`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DYNACRAFT BSC, INC.,
`Petitioner,
`
`v.
`
`MATTEL, INC.,
`Patent Owner.
`
`Case IPR2018-00039
`Patent 7,950,978
`
`DECLARATION OF JEFF REYNOLDS
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`1
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`Mattel Ex. 2001
`Dynacraft v. Mattel
`IPR2018-00039
`
`
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`
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`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. I retired
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`in 2015 and am currently retired. 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 development of 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 many of these events have transpired, the
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`following reflects my best recollection regarding the events surrounding Power Wheels’
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`development of a soft-start system: I started with the Power Wheels group as a manager for the
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`electromechanical group in 1995. From my earliest 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 had issues 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 was challenging in 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 needed to be
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`developed in a way that did not add unacceptable levels of complexity 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 my earliest time with the team. 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 prototype ride-ons.
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`2
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`6.
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`At some point 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 my recollection, this was the first 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 forgoing is true and correct to the best of my recollection.
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` Date
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` Jeff Reynolds
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`3
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