`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DYNACRAFTBSC,INC.,
`Petitioner,
`
`V.
`
`MATTEL,INC.,
`Patent Owner.
`
`Case IPR2018-00038
`Patent 7,222,684
`
`DECLARATION OF JEFF REYNOLDS
`
`1
`
`Mattel Ex. 2001
`Mattel Ex. 2001
`Dynacraft v. Mattel
`Dynacraft v. Mattel
`IPR2018-00038
`IPR2018-00038
`
`
`
`I, Jeff Reynolds, declare to the best of my recollection as follows;
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`1.
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`I worked at Fisher-Price in East Aurora, New York, from 1977 to 2015.
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`I retired
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`in 2015 and am currently retired.
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`I was continuously employed at Fisher-Price for that entire
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`period, except for 1985 to 1988, during which time I was at Hasbro.
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`2.
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`From approximately 1995 to 2010, I was assigned to Fisher-Price’s Power Wheels
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`electromechanical group in the developmentof children’s battery powered ride-ons.
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`3.
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`I graduated from Worcester Polytechnic Institute in 1977 with a Bachelor of
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`Science degree in Mechanical Engineering.
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`4.
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`As over twenty years have passed since manyofthese events have transpired, the
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`following reflects my best recollection regarding the events surrounding Power Wheels’
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`developmentofa soft-start system:
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`I started with the Power Wheels group as a managerfor the
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`electromechanical group in 1995. From myearliest times with the group, I recall being made
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`aware of consumer complaints regarding the jerky on/off nature of Power Wheels vehicles.
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`These vehicles hadissues with electrical “in rush,” as well as mechanical failures, due to the
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`abrupt on/off nature of the electromechanical systems employed in these vehicles. Addressing
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`these concerns waschallengingin large part due to the cost constraints that these vehicles were
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`manufactured under. To solve this, additional features were explored and neededto be
`developed in a way that did not add unacceptable levels ofcomplexity and cost to the
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`manufacturer and consumer.
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`5.
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`Power Wheels as a group grappled with ways of dealing with these issues in a
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`safe, and cost effective manner from myearliest time with the team.
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`I recall different attempts to
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`do so that were not successful, including efforts by my team to purchase motor controllers and
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`incorporate them into prototyperide-ons.
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`2
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`
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`6.
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`At somepoint in those days,likely in the late 1990s or very early 2000s,I recall
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`speaking with with Tony Norman from Innovation First to discuss speed control as a possible
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`solution to these problems. Following on these conversations, Innovation First ended up
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`designing speed control circuits for Power Wheels within Power Wheels’ acceptable safety and
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`performance parameters. To myrecollection, this was thefirst acceptable electronic speed
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`control system utilized in a Power Wheels vehicle that effectively slowed the time over which
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`the motors reached full speed.
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`The forgoingis true and correct to the best of my recollection.
`
`|= 14- Zan¥
`Date
`
`ff Reynolds
`
`3
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`