`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DYNACRAFT BSC, INC.,
`
`Petitioner,
`
`V.
`
`MATTEL, INC.,
`Patent Owner.
`
`Case IPR2018-0003 8
`
`Patent 7,222,684
`
`DECLARATION OF JEFF REYNOLDS
`
`1
`1
`
`-
`
`Mattel Ex. 2001
`Mattel Ex. 2001
`Dynacraft v. Mattel
`Dynacraft v. Mattel
`IPR2018-00038
`|PR2018-00038
`
`
`
`1, Jeff Reynolds, declare to the best of my recollection as follows;
`
`1.
`
`I worked at Fisher-Price in East Aurora, New York, from 1977 to 2015.
`
`I retired
`
`in 2015 and am currently retired.
`
`I was continuously employed at Fisher-Price for that entire
`
`period, except for 1985 to 1988, during which time I was at Hasbro.
`
`2.
`
`From approximately 1995 to 2010, I was assigned to Fisher-Price’s Power Wheels
`
`electromechanical group in the development of children’s battery powered ride-ons.
`
`3.
`
`I graduated from Worcester Polytechnic Institute in 1977 with a Bachelor of
`
`Science degree in Mechanical Engineering.
`
`4.
`
`As over twenty years have passed since many of these events have transpired, the
`
`following reflects my best recollection regarding the events surrounding Power Wheels’
`
`development of a soft-start system:
`
`I started with the Power Wheels group as a manager for the
`
`electromechanical group in 1995. From my earliest times with the group, I recall being made
`
`aware of consumer complaints regarding the jerky on/off nature of Power Wheels vehicles.
`
`These vehicles had issues with electrical “in rush,” as well as mechanical failures, due to the
`
`abrupt on/off nature of the electromechanical systems employed in these vehicles. Addressing
`
`these concerns was challenging in large part due to the cost constraints that these vehicles were
`
`manufactured under. To solve this, additional features were explored and needed to be
`developed in a way that did not add unacceptable levels of complexity and cost to the
`
`manufacturer and consumer.
`
`5.
`
`Power Wheels as a group grappled with ways of dealing with these issues in a
`
`safe, and cost effective manner from my earliest time with the team.
`
`I recall different attempts to
`
`do so that were not successful, including efforts by my team to purchase motor controllers and
`
`incorporate them into prototype ride-ons.
`
`2
`
`
`
`6.
`
`At some point in those days, likely in the late 19903 or very early 2000s, I recall
`
`speaking with with Tony Norman from Innovation First to discuss speed control as a possible
`
`solution to these problems. Following on these conversations, Innovation First ended up
`
`designing speed control circuits for Power Wheels within Power Wheels’ acceptable safety and
`
`performance parameters. To my recollection, this was the first acceptable electronic speed
`
`control system utilized in a Power Wheels vehicle that effectively slowed the time over which
`
`the motors reached full speed.
`
`The forgoing is true and correct to the best of my recollection.
`
`Vii-201$
`Date
`
`ff eynolds
`
`3
`
`
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