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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`
`
`
`
`American Honda Motor Company, Inc.
`Petitioner
`
`v.
`
`Intellectual Ventures II LLC
`Patent Owner
`_______________
`
`Case IPR2018 – 00619
`
`U.S. Patent No. 7,067,952
`_______________
`
`DECLARATION OF DR. JAMES KIRTLEY JR IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 7,067,952
`
`
`
`
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`Am. Honda v. IV II - IPR2018-00619
`PET_HONDA_1002-0001
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`
`Table of Contents
`
`I.
`
`Introduction ...................................................................................................... 1
`
`II. Qualifications .................................................................................................... 1
`
`III. Materials Considered ........................................................................................ 6
`
`IV. Summary of Opinions ....................................................................................... 7
`
`A. Person Having Ordinary Skill in the Art .......................................................... 7
`
`B. Claim Construction ........................................................................................... 9
`
`C. Obviousness .................................................................................................... 10
`
`D. Anticipation .................................................................................................... 12
`
`V. Overview of the ’952 Patent ........................................................................... 12
`
`A. The ’952 Patent ............................................................................................... 12
`
`B. Prosecution History of the ’952 Patent ........................................................... 15
`
`C. The Effective Filing Date of Challenged Claims 1 and 10-14 Is March 5,
`
`2003. ...................................................................................................................... 16
`
`D. Relevant Technology ...................................................................................... 17
`
`VI. Summary of Prior Art ..................................................................................... 19
`
`A. Inoue (JP 11-341717) (Ex. 1004) ................................................................... 19
`
`B. Ishihara (JP 11-89128) (Ex. 1005) ................................................................. 23
`
`C. Iikuma (JPH 9-308163) (Ex. 1006) ................................................................ 25
`
`D. Calsonic (JP 2000-184635) (Ex. 1007) .......................................................... 26
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`E. Sheeran (U.S. Patent Publication No. 2004/0084988) (Ex. 1008) ................. 28
`
`VII. Claims Challenged .......................................................................................... 29
`
`VIII. Detailed Analysis of Grounds of Challenge ................................................... 31
`
`A. Ground 1: Claims 1, 10- 14 are obvious over Inoue ...................................... 31
`
`B. Ground 2: Claims 10-14 are Obvious over Inoue in view of Ishihara ........... 54
`
`C. Ground 3: Claims 10-14 are Obvious over Inoue in view of Iikuma............. 60
`
`D. Ground 4: Claims 10-14 are Obvious over Inoue in view of Calsonic .......... 65
`
`E. Ground 5: Claims 10-14 are Obvious over Inoue in view of Sheeran ........... 71
`
`IX. Conclusion ...................................................................................................... 77
`
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`PET_HONDA_1002-0003
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`I, Dr. James Kirtley, Jr., declare as follows:
`I.
`
`Introduction
`
`1.
`
`I am making this declaration in connection with the petition for
`
`inter partes review of U.S. Patent No. 7,067,952 (“the ’952 patent”).
`
`2.
`
`I am being compensated for my work in these matters at a rate of
`
`$400 per hour for my professional consulting services. I am also reimbursed for
`
`my reasonable expenses incurred in connection with my work in this proceeding.
`
`My compensation is not in any way contingent upon the outcome of this Inter
`
`Partes Review. I have no interest in the outcome of this proceeding or any related
`
`litigation.
`
`II. Qualifications
`
`3.
`
`My qualifications for presenting the opinions in this Declaration
`
`are set forth below and in my curriculum vitae.
`
`4.
`
`I earned Bachelor’s and Master’s degrees in electrical
`
`engineering from the Massachusetts Institute of Technology (MIT) in September,
`
`1968. I earned a Ph.D. in Electrical engineering from MIT in September, 1971.
`
`5.
`
`In my research work in pursuit of the Ph.D. and afterwards, I
`
`constructed a large electric machine (a generator) in which the armature winding
`
`was fully encapsulated in resin material. That armature winding was cooled by a
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`fluid (transformer oil) flowing through channels formed by the copper windings
`
`and encapsulating resin.
`
`6.
`
`I have been a professor of electrical engineering at MIT since
`
`1971. While serving on the faculty at MIT for nearly 45 years, I taught courses in
`
`electric machinery; electric power systems; the design of electric motors,
`
`generators, and drives; and control systems and digital electronic systems.
`
`7.
`
`One of the classes I have been teaching at MIT is design of
`
`motors, generators, and drive systems. It teaches the construction of aggressive,
`
`high-performance motor drives. From this class, professionals who design systems
`
`that employ electric machinery for generation or as motors in any of these
`
`industries can gain a deeper understanding of how electric machines operate. This
`
`class includes hands-on experiments that provide opportunities to compare
`
`analytical results with real motor/drive systems in the laboratory.
`
`8.
`
`At MIT, I have supervised fifteen PhD theses, 88 Master’s degree
`
`theses and sixteen Bachelor’s degree theses, covering a wide range of topics in
`
`Electrical Engineering. In addition to thesis supervision, I have served on a number
`
`of PhD thesis committees, at MIT and at other universities. My resume does not
`
`detail the topics for these theses, but many of them deal with design issues.
`
`Specifically, I have supervised, collaborated with, and advised both Master’s and
`
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`PhD thesis students who were working on designs for electric motors and drives
`
`and for inductive battery charging systems.
`
`9.
`
`I have researched topics on electro-mechanics and electric-energy
`
`systems. For example, I have researched induction motors for vehicle drive and
`
`how to improve the performance of induction motors. I have conducted research on
`
`variable reluctance and permanent magnet drive motors and generators. I have also
`
`worked on design of induction motors in a production environment and design of
`
`advanced motor and generator machines.
`
`10.
`
`In additional to my work at MIT, I have had substantial industry
`
`experience. I worked as an intern and as a research scientist at Raytheon
`
`Corporation from 1965 until 1971. I worked as an electrical engineer in the large
`
`steam-turbine generator department at General Electric Company from 1974 until
`
`1975. I was Vice President, General Manager, and Chief Scientist at SatCon
`
`Technology Corporation from 2000 until 2004. While at Satcon, I designed
`
`brushless DC servomotors for the Magmotor Division of the company. I also
`
`participated in the design of the generators, energy storage machines, and a drive
`
`motor for the Patriot race car. I also participated in detailed electromagnetic design
`
`for Electromagnetic Aircraft Launch System (EMALS) and participated in
`
`electromagnetic design for a number of other projects.
`
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`11.
`
`I have consulted for over 50 different organizations in the field of
`
`electrical engineering. A complete list of my academic and industrial professional
`
`experience can be found in my CV.
`
`12.
`
`I am named as an inventor on at least 24 patents directed towards
`
`electric machines, electric power systems, motors, and rotors, including:
`
` J.L. Smith, Jr., P. Thullen, and J.L. Kirtley, Jr., “Stator Structure for
`Electric Machines,” U.S. Patent No. 3,781,578, issued December 25,
`1973.
`
` J.L. Kirtley, Jr., and R.H. Baker, “Electronic Motor that Includes an
`Electronic Waveform Synthesizer and the Synthesizer Per Se,” U.S.
`Patent No. 4,060,754, issued November 29, 1977.
`
` J.L. Kirtley, Jr., “Variable Speed Electronic Motor,” U.S. Patent No.
`4,233,548, issued November 11, 1980.
`
` R. Salter, J.L. Kirtley Jr., G. Rao, D. Bushko, G. Colello, “Solid Rotor
`Assembly,” U.S. Patents No. 5,793,142, issued Aug 11, 1998; and
`U.S. Patent No. 5,798,593., issued August 25, 1998.
`
` K.M. Avakian, J.L. Kirtley Jr., G.P Rao, D.A Bushko, G. Colello,
`“Rotor Squirrel Cage Construction,” U.S. Patent No. 5,808,391,
`issued Sept. 15, 1998.
`
` J.L. Kirtley Jr., G.P. Rao, D.A. Bushko, J.R. Oleksy, “Stator
`fabrication process,” U.S. Patent No. 5,852,865, issued December 29,
`1998.
`
` J.L. Kirtley Jr., G. Rao, D.A. Bushko, J.R. Oleksy, “Stator Fabrication
`Process,” U.S. Patent No. 5,852,865, issued Dec 29, 1998.
`
` Eisenhaure, DB, Kirtley, JL Jr., Lansberry, GB, Donegan, KJ, Rao,
`GP, “Externally Field-Controlled Induction Generator,” U.S. Patent
`No. 5,929,612, issued July 27, 1999.
`
` 
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` G.P Rao, J.L. Kirtley Jr., D.C. Meeker, K.J. Donegan, “Hybrid
`permanent magnet/homopolar generator and motor,” U.S. Patent No.
`6,097,124, issued August 1, 2000.
`
` D.B. Eisenhaure, J.L. Kirtley Jr., L.E. Lesster, “Uninterruptible Power
`Supply System Using a Slip-Ring, Wound-Rotor-Type Induction
`Machine and a Method for Flywheel Energy Storage,” U.S. Patent No.
`7,071,581, issued July 4, 2006.
`
`13.
`
`I have published a number of books, including a co-authored one
`
`titled “Electric Motor Handbook,” which was published in 1998 by McGraw-Hill.
`
`This book has several chapters that describe, from a theoretical and physical basis,
`
`how different classes of motors work, as well as practical information about
`
`existing motors and motor standards.
`
`14.
`
`I have published 100 papers in refereed professional journals,
`
`112 papers in refereed professional conferences, four technical magazine articles,
`
`and numerous technical reports on electric motors, generators, drives, control
`
`systems, and digital electronic systems.
`
`15.
`
`I have also authored numerous research proposals, proprietary
`
`technical memoranda, and test reports on electric motors, generators, drives,
`
`control systems, and digital electronic systems.
`
`16.
`
`My professional memberships include the Institute of Electrical
`
`and Electronic Engineers (IEEE), the International Conference on Large High
`
`Voltage Electric Systems (CIGRE), the National Academy of Engineering and the
`
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`American Association for the Advancement of Science. I am a Registered
`
`Professional Engineer in Massachusetts.
`
`17.
`
`I served as Editor in Chief of the IEEE Transactions on Energy
`
`Conversion from 1998 to 2006 and continue as Associate Editor for the same
`
`journal. I am a member of the Editorial Board of the journal Electric Power
`
`Components and Systems. I chaired the International Conference on Electric
`
`Machines (ICEM) in 1990 and was program chair of the International Electric
`
`Machines and Drives Conference in 2001. I have served as chairman and vice-
`
`chairman of the Electric Machinery Committee of the IEEE Power Engineering
`
`Society (Now known as the IEEE Power and Energy Society).
`
`18.
`
`I have received multiple awards for my contributions to the field
`
`of electrical engineering, including the Nikola Tesla Award in 2002 from the IEEE
`
`Power Engineering Society and the IEEE Third Millennium Medal in 2000 and to
`
`membership in the National Academy of Engineering in 2007.
`
`III. Materials Considered
`
`19.
`
`The analysis provided in this Declaration is based on my
`
`education as well as my experience in this field. In addition to relying on my
`
`knowledge based on written materials and other information that was known
`
`before March 5, 2003, I have considered the documents described in this
`
`Declaration.
`
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`IV. Summary of Opinions
`
`20.
`
` In my opinion, claims 1 and 10-14 of the ’952 patent are
`
`directed to technologies that were well known before March 5, 2003 and are not
`
`patentable. Claims 1 and 10-14 are anticipated by or obvious over Inoue (JP 11-
`
`341717) (Ex. 1004); claims 10-14 are obvious over Inoue in view of Ishihara (JP
`
`11-89128) (Ex. 1005); claims 10-14 are obvious over Inoue in view of Iikuma (JP
`
`9-308163) (Ex. 1006); claims 10-14 are obvious over Inoue in view of Calsonic
`
`(JP 2000-184635) (Ex. 1007); and claims 10-14 are obvious over Inoue in view of
`
`Sheeran (U.S. Patent Publication No. 2004/0084988) (Ex. 1008).
`
`Legal Standards
`A. Person Having Ordinary Skill in the Art
`
`V.
`
` 
`
`21.
`
`I understand that the disclosures of patents and prior art
`
`references are to be viewed from the perspective of a person of ordinary skill in the
`
`art at the time of the alleged invention (“POSITA”).
`
`22.
`
`I have been asked to provide my opinion regarding the “level of
`
`ordinary skill in the art” at the time of the invention, which I have been told is on
`
`or before March 5, 2003.
`
`23.
`
`I understand that the hypothetical person of ordinary skill in the
`
`art is considered to have the normal skills and knowledge of a person in a certain
`
`technical field. I understand that factors that may be considered in determining the
`
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`level of ordinary skill in the art include: (1) the education level of the inventor; (2)
`
`the types of problems encountered in the art; (3) the prior art solutions to those
`
`problems; (4) rapidity with which innovations are made; (5) the sophistication of
`
`the technology; and (6) the education level of active workers in the field. I also
`
`understand that “the person of ordinary skill” is a hypothetical person who is
`
`presumed to be aware of the universe of available prior art.
`
`24.
`
`I also understand the level of ordinary skill in the art can be
`
`evidenced by the prior art. Accordingly, I have also considered the prior art
`
`discussed herein in determining the level of ordinary skill in the art.
`
`25.
`
`In my opinion, a POSITA with respect to the ’952 patent as of
`
`their priority date would generally have a Bachelor’s degree in Electrical or
`
`Mechanical Engineering, or equivalent experience, and two years of relevant work
`
`experience in the area of electric motor design. A POSITA would be familiar with
`
`the fundamentals of electric motor design and operation, the concept of
`
`encapsulating various components in an electric motor, the types of materials that
`
`could be used for encapsulation and their thermal and dimensional properties. A
`
`POSITA would further be familiar with techniques for manufacturing encapsulated
`
`motors, including injection molding.
`
`
`
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`B. Claim Construction
`26.
`I understand that the first step in determining the validity of a
`
`claim is for the claim to be properly construed. I understand that “claim
`
`construction” is the process of determining a patent claim’s meaning.
`
`27.
`
`For purposes of Inter Partes Review, I understand that each
`
`challenged claim must be given its broadest reasonable interpretation in light of the
`
`patent specification. I am informed that the broadest reasonable interpretation
`
`dictates that claim terms are given their ordinary and customary meaning, as would
`
`be understood by a POSITA in the context of the entire disclosure or specification
`
`of the patent, unless the inventor, as a lexicographer, has set forth a special
`
`meaning for a term. I understand that a patent’s “specification” includes all the
`
`figures, discussion, and claims within the patent document.
`
`28.
`
`I understand that the limitation that “the bridge is formed by
`
`interconnecting two mating sections formed from the phase change material” has
`
`been construed to be a product by process claim and to mean “the bridge comprises
`
`two sections mated to the stator segments that are interconnected and formed from
`
`the phase change material.” IPR2017-01631, Paper 11 at 9-12; IPR2017-01497,
`
`Paper 9 at 10-13. In this declaration, I apply that construction to my analysis. As
`
`shown below, the encircled locations of FIG. 5 have been identified as the
`
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`locations where webbing 23 is mated to encapsulated stator arc segments 20.
`
`IPR2017-01631, Paper 11 at 11-12; IPR2017-01497, Paper 9 at 12-13.
`
`Annotated FIG. 5 of the ’952 patent
`
`
`
`C. Obviousness
`
` 
`
`29.
`
`I understand that a patent claim is unpatentable as obvious if
`
`subject matter within the definition provided by the claim would have been
`
`obvious to a POSITA as of the time of the invention at issue. I understand that the
`
`following factors must be evaluated to determine whether the claimed subject
`
`matter was obvious: (1) the scope and content of the prior art; (2) the difference or
`
`differences, if any, between the subject matter defined by the claim of the patent
`
`under consideration and what is disclosed in the prior art; (3) the level of ordinary
`
`skill in the relevant field at the time; and (4) so-called “objective evidence of non-
`
`obviousness.”
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`30.
`
`I understand that so-called “objective indicia of non-obviousness”
`
`(also known as “secondary considerations”) like the following can be considered
`
`when assessing obviousness: (1) commercial success; (2) long-felt but unresolved
`
`needs; (3) copying of the invention by others in the field; (4) initial expressions of
`
`disbelief by experts in the field; (5) failure of others to solve the problem that the
`
`inventor solved; and (6) unexpected results. I also understand that evidence of
`
`objective indicia of non-obviousness must be commensurate in scope with the
`
`claimed subject matter. I am not aware of any objective indicia of non-obviousness
`
`relevant to the claims of the ’952 patent.
`
`31.
`
`I understand that that prior art references can be combined to
`
`support a finding that a claim is unpatentable for obviousness when there was an
`
`apparent reason for one of ordinary skill in the art, at the time of the invention, to
`
`combine the references and that such apparent reasons include: (A) identifying a
`
`teaching, suggestion, or motivation to combine prior art references; (B) combining
`
`prior art methods according to known methods to yield predictable results; (C)
`
`substituting one known element for another to obtain predictable results; (D) using
`
`a known technique to improve a similar device in the same way; (E) applying a
`
`known technique to a known device ready for improvement to yield predictable
`
`results; (F) trying a small number of identified, predictable potential solutions, with
`
`a reasonable expectation of success; and (G) identifying that known work in one
`
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`field of endeavor may prompt variations of it for use in either the same field or a
`
`different one based on design incentives or other market forces if the variations are
`
`predictable to one of ordinary skill in the relevant field.
`
`D. Anticipation
`
` 
`
`32.
`
`I understand that a patent claim is unpatentable as anticipated if a
`
`POSITA during the relevant timeframe would have understood a single prior art
`
`reference to disclose an embodiment that expressly or inherently teaches every
`
`limitation contained in the claim. The disclosure in a reference does not have to be
`
`in the same words as the claim, but all of the requirements of the claim must be
`
`described in enough detail, or necessarily inherent in an embodiment disclosed in
`
`the reference, to enable a POSITA looking at the reference to practice the claimed
`
`invention.
`
`V. Overview of the ’952 Patent
`
`A. The ’952 Patent
`
` 
`
`33.
`
`The ’952 patent relates to a stator assembly, which includes a
`
`plurality of stator arc segments linked together by a phase change material. Ex.
`
`1001 at [Abstract]. A stator arc segment 20 is first constructed using steel pieces.
`
`Id. at 5:61-62. The stator assembly in the ’952 patent can be formed by injection
`
`molding a plurality of stator arc segments 20 (FIG. 2) aligned to form a toroidal
`
`core. Id. at 5:48-50. Through injection molding, the steel pieces are coated with
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`encapsulating material 22 which provides electrical insulation and laminates the
`
`pieces together to form a stator arc segment 20. Id. at 6:1-5. The encapsulating
`
`material also links other arc segments into a continuous strip via webbing 23. Id.
`
`                       
`FIGS. 2 and 3 of the ’952 patent
`
` 
`
` 
`
`34.
`
`According to the ’952 patent, the encapsulating material 22 is
`
`preferably formed of a phase change material. Id. at 6:6-9. A phase change
`
`material means “a material that can be used in a liquid phase to envelope the stator,
`
`but which later changes to a solid phase.” Id. According to the ’952 patent, phase
`
`change materials include temperature activated material, such as thermoplastics;
`
`and include chemically activated material. Id. at 6:9-28. The ’952 patent discloses
`
`an example list of resin materials as the phase change material. Id. at 9:3-19.
`
`35.
`
`As shown in FIG. 2 of the ’952 patent, the segments 20 can be
`
`placed in a multi-cavity mold and, after being coated with the phase change
`
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`material, the overmolded segments are ejected from their cavities. Id. at 6:29-35.
`
`New laminations are inserted into the cavities and the process repeats. Id. In the
`
`preferred embodiment, a continuous strip of segments is formed by linking the
`
`webbing from successive molding operation. Id. at 6:35-38. This is done by
`
`inserting a section of the plastic webbing of the segment molded in the prior cycle
`
`with the new laminations to be molded. Id. at 6:38-41. When the plastic
`
`encapsulates the new segments, it can mechanically lock with or re-melt the
`
`webbing from the prior cycle, thus making a continuous strip, as shown in FIG. 5.
`
`Id. at 6:41-45.
`
`FIG. 5 of the ’952 patent
`
` 
`
`36.
`
`According to the ’952 patent, as shown in FIG. 10, a steel band
`
`can be used to unitize the webbed stator arc segments. Id. at 5:35-37.
`
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`FIG. 10 of the ’952 patent
`
`
`
`
`B. Prosecution History of the ’952 Patent
`
`37.
`
`The ’952 patent was filed on March 5, 2003 and is a
`
`continuation-in-part of application number 09/798,511 (“’511 application”) (Ex.
`
`1011) filed on March 2, 2001. According to the Examiner, the claims were
`
`allowable because the prior art does not teach that “the retaining member
`
`comprises a metal band,” that “the bridge is formed by interconnecting two mating
`
`sections formed from the phase change material,” and that “the flexible carrier
`
`links said segments by connecting two mating sections formed in said carrier.” Ex.
`
`1003 at 10/19/2005 Office Action at 5.
`
`
` 
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` 
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`C. The Effective Filing Date of Challenged Claims 1 and 10-14 Is March 5,
`2003.
`38.
`
` The ’952 patent is not entitled to the priority date of the ’511
`
`application filed on March 2, 2001. I have been informed that for challenged
`
`claims 1 and 10-14 of the ’952 patent to claim priority to the ’511 application, that
`
`application must provide written description support for the limitations in those
`
`claims. The ’511 application does not provide written description for all the
`
`limitations in independent claims 1, 10, and 14. For example, the ’511 application
`
`does not describe “a bridge between adjacent segments to link adjacent segments
`
`into a continuous strip” of independent claim 1, does not describe “a bridge
`
`between adjacent segments to link adjacent segments into a continuous strip,
`
`wherein the bridge is formed by interconnecting two mating sections formed from
`
`the phase change material” of independent claim 10, and does not describe “a
`
`phase change material constituting said flexible carrier adhered to the stator arc
`
`segments which links said segments in a uniform and predetermined position with
`
`respect to one another; wherein the flexible carrier links said segments by
`
`connecting two mating sections formed in said carrier” of independent claim 14.
`
`Therefore, challenged claims 1 and 10-14 are not entitled to the filing date of
`
`the ’511 application, and have an effective filing date of March 5, 2003.
`
`Additionally, I have been informed that the Patent Owner acknowledges in the
`
`related ITC case that the priority date for asserted claims 10 and 12 is March 5,
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`2003. See Ex. 1016. I understand the Board has also decided that “the ’952 Patent
`
`is not entitled to an earlier March 2, 2001, effective filing date, but is entitled to its
`
`March 5, 2003, actual filing date.” IPR2017-01631, Paper 11 at 14; IPR2017-
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`01497, Paper 9 at 15.
`
`D. Relevant Technology
`39.
`The technology had been well known at the time the ’952 patent
`
`was filed. The ’952 patent itself admits that many aspects of claims 1 and 10-14
`
`were known. For example, it admits that U.S. Pat. No. 6,265,804 to Nitta, Ex.
`
`1012, describes the use of plastic insulation in combination with segmented stators
`
`(Ex. 1001 at 3:59-63); that U.S. Pat. No. 5,694,268 to Dunfield et al. (Ex. 1013)
`
`teaches an overmolded stator, where stator teeth and windings are overmolded by a
`
`resilient rubber-like or plastic-like material (Ex. 1001 at 3:12-13; Ex. 1013 at 8:12-
`
`18); that U.S. Pat. No. 6,167,610 to Nakahara (Ex. 1014) describes a method of
`
`making a rotary motor with a length of steel strip having thin portions connecting a
`
`plurality of blocks (Ex. 1001 at 3:64 - 4:8; Ex. 1014 at [Abstract]), where resin is
`
`molded to insulate between the stator coil and the stator core (Ex. 1014 at 3:21-22).
`
`40.
`
`The ’952 patent provides a stator formed by injection molding a
`
`plurality of stator arc segments aligned to form a toroidal core, and the segments
`
`can be encapsulated by injection molding the phase change material around the
`
`laminations. Ex. 1001 at 5:47-50, 12:51-53. Injection molding is a process where a
`
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`plastic material is heated until it becomes soft enough to force into a mold, at
`
`which point the material cools to solidify and form a specific product. Ex. 1009 at
`
`3, Plastic Injection Molding – Material Selection and Product Design
`
`Fundamentals.
`
`41.
`
`Some prior art use a process called “insert molding.” I understand
`
`that the insert molding process is the same as the process used during injection
`
`molding, where solid raw material is melted and extruded into a mold, the plastic is
`
`then solidified, and the molded parts are then ejected. Ex. 1010 at 2, What is Insert
`
`Molding for Plastic Components. The difference with injection molding is that
`
`insert molding utilizes or includes an insert, which is placed into the mold prior
`
`to melted plastic material being injected into the mold. The insert molding uses the
`
`same material as the injection molding. Id. Indeed, the ’952 patent describes the
`
`process of forming overmolded segments with insertion molding – “In the
`
`preferred embodiment the individual laminations 11 making up the segments are
`
`not interconnected but loosely stacked together before insertion into the mold 28.”
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`Ex. 1001 at 6:31-35.
`
`42.
`
`The ’952 patent describes a phase change material as a material
`
`that can be used in injection molding and insert molding, by saying that “a phase
`
`change material meaning a material that can be used in a liquid phase to envelope
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`the stator, but which later changes to a solid phase.” Therefore, the materials used
`
`in insert molding described in prior art are also phase change materials.
`
`
`
`43.
`
`Plastic materials are generally classified as either thermoplastic
`
`or thermoset. Ex. 1009 at 42-43. Thus, it is my understanding that resin is either
`
`thermoplastic or thermoset. Thermoplastic material can be reheated and
`
`reprocessed many times before the material’s properties begin to suffer. Ex. 1009
`
`at 42-43. When heated they can change from a solid to a liquid, and back again
`
`when cooled. Id. They are easily processed and formed in a mold. Id. They are also
`
`easier to recycle and repair. Thermoplastics are available in a wide variety of
`
`formulations and are a more popular choice for injection molding, with
`
`approximately 80% of all plastic products made from thermoplastic material. Id.
`
`Because of these advantages, thermoplastic materials can also have a lower overall
`
`cost making them a more favorable material selection.
`
`VI. Summary of Prior Art
`
`44.
`
`In my opinion, elements of claims 1 and 10-14 of the ’952 patent
`
`are disclosed by the following prior art or obvious over their combination.
`
`A. Inoue (JP 11-341717) (Ex. 1004)
`
` 
`
`45.
`
`Inoue describes a rotor comprising unit iron core bodies each
`
`including a yoke having an arcuate outer periphery and a planar portion on an inner
`
`periphery thereof, a tooth provided on the planar portion and having a pole shoe
`
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`defining a rotor opposing surface on the inner periphery thereof, and a winding
`
`wound around each tooth. Ex. 1004 at [Abstract], Claim 1. The unit iron core
`
`bodies are arranged in an annular pattern and the side end surfaces of the adjoining
`
`yokes closely contact one another. Id.
`
`
`
`FIG. 2 of Inoue
`
`46.
`
`In one embodiment, a unit iron core body is made by insert
`
`molding in resin a stack of core laminates, each unit core body including a yoke
`
`having an arcuate outer periphery formed with a pair of concave portions for
`
`connection. Ex. 1004 at [0024]; FIGS. 6-10. An angle Q of both end faces of the
`
`yoke portion 11A and the resin film 17 of the pole shoe portion 4 of the inner
`
`peripheral end are formed. Id. A stator can be formed by using a flat plate member
`
`to retain the unit iron core bodies by connecting the concave portions on the unit
`
`core bodies with the convex portions formed on the flat plate member. Id. at [0026].
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`47.
`
`In embodiments 6 and 9 of Inoue, unit iron cores, each having a
`
`pair of concave portions 15 for connecting on arcuate surface 14, are placed in an
`
`insert molding tool including a resin molding die and a jig to form unit iron core
`
`bodies 8C. Ex. 1004 at [0044], [0051]. In this process, a resin film 17A serving as
`
`an insulator for the unit iron core body 8C and a flat plate member 19E are
`
`integrally formed with resin. Ex. 1004 at [0044], [0051]; FIGS. 17-19 and 25.
`
`FIG. 19 of Inoue
`
`
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`FIG. 25 of Inoue 
`
`
`
`48.
`
`In one embodiment, n of the unit iron core bodies are formed into
`
`a molded assembly by being insert molded so as to be connected by a ring
`
`provided on the pole shoes. Id. at [0047]. The unit iron core bodies of each 1 unit
`
`are shifted in position so that the yoke portions are in close contact with each other,
`
`and a number of units are annularly arranged to form the stator. Id.
`
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`Annotated FIG. 20 of Inoue (resin in green)
`
`49.
`
`The ring formed on the pole shoes can be formed with fitting
`
`holes 24 so that the ribs 23 of one of the assembly can be received in the
`
`corresponding fitting holes 24. Ex. 1004 at [0049].
`
`
`
`Annotated FIGS. 23 and 24 of Inoue (resin in green)
`
`50.
`
`A fl