electronic device includes “suction holes provided in the
`
`electronic device casing for taking in outside air” and “discharge holes,” through
`
`which “warmed air is discharged to the exterior of the electronic device casing.”
`
`Hanaguchi, ¶¶[0014]-[0015]. Hanaguchi’s suction holes 3b correspond to an inlet
`
`vent, and the discharge holes 3c correspond to an exhaust vent. Ex.-1002, ¶38.
`
`iv.
`
`b) a centrifugal blower assembly having defined top and
`bottom planes and perimeter walls;
`
`Lewis discloses a centrifugal blower assembly having defined top and
`
`bottom planes and perimeter walls. As illustrated in Lewis’s Figure 2, reproduced
`
`and annotated below, the centrifugal blower assembly 44 has a top plane (yellow),
`
`a bottom plane (blue), and perimeter walls (green). Ex.-1002, ¶39.
`
`24
`
`
`
`
`
`
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`The centrifugal blower 44 of Lewis’s cooling assembly 32 corresponds to
`
`the claimed “centrifugal blower assembly.” The centrifugal blower assembly 44
`
`includes “a housing 46 having a large area inlet opening 48 in the bottom wall of
`
`the housing and an exit opening 52 at the side of the housing.” Lewis, 3:29-32. As
`
`shown in the annotated Figure 2 of Lewis above, the centrifugal blower assembly
`
`44’s housing 46 has a defined top plane (yellow), bottom plane (blue), and
`
`perimeter walls (green). Ex.-1002, ¶40.
`
`25
`
`
`
`
`
`Hanaguchi’s electronic device has an air-cooling structure, which includes
`
`“a cooling fan, which generates a flow of air … by suctioning and discharging air.”
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`Hanaguchi, ¶[0014]. Ex.-1002, ¶41.
`
`v.
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`a second predetermined height measured between the top
`and bottom planes that is less than the predetermined
`height of the interior space;
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`Lewis discloses a second predetermined height measured between the top
`
`and bottom planes that is less than the predetermined height of the interior space.
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`As illustrated in Figure 2, Lewis’s centrifugal blower 44 (centrifugal blower
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`assembly) has a rectangular exit opening 52, which “has the same dimensions as
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`the end openings into the heat sink channel 34.” Lewis, 3:29-34. Thus, the
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`centrifugal blower assembly 44 has a predetermined height measured between the
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`top and bottom planes. Ex.-1002, ¶42.
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`The centrifugal blower assembly 44 has a predetermined height that is less
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`than the predetermined height of the interior space because it is positioned inside
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`the interior space: i.) with a baffle on top; and ii.) with space between the bottom
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`plane and the bottom of the enclosure 10. Ex.-1002, ¶43. The cooling assembly 32,
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`which includes the centrifugal blower assembly, is positioned inside enclosure 10,
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`(Lewis, 2:63-3:45), with baffle member 74 between the centrifugal blower
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`assembly 44 and the enclosure 10 (see Lewis, Fig. 2). Additionally, the cooling
`
`26
`
`
`
`
`
`assembly 32 does not extend to the bottom plane of the interior space of enclosure
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`10:
`
`When the cooling assembly 32 is secured thusly to chip 18, it is
`important to note that blower 44 extends out beyond the edge of
`motherboard 16 so that the blower inlet opening 48 is completely
`unobstructed.
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`Lewis, 3:63-66 (emphasis added). This can be further seen in Figure 3 of Lewis, in
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`which cooling air AIN can be seen to flow under then into the centrifugal blower
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`44. The predetermined height measured between the top and bottom planes of the
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`centrifugal blower assembly 44 is thus less than the predetermined height of the
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`interior space of the enclosure 10. Ex.-1002, ¶44.
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`Hanaguchi’s electronic device includes “a cooling fan provided within a
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`casing.” Thus, the height of the cooling fan is less than the height of the interior of
`
`the casing. Ex.-1002, ¶45.
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`vi.
`
`and inlet and outlet ports;
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`Lewis discloses a centrifugal blower assembly having inlet and outlet ports.
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`Lewis discloses, for example, that the centrifugal blower housing 46 (of the
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`centrifugal blower assembly 44) has “a large area inlet opening 48 in the bottom
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`wall of the housing.” Lewis, 3:25-34. The inlet opening 48 corresponds to the
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`claimed inlet port. According to Lewis, “cooling air is sucked into the blower [44]
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`and discharged through heat sink 33.” Lewis, 4:58-60. The “exit opening 52”
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`27
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`
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`(Lewis, 3:30-32) of the blower 44 corresponds to the claimed outlet port. Ex.-1002,
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`¶46.
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`Hanaguchi discloses an electronic device that includes “a cooling fan, which
`
`generates a flow of air … by suctioning and discharging air.” Hanaguchi, ¶[0014].
`
`Ex.-1002, ¶47.
`
`vii.
`
`the blower assembly is mounted within the interior space
`such that its inlet port is in fluid communication with the
`inlet vent and its exhaust port is in fluid communication
`with the exhaust vent; and,
`
`Lewis discloses that the blower assembly is mounted within the interior
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`space such that its inlet port is in fluid communication with the inlet vent and its
`
`exhaust port is in fluid communication with the exhaust vent. As noted above: an
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`inlet vent is disclosed in Lewis at the location of fans 24; an exhaust vent is
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`disclosed at fan 26; an inlet port to the blower is indicated at 48; and an outlet port
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`is indicated at the exit opening 52 of the blower assembly 44. Ex.-1002, ¶48.
`
`According to Lewis:
`
`When fans 24 and 26 and cooling assembly 32 are in operation, air is
`drawn into enclosure 10 as shown by the arrows AIN in FIG. 1, with
`the flow of that incoming air being directed to the inlet opening 48 of
`blower 44. That cooling air is sucked into the blower and discharged
`through the heat sink 33…. As the heated air AOUT nears exhaust fan
`26, it is again redirected 90° by skirt 88 directly into fan 26 so that the
`flow rate of the heated air exiting enclosure 10 is maximized.
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`28
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`
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`Lewis, 4:55-5:2. The air flow path is illustrated in Figure 1 of Lewis, reproduced
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`below, between AIN and AOUT. Ex.-1002, ¶49.
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`Thus, the inlet port 48 of
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