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`IPR2018-01061
`US Patent No. 6,557,540
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`Exhibit No. 1002
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`
`Hyundai Motor Company,
`
`Petitioner
`
`v.
`
`Michigan Motor Technologies LLC,
`
`Patent Owner
`
`
`
`Patent No. 6,557,540
`
`Issue Date: May 6, 2003
`
`Title: METHOD OF CALCULATING A
`VALVE TIMING COMMAND FOR AN ENGINE
`
`
`Inter Partes Review No. IPR2018-01061
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`____________________________________________________________
`
`DECLARATION OF SCOTT ANDREWS
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`
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`IPR2018-01061
`US Patent 6,748,540
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`TABLE OF CONTENTS
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`Page
`INTRODUCTION ........................................................................................... 1
`I.
`BACKGROUND ............................................................................................. 1
`II.
`SUMMARY OF MY OPINIONS ................................................................... 4
`III.
`IV. LEGAL PRINCIPLES ..................................................................................... 5
`A.
`Person of Skill in the Art ....................................................................... 5
`B.
`Claim Interpretation .............................................................................. 6
`C.
`Priority Date .......................................................................................... 7
`D.
`Prior Art ................................................................................................. 7
`E.
`Anticipation ........................................................................................... 8
`F.
`Obviousness ........................................................................................... 8
`i.
`Motivation to Combine ............................................................... 9
`ii.
`Secondary Considerations ......................................................... 12
`V. DOCUMENTS RELIED UPON ................................................................... 13
`VI. OVERVIEW OF THE TECHNOLOGY ....................................................... 15
`A.
`Background of the Technology ........................................................... 15
`VII. SCOPE OF THE PRIOR ART ...................................................................... 28
`VIII. CLAIM CONSTRUCTION .......................................................................... 29
`IX. SUMMARY OF THE ‘540 PATENT ........................................................... 29
`X. OPINIONS ON CLAIM CONSTRUCTION ................................................ 38
`A.
`“engine performance”.......................................................................... 38
`B.
`“environmental conditions signal” ...................................................... 40
`C.
`“vehicle performance command” ........................................................ 42
`D.
`“fuel conversion data” ......................................................................... 43
`E.
`“engine emissions data” ...................................................................... 44
`XI. OVERVIEW OF THE PRIOR ART ............................................................. 47
`A. U.S. Patent No. 5,713,317 (“Yoshioka”) ............................................ 47
`B.
`Torque Management of Engines with Variable Valve Timing, By
`Jankovic, Stefanopoulou, and Cook .................................................... 51
`XII. CLAIMS 1-3, 7, 10-11, AND 14 OF THE ‘540 PATENT ARE INVALID
`AS OBVIOUS ............................................................................................... 57
`A. Ground 1: Claims 1-3, 7, 10-11, and 14 are Rendered Obvious Under
`the Combination of Yoshioka and Jankovic ....................................... 57
`i.
`Summary ................................................................................... 57
`ii.
`Claim Element Analysis ........................................................... 58
`iii.
`The Combination of Yoshioka and Jankovic ............................ 91
`XIII. CONCLUSION .............................................................................................. 95
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`IPR2018-01061
`US Patent 6,748,540
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`I.
`1.
`
`INTRODUCTION
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`I have been retained by counsel for Hyundai Motor Company (“HMC” or
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`“Petitioner”), and asked to review and provide my opinion on the invalidity of
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`claims 1-3, 7, 10-11, and 14 of U.S. Patent No. 6,557,540. (Ex. 1001, “‘540
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`patent”). This declaration accompanies the petition for inter partes review no.
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`IPR2018-01061 (“Petition”).
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`2.
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`I am being compensated at an hourly consulting rate for time actually spent
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`reviewing materials and performing my analysis of the technical issues relevant to
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`this matter. My compensation is not contingent on the outcome of this proceeding
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`or the content of my opinions.
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`II. BACKGROUND
`3.
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`I have over 30 years of professional experience in the field of automotive
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`technologies and systems, including vehicle information systems and vehicle
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`safety and control systems. Further, I have authored numerous published technical
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`papers and am a named inventor on 11 U.S. and foreign patents.
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`4.
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`I received a Bachelor of Science degree in Electrical Engineering from
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`University of California, Irvine in 1977 and a Master of Science degree in
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`Electronic Engineering from Stanford University in 1982.
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`5.
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`From 1977 to 1979, I worked at Ford Aerospace where I designed, tested
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`and delivered microwave radar receiver systems.
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`From 1979 to 1983, I worked at Teledyne Microwave, where I developed
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`6.
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`high reliability microwave components and developed CAD tools.
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`7.
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`From 1983 to 1996, I worked at TRW, Inc., having held various positions.
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`From 1983 to 1985, I was a Member of the technical staff and a Department
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`Manager in the Space Electronics sector. Between 1985 and 1990 I was a project
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`manager working on various communications systems projects including the US
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`DoD Advanced Research Projects Administration (ARPA) MIMIC Program.
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`Between 1990 and 1993 I was the Manager of MMIC (monolithic-microwave-
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`integrated-circuit) Products Organization. In this role, I developed business
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`strategy and managed customer and R&D programs. During this time, I also
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`developed the first single chip 94 GHz Radar, used for automotive cruise control
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`and anti-collision systems. In 1993 I transferred to the TRW Automotive
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`Electronics Group, and managed about 30 engineers in the Systems Engineering
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`and Advanced Product Development organization. In this role, I managed
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`advanced development programs such as advanced automotive electronics sensors
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`and control systems, adaptive cruise control using millimeter wave radar, occupant
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`sensing, automatic crash notification systems, in-vehicle information systems, and
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`other emerging transportation products.
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`8. My work I at TRW included the development of various types of sensors for
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`vehicle systems, as well as control systems based on those sensors. For example, I
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`worked on an electronic power steering system that required the real-time feedback
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`controlled variation of the electrical drive signals to produce a motor drive signal
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`to provide steering boost while still providing a realistic steering wheel feel to the
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`driver. I also worked on various electronic systems that used feed-forward
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`techniques in order to improve transient response characteristics.
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`9.
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`In addition, my work in the auto industry in general has provided me with
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`the opportunity to develop and test a variety of vehicle control systems, including
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`sensing and responding to various gaseous mixtures, air fuel ratio controls based
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`on environmental sensors and exhaust sensors, and numerous other closed loop
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`control systems.
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`10.
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`I was employed as a Project General Manager in the Electronics Division of
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`Toyota Motor Corporation at Toyota headquarters in Toyota City, Japan from
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`April 1996 to around April 2000. In this position, I was responsible for leading the
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`development of vehicle telematics systems, infotainment systems, including on-
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`board and off-board navigation systems, traffic information systems, vehicle
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`communications systems, safety applications, and automated vehicle control
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`systems.
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`11.
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`I am currently a consultant for Cogenia Partners, LLC, focusing on systems
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`engineering, business development and technical strategy supporting automotive
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`and information technology. I have been in this position since 2001. In one of my
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`active engagements, I serve as the technical lead on a project funded by the
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`National Highway Traffic Safety Administration (NHTSA) to develop
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`requirements for connected vehicle safety systems in preparation for NHTSA
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`regulations governing such systems. I also serve as a technical consultant on
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`multiple projects sponsored by the Federal Highway Administration (FHWA)
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`related to connected vehicle technology research.
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`12.
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`In the various positions mentioned above, I was responsible for research and
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`development projects relating to numerous vehicle information systems, user
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`interface systems, sensory systems, control systems and safety systems, and also
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`had the opportunity to collaborate with numerous researchers and suppliers to the
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`auto industry. I therefore believe that I have a detailed understanding of the state of
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`the art during the relevant period, as well as a sound basis for opining how persons
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`of skill in the art at that time would understand the technical issues in this case.
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`13. A more complete summary of my experience, expertise, and publications is
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`set forth in my curriculum vitae (Ex. 1011).
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`III. SUMMARY OF MY OPINIONS
`14.
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`In my opinion, claims 1-3, 7, 10-11, and 14 (the “challenged claims”) of the
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`‘540 patent are invalid as obvious. My opinions are based on my expertise in the
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`technology of the ‘540 patent at the time the application was filed, as well as my
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`review of the ‘540 patent, its file history, and the prior art discussed in the Petition.
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`If the patent owner is allowed to submit additional evidence pertaining to the
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`validity of the ‘540 patent, I intend to review that as well and update my analysis
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`and conclusions as appropriate and allowed under the rules of this proceeding.
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`15.
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`I reviewed and contributed to the Petition’s explanation as to why the
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`challenged claims are unpatentable as obvious. The Petition’s explanation as to
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`why the challenged claims are unpatentable reflects my understanding, and I
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`incorporate it herein by reference.
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`IV. LEGAL PRINCIPLES
`16.
`
`I am not an attorney. I have been informed that it is a basic principle of
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`patent law that assessing the validity of a patent claim involves a two-step analysis.
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`In the first step, the claim language must be properly construed to determine its
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`scope and meaning. In the second step, the claim as properly construed, must be
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`compared to the alleged prior art to determine whether the claim is valid. I use the
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`principles below, however, as a guide in formulating my opinions.
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`A.
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`Person of Skill in the Art
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`17.
`
`I have been informed “A person of ordinary skill in the art” (“POSITA”) is a
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`hypothetical person who is presumed to have known the relevant art at the time of
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`the invention. Such a hypothetical person would have the capability of
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`understanding the scientific and engineering principles applicable to the pertinent
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`art of the claimed invention. Factors that may be considered in determining the
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`level of ordinary skill in the art include: (A) the type of problems encountered in
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`the art; (B) prior art solutions to those problems; (C) rapidity with which
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`innovations are made; (D) sophistication of the technology; and (E) educational
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`level of active workers in the field. Here, workers in the field of automotive
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`electronics would typically have a bachelor’s or master’s degree in electrical
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`engineering and several years of experience. Accordingly, it is my opinion that a
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`person of ordinary skill in the art here would have had a bachelor’s degree in
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`electrical engineering and at least 4-5 years of work experience in automotive
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`electrical or electronics systems design, or would have had a masters degree in
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`electrical engineering and at least 2 years of work experience in automotive
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`electrical or electronics systems design.
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`B. Claim Interpretation
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`18.
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`I have been informed that in an inter partes review, the words of a patent
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`must be given their broadest reasonable construction in light of the specification as
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`it would be interpreted by one of ordinary skill in the art. This meaning must be
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`ascertained from a reading of the patent documents, paying special attention to the
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`language of the claims, the written specifications, and the prosecution history. I
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`understand that an inventor may also attribute special meanings to some terms by
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`defining those terms or by otherwise incorporating such meanings in these
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`documents.
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`19. My methodology for determining the meaning of claim phrases was first to
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`carefully study the patent. In particular, I studied the claims themselves, followed
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`by a study of the background, detailed specification, figures, and other patent
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`content. Next, I reviewed the file histories looking for any clarifications or
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`limitations that might be attached to claim terms. In some circumstances, I looked
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`at other documents, such as references applied by the patent office.
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`C.
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`Priority Date
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`20.
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`I understand that the ‘540 patent application (Application No. 10/014,286)
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`was filed on December 11, 2001. Accordingly, my opinions reference December
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`11, 2001, as the relevant date for the claimed invention, although the main prior art
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`references I have relied upon pre-date December 11, 2001 by several years.
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`D.
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`Prior Art
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`21.
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`I have been informed that only information which satisfies one of the
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`categories of prior art set forth in 35 U.S.C. § 102 may be used in any invalidity
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`analysis under §§ 102 or 103. Therefore, if information is not properly classified as
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`prior art under one of the subsections of § 102 of the Patent Code, then it may not
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`be considered in an anticipation or obviousness determination. It is also my
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`understanding that, for inter partes review, applicable prior art is limited to patents
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`and printed publications.
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`E. Anticipation
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`22.
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`I have been informed that to anticipate a patent claim under 35 U.S.C. § 102,
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`a single asserted prior art reference must disclose each and every element of the
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`claimed invention, either explicitly or inherently, to a person of ordinary skill in
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`the art. I understand that a disclosure of an asserted prior art reference can be
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`“inherent” only if the missing element is necessarily present or is the inevitable
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`outcome of the process and/or thing that is explicitly described in the asserted prior
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`art reference.
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`F. Obviousness
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`23.
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`I have been informed that to find a patent claim invalid under 35 U.S.C. §
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`103 the petitioner must show that the differences between the claimed invention
`
`and the prior art would have been obvious, at the time the invention was made, to
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`“a person having ordinary skill in the art” to which the claimed invention pertains.
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`24.
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`I have been informed that obviousness may be shown by demonstrating that
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`it would have been obvious to modify what is taught in a single piece of prior art to
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`create the patented invention. Obviousness may also be shown by showing that it
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`would have been obvious to combine the teachings of more than one prior art
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`reference.
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`25.
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`I understand that in the Graham v. John Deere decision, the Supreme Court
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`outlined three issues that must be resolved in the obviousness determination: (1)
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`the level of ordinary skill in the pertinent art, (2) the scope and content of the prior
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`art, (3) differences between the prior art and the claims at issue. “Objective”
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`considerations, such as commercial success and praise of the alleged invention,
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`may also be considered in the obviousness analysis.
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`i.
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`Motivation to Combine
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`26.
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`I have been informed that in the KSR v. Teleflex decision, the Supreme
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`Court outlined a variety of factors to consider in determining whether a claimed
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`combination of components is obvious. These factors are set forth below for
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`reference.
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`KSR
`Factor No.
`1
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`2
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`3
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`4
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`5
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`KSR Factor Description
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`The identified prior art includes an express or inherent suggestion
`to modify or combine the reference in a way that renders the
`claimed invention obvious.
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`The combination of familiar elements of the asserted claims is
`obvious because it does no more than yield predictable results.
`
`The asserted patents simply arrange old elements with each
`performing the same function it had been known to perform and
`yields no more than one would expect from such an arrangement,
`the combination is obvious.
`
`Because the subject matter of the asserted patents is available in
`one field of endeavor, design incentives and other market forces
`can prompt variations of it, either in the same field or a different
`one, rendering the combination obvious.
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`Because the technique of the patents-in-suit has been used to
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`improve one device, a person of ordinary skill in the art would
`recognize that it would improve similar devices in the same way,
`and thus using the technique is obvious unless its actual
`application is beyond his or her skill.
`
`I may consider the interrelated teachings of multiple patents; the
`effects of demands known to the design community or present in
`the marketplace; and the background knowledge possessed by a
`person having ordinary skill in the art, all in order to determine
`whether there was an apparent reason to combine the known
`elements in the fashion claimed by the patents at issue.
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`Market demand has driven design trends to render the claimed
`invention of the patents-in-suit obvious.
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`The subject matter of the asserted patents extends to what is
`obvious, and is therefore invalid.
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`The claimed subject matter of the patents-in-suit is an obvious
`solution to a problem that was known at the time of invention.
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`The familiar items of the claims of the patents-in-suit have obvious
`uses beyond their primary purposes, and a person of ordinary skill
`will be able to fit the teachings of prior art references together like
`pieces of a puzzle to demonstrate that the asserted claims are
`obvious.
`
`The need and problem known in the field at the time of invention
`of the patent-in-suit, and addressed by the patent-in-suit, provides
`a reason for combining known prior art elements in the manner
`claimed in the patents-in-suit.
`
`There was a design need and/or market pressure to solve the
`problem addressed by the patents-in-suit. Because there was a
`finite number of identified, predictable solutions to the problem
`addressed in the patents-in-suit, a person of ordinary skill would
`have had good reason to pursue the known options within his or
`her technical grasp. Such a pursuit would have led to the
`anticipated success, making it likely that the product was not of
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`innovation but of ordinary skill and common sense. In that
`instance the fact that a combination was obvious to try might show
`that it was obvious.
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`
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`27.
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`I also have been informed that it is improper to rely on hindsight, that is, to
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`rely on the teachings of the patent claims, in order to merely show that the
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`elements of the claims can be found in various otherwise unrelated prior art
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`references. Instead, obviousness is found by considering whether a POSITA
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`would have had a reason to combine the prior art to achieve the claimed invention.
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`28.
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`I also understand that, for example, this reason may come from sources such
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`as explicit statements in the prior art, or from the knowledge of a person having
`
`ordinary skill in the art. Alternatively, any need or problem known in the field at
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`the time and addressed by the patent may provide a reason for combining elements
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`of the prior art. I also understand that when there is a design need or market
`
`pressure, and there are a finite number of predictable solutions, a person of
`
`ordinary skill may be motivated to apply both his skill and common sense in trying
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`to combine the known options in order to solve the problem.
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`29. Moreover, I understand that the obviousness inquiry requires a flexible
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`approach. I understand that the obviousness inquiry recognizes that a POSITA is
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`also a person of ordinary creativity (not an automaton), that familiar items may
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`have obvious uses beyond their primary purposes, and that, in many cases, a
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`POSITA will be able to fit the teachings of multiple patents together like pieces of
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`a puzzle.
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`ii.
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`Secondary Considerations
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`30.
`
`I understand that certain objective factors, sometimes known as "secondary
`
`considerations," may also be taken into account in determining whether a claimed
`
`invention would have been obvious or not. These considerations include:
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`(a) commercial success of a product due to the merits of the claimed
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`invention;
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`(b) a long-felt, but unsatisfied need for the invention;
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`(c) failure of others to find the solution provided by the claimed invention;
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`(d) deliberate copying of the invention by others;
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`(e) unexpected results achieved by the invention;
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`(f) praise of the invention by others skilled in the art;
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`(g) lack of independent simultaneous invention within a comparatively short
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`space of time;
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`(h) teaching away from the invention in the prior art.
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`31.
`
`I also understand that these objective indications are only relevant to
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`obviousness if there is a connection, or nexus, between them and the invention
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`covered by the patent claims.
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`V. DOCUMENTS RELIED UPON
`32.
`
`In this declaration, I rely on the following documents, which are hereby
`
`incorporated by reference.
`
`Exhibit Number
`
`Document
`
`Ex. 1001
`
`Ex. 1003
`
`Ex. 1004
`
`Ex. 1005
`
`U.S. Patent No. 6,557,540
`
`U.S. Patent No. 6,557,540 File History
`
`U.S. Patent No. 5,713,317 (“Yoshioka”)
`
`Torque Management of Engines with
`
`Variable Valve Timing, By Jankovic,
`
`Firschmuth, Stefanopoulou, and Cook
`
`(“Jankovic”), IEEE Control Systems in
`
`October, 1998
`
`Ex. 1006
`
`Bosch Fuel Injection Systems, by Forbes
`
`Aird, ©2001 Forbes Aird, published by the
`
`Berkeley Publishing Group,
`
`ISBN 1-55788-365-3
`
`Ex. 1007
`
`Bosch Fuel Injection & Engine
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`Management, by Charles O. Probst,
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`©1992, Robert Bentley, Inc.
`
`ISBN-978-0-8376-0300-1
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`Ex. 1008
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`Modeling and Control of Advanced
`Technology Engines by Anna
`Stefanopoulou, A dissertation submitted in
`partial fulfillment of the requirements for
`the degree of Doctor of Philosophy
`(Electrical Engineering: Systems) in The
`University of Michigan 1996
`
`Ex. 1009
`
`Automotive Encyclopedia, by William
`
`Toboldt and Larry Johnson, © 1979
`
`Goodheart-Wilcox Co. Inc.
`
`ISBN 0-87006-268-9
`
`Ex. 1010
`
`Bosch Automotive Handbook, © 2000
`
`Ex. 1011
`
`Ex. 1012
`
`Robert Bosch GmbH,
`
`ISBN 0-7680-0669-4
`
`CV of Scott Andrews
`
`Automotive Electronics Handbook, by
`
`Ronald Jurgen, © 1994, McGraw-Hill, Inc.
`
`ISBN0-07-033189-8
`
`Ex. 1013
`
`McGraw-Hill Electronics Dictionary, 6th
`
`ed. By Neil Sclater and John Markus ©
`
`1997 Mcgraw-Hill Inc.
`
`ISBN 0-07-057837-0
`
`Ex. 1014
`
`“The New Shorter Oxford English
`
`Dictionary,” Oxford University Press, vol.
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`1, 0-19-861271-0ISBN, 1993 (“Oxford
`
`Dictionary”)
`
`
`
`VI. OVERVIEW OF THE TECHNOLOGY
`
`
`A. Background of the Technology
`
`33.
`
`Internal combustion engines operate by mixing a combustible fuel such as
`
`gasoline or diesel oil with air, compressing this mixture and then either igniting it
`
`with an electrical spark (gasoline engines), or relying on the heat of compression to
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`ignite the mixture (diesel engines). The resulting exothermic expansion causes the
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`engine components (typically pistons) to move, thereby producing rotational power
`
`for whatever use the engine is intended. A 4-stroke engine is essentially a pump
`
`that draws air in, mixes it with fuel, and combusts the air-fuel mixture. That
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`combustion produces power that turns the engine, causing it to expel the burned
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`fuel and air (exhaust), and draw in air again, and the cycle continues. In the process,
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`depending on the engine, substantially more power is generated than is required to
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`maintain the intake / compression / ignition / exhaust cycle, and that power is then
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`used for other purposes, for example, powering an automobile.
`
`34.
`
` To control the engine speed (and thus output power), the intake of air has
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`long been controlled by a throttle valve. For example, in 1992, Probst described the
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`role of the throttle valve as follows:
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`The throttle valve regulates air flow into the engine. The more it
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`is open, the greater the air flow into the engine. The throttle
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`valves is located downstream from the mixture control unit,
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`usually mounted on the intake manifold, and is controlled by
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`the accelerator cable.
`
`(Ex. 1007 p. 79; Probst ch. 5 p. 11)
`
`
`
`And, in 1979, Toboldt and Johnson described the throttle valve as follows:
`
`One of the most important controls on a carburetor is the
`
`throttle valve, or valves. The throttle valve is a device for
`
`varying the amount of air –fuel mixture that enters the intake
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`manifold. This control is necessary so that the speed of the
`
`vehicle can be changed. The throttle valve, figure 21-5, is
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`simply a round disk mounted on a shaft, so that it can be tilted
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`at various angles in the carburetor throttle valve body. It is
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`connected by means of a suitable linkage to the accelerator
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`pedal in the driving compartment of the vehicle. Depressing the
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`pedal opens the throttle valve, permitting an increased amount
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`of air-fuel mixture to reach the manifold.
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`(Ex. 1009 p. 11; Automotive Encyclopedia p. 239)
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`35. An example throttle valve is illustrated in the figure below:
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`(Ex. 1009 p. 11, Automotive Encyclopedia p. 239)
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`36. There are three competing objectives with internal combustion engines: The
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`development of maximum power output with minimum fuel consumption, and
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`minimum exhaust byproducts (e.g. emissions). Key to meeting these goals is the
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`management of the ratio of fuel and air. Too much fuel (what is known as a “rich”
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`mixture) and the resulting exhaust will contain substantial unburned fuel, excessive
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`hydrocarbon emissions (HC), and poor fuel economy. Too little fuel, and the “lean”
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`mixture will cause the engine to run hot, misfire and generate substantial levels of
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`CO and NOx in the exhaust. Accordingly, a POSITA would have appreciated that
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`the efficiency of the combustion of the air fuel mixture in the cylinder(s) depends
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`heavily on the ratio of air and fuel. The so-called stoichiometric air-fuel ratio is the
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`ratio wherein all of the fuel in the mixture is combusted with all of the oxygen in
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`the cylinder. The stoichiometric ratio is typically considered to be 14.7:1 air to fuel.
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`To simplify computations this term is normalized using variable called “lambda”
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`(λ). Thus a lambda of 1.0 corresponds to an air fuel ratio of 14.7:1. This is also
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`indicated in the figure below (from Probst, 1992) which illustrates the relationship
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`between air fuel ratio, power and fuel consumption:
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`(Ex. 1007 p. 12, Probst ch. 2 p. 5)
`37. Of course, since the combustion is not ideal, as a POSITA would have
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`appreciated, there are a variety of byproducts, and these are known collectively
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`as ”emissions”.
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`38. For example, the primary emissions from the combustion process are oxides
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`of nitrogen (typically designated NOx), carbon monoxide (CO), and unburned
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`hydrocarbons (HC). As can be seen in the figure below, from 1992, the quantity of
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`these emissions varies as the air fuel ratio varies.
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`(Ex. 1007 p. 23, Probst ch. 2 p. 16)
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`39. The oxygen sensor, sometimes referred to as a “lambda sensor”, was
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`developed in order to measure the amount of oxygen in the exhaust, and therefore
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`how closely to a stoichiometric air fuel ratio the engine is operating. For example,
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`according to Aird, the lambda sensor is described as follows:
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`In construction,
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`the lambda sensor consists of a hollow
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`ceramic bulb, with both inner and outer surfaces covered with a
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`microthin layer of platinum. For protection, the outer surface is
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`surrounded by a shield. This bulb is inserted into the exhaust
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`system so that its exterior surface is washed by the exhaust gas
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`stream, while
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`its hollow interior
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`is exposed
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`to
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`the
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`atmosphere. In operation,
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`the
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`lambda sensor acts
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`like
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`an oxygen-powered battery: A difference in the oxygen level of
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`the gasses surrounding the two surfaces of the sensor causes it
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`to generate a small voltage.
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`(Ex. 1006 p. 22, Bosch Fuel Injection Systems p. 35)
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`40. Similarly, Probst in 1989 explained a lambda sensor:
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`IPR2018-01061
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`The lambda sensor is essentially a small battery that generates a
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`voltage signal based on the differential between the oxygen
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`content of the exhaust gas, and the oxygen content of the
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`ambient air.
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` A cutaway view of the lambda sensor is shown in Fig. 2-46.
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`The tip of the sensor that protrudes into the exhaust gas is
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`hollow, so that the interior of the tip can be exposed to the
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`ambient air. Both sides of the ceramic tip of the sensor are
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`covered with metal electrodes that react to create a voltage only
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`if the ambient air has a higher oxygen content than the exhaust
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`and the ceramic material is hotter than 575°F (300°C)[.]
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`When these conditions are met, voltage is generated between
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`the two sides of the tip. The voltage is usually about 1 volt. But
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`if the engine is running lean, the exhaust gas has about the same
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`amount of oxygen as the ambient air, so the lambda sensor will
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`generate little or no voltage; if the engine is running rich, the
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`oxygen content of the exhaust will be much lower than the
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`ambient air and the sensor voltage will be larger.
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`(Ex. 1007 at 47-48, Probst at ch. 3 pp. 21-22.)
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`Thus, a POSITA would have understood that the oxygen sensor output represents
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`the fuel conversion (e.g., rich vs. lean) of the engine.
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`41. One method long known and used to control emissions is known as exhaust
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`gas recirculation (EGR) wherein a small amount of the exhaust gas is re-introduced
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`into the intake. For example, from Probst in 1992:
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`Exhaust Gas Recirculation (EGR) is a technique for reducing
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`the formation of oxides of nitrogen (NOX). A small amount of
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`exhaust gas is rerouted back into the combustion chambers,
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`diluting the combustible mixture and lowering combustion
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`temperature. You'll remember
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`that excessive combustion
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`temperature is the cause of NOX formation.
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`(Ex. 1007 p. 24 Probst ch. 2 p. 17)
`42. A POSITA would also appreciate that one way to implement EGR is to
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`physically sample the exhaust gas and introduce it back into the intake using a
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`pressure controlled valve. One drawback of this approach is that the exhaust gasses
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`are very hot, and corrosive, and the EGR valves were consequently somewhat
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`unreliable. An alternative solution is to control the valve timing so that the exhaust
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`valve remains open briefly during the intake stroke. This causes a small amount of
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`the exhaust gas in the exhaust manifold (just pumped out of the cylinder by the
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`piston) to be drawn back into the cylinder. For example, from Stefanopoulou in
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`1996:
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`Exhaust gas recirculation (EGR) was introduce