`
`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 PETER VOM SCHEIDT
`
`1
`1
`
`Mattel Ex. 2002
`Mattel Ex. 2002
`Dynacraft v. Mattel
`Dynacraft v. Mattel
`IPR2018-00038
`IPR2018-00038
`
`
`
`I, Peter T. vom Scheidt Jr., declare as follows:
`
`(1)
`
`I am a Staff Engineer at Fisher-Price in East Aurora, NY, and support the Power
`
`Wheels group that designs and develops Fisher-Price’s line of battery-powered ride-ons for
`
`children.
`
`(2)
`
`I started working at Fisher—Price in 2003, and have been continuously employed
`
`there since.
`
`I have been supporting the Power Wheels group for the past four years.
`
`(3)
`
`I graduated from State University of New York at Buffalo in 2003 with a
`
`Bachelors of Science degree in Electrical Engineering.
`
`(4)
`
`I inspected the electrical assembly of Dynacraft’s 24—Volt Disney Princess
`
`Carriage. During that process, I found a “soft-start” circuit, a photograph of which is attached as
`
`Exhibit A. From my inspection of that circuit, it appears that Dynacraft’s board is copied from a
`
`previous Fisher-Price soft-start circuit. This is the case because the design is essentially identical
`
`in execution.
`
`(5)
`
`Attached as the first image in Exhibit A to this declaration is an image of the prior
`
`Fisher-Price soft-start circuit board. As the first image shows, Fisher-Price’s board has a relay
`
`(circled in purple) that is present to address potential issues with failures of the primary field-
`
`effect transistors (or FETs, circled in red). Two of these FETs are high power driver FETs, and
`
`the third is a pre-driver FET.
`
`(6)
`
`Attached as the second image in Exhibit A is an image of the current Dynacraft
`
`sofi-start circuit board. As the second image shows, Dynacraft’s board also has a relay (circled
`
`again in purple) and three FETs (circled again in red). Again, two of FETs are high power driver
`
`FETs, and the third is a pre-driver FET. The fact that this configuration is effectively the same
`
`indicates that Dynacraft or one of its manufacturers developed its board by referencing the
`
`Fisher-Price board as a starting point and copying its design.
`
`I come to this conclusion because,
`
`2
`
`
`
`in the time that has passed since this original Mattel board was designed by Innovation First,
`
`FET design has improved and a company doing its own circuit design work would no longer use
`
`the configuration of the older Innovation First board with two of the FETs in parallel and a relay.
`
`Much more cost effective, durable FET solutions exist today that even make the relay no longer
`
`necessary. A company doing its own circuit design work would have incorporated some of these
`
`advances. The fact that none of these solutions were used by Dynacraft, but rather the prior
`
`Innovation First design taken in full, evidences to me that the circuit was copied by Dynacraft.
`
`I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing is true and
`
`correct.
`
`Executed:
`
`»\
`
`Peter vorn Scheidt
`
`3
`
`
`
`Exhibit A
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`
`
`4
`
`
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