Motherson Innovations Co., Ltd. v. Magna Mirrors of America, Inc.
`IPR 2020-00777, U.S. Patent No. 10,261,648
`
`July 13, 2021
`
`Dennis J. Abdelnour, Honigman LLP
`on behalf of Patent Owner Magna Mirrors of America, Inc.
`
`1
`
`Demonstrative Exhibit, Not Evidence
`
`
`IPR 2020-00777, U.S. Patent No. 10,261,648
`
`July 13, 2021
`
`Dennis J. Abdelnour, Honigman LLP
`on behalf of Patent Owner Magna Mirrors of America, Inc.
`
`1
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Agenda
`
`1. Bracket
`
`2. Yaw, Pitch and Roll
`
`3. Exterior Mirror Reflective Element
`Fixedly Attached At Said Mirror Head
`
`4. Rounded
`
`5. Cooperatively Operable Actuators
`
`6. Tsuyama Obviousness
`
`13 July 2021
`
`2
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`‘648 Patent, Claims 3, 4 and 6
`
`3. The exterior rearview mirror
`assembly of claim 1, wherein
`said mirror head comprises a
`bracket to which said exterior
`mirror reflective element is fixedly
`attached.
`
`4. The exterior rearview mirror
`assembly of claim 1, wherein
`said mirror head comprises a
`bracket to which said exterior
`mirror reflective element is
`fixedly attached by use of an
`adhesive.
`
`6. The exterior rearview mirror
`assembly of claim 5, wherein said
`mirror head comprises a bracket
`to which said exterior mirror
`reflective element is fixedly
`attached, and wherein said one
`end of said support structure
`attaches at said bracket.
`
`13 July 2021
`
`3
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Motherson Identifies Lupo’s Projections 53 As The Claimed “Bracket”
`
`13 July 2021
`
`4
`
`Petitioner Reply
`(Paper No. 13) at 19.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Petitioner’s “Bracket” Does Not Meet Express Claim Requirements
`
`3. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached.
`
`4. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached by use of
`an adhesive.
`
`13 July 2021
`
`5
`
`Demonstrative Exhibit, Not Evidence
`
`Petitioner Reply (Paper No. 13) at 19.
`
`
`
`Petitioner’s “Bracket” Does Not Meet Express Claim Requirements
`
`3. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached.
`
`4. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached by use of
`an adhesive.
`
`13 July 2021
`
`6
`
`Demonstrative Exhibit, Not Evidence
`
`Petitioner Reply (Paper No. 13) at 27;
`see also Petition at 47.
`
`
`
`Petitioner Identified The “Bracket” In Lupo Strategically
`
`6. The exterior rearview mirror
`assembly of claim 5, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached, and
`wherein said one end of said support
`structure attaches at said bracket.
`
`13 July 2021
`
`7
`
`Demonstrative Exhibit, Not Evidence
`
`Petitioner Reply (Paper No. 13) at 27.
`
`
`
`Motherson Tries To Overcome The Deficiency By
`Misconstruing “Fixedly Attached” In Isolation
`
`13 July 2021
`
`8
`
`Petition (Paper No. 1) at 20.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`The ‘648 Claims And Specification Requires Direct
`Attachment Of The Mirror Reflective Element To The Bracket
`
`3. The exterior rearview mirror assembly
`of claim 1, wherein said mirror head
`comprises a bracket to which said exterior
`mirror reflective element is fixedly
`attached.
`
`4. The exterior rearview mirror assembly
`of claim 1, wherein said mirror head
`comprises a bracket to which said exterior
`mirror reflective element is fixedly
`attached by use of an adhesive.
`
`6. The exterior rearview mirror assembly of
`claim 5, wherein said mirror head
`comprises a bracket to which said exterior
`mirror reflective element is fixedly
`attached, and wherein said one end of
`said support structure attaches at said
`bracket.
`
`13 July 2021
`
`9
`
`“mirror reflective
`element”
`
`“support arm or
`structure”
`
`“bracket”
`
`Ex. 1001, Fig. 68.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`The ‘648 Patent Requires Direct Attachment Of
`The Mirror Reflective Element To The Bracket
`
`“The mirror reflective element can be adhered
`or otherwise fixedly attached at a surface or
`mounting portion of the mirror head, and the
`mirror head can be any shape (such as
`generally flat or having a narrow or thin profile
`or the like) depending on the particular
`application of the mirror assembly and the
`vehicle manufacturer's design preferences.”
`
`Ex. 1001 at 71:53—58.
`
`13 July 2021
`
`10
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`The ‘648 Patent Requires Direct Attachment Of
`The Mirror Reflective Element To The Bracket
`
`3. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached.
`
`4. The exterior rearview mirror
`assembly of claim 1, wherein said
`mirror head comprises a bracket to
`which said exterior mirror reflective
`element is fixedly attached by use of
`an adhesive.
`
`13 July 2021
`
`11
`
`Ex. 1001, Fig. 56.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Motherson’s Construction Relies Solely On Extrinsic Evidence
`
`13 July 2021
`
`12
`
`Petition (Paper No. 1) at 5-6.
`
`Ex. 1002 ¶ 49.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`The Testimony Of Magna’s Expert Is The
`Only One Based On The Intrinsic Record
`
`91. …one of skill in the art would understand the phrase ‘a bracket to
`which said exterior mirror reflective element is fixedly attached’ to mean ‘a
`bracket that is directly attached to said exterior mirror reflective element.’
`The understanding is the plain meaning of the term when read in context of
`the entire claim and the specification.
`
`94. A person of ordinary skill in the art reading the ’648 Patent would
`understand that the claims reciting a “bracket to which said exterior mirror
`reflective element is fixedly attached” read specifically on the embodiment,
`for example, of at least Figure 68. …
`
`Ex. 2001, ¶¶ 91, 93.
`
`13 July 2021
`
`13
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Motherson’s Own Exhibits Support Magna
`
`13 July 2021
`
`14
`
`Ex. 1011 at 1.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`The Board Agreed, But Motherson Offered
`No Further Supporting Evidence
`
`13 July 2021
`
`15
`
`Institution Decision
`(Paper No. 7) at 22.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Agenda
`
`1. Bracket
`
`2. Yaw, Pitch and Roll
`
`3. Exterior Mirror Reflective Element
`Fixedly Attached At Said Mirror Head
`
`4. Rounded
`
`5. Cooperatively Operable Actuators
`
`6. Tsuyama Obviousness
`
`13 July 2021
`
`16
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`‘648 Patent, Claim 9
`
`9. The exterior rearview mirror assembly of claim 1,
`wherein said multi-axis adjustment mechanism is
`operable for yaw and roll adjustment of said
`exterior mirror reflective element relative to the
`exterior portion of the equipped vehicle at which
`said exterior rearview mirror assembly is attached.
`
`13 July 2021
`
`17
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Standard Yaw, Pitch, and Roll Coordinate System
`
`Patent Owner’s Evidence:
`
`Petitioner’s Evidence:
`
`13 July 2021
`
`18
`
`Demonstrative Exhibit, Not Evidence
`
`Ex. 2005 at 3.
`
`Ex. 1009.
`
`
`
`Lupo Does Not Disclose “Roll Adjustment”
`
`PITCH
`
`YAW
`
`Ex. 2005 at 3, annotated.
`
`Lupo Ex. 1003, Figure 2, annotated.
`
`13 July 2021
`
`19
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Motherson’s Original Construction Surreptitiously
`Sought To Reorient The Standard Coordinate System
`
`Petitioner’s Original Construction
`
`roll: “a rotation about a main axis”
`
`yaw: “a rotation about a vertical
`axis perpendicular to the main
`axis”
`
`Paper No. 1 (Petition) at 6.
`
`13 July 2021
`
`20
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Motherson Concedes The ‘648 Patent Does
`Not Re-Define The Standard Coordinate System
`
`Petition (Paper No. 1) at 6.
`
`Ex. 1002 at ¶ 50.
`
`13 July 2021
`
`21
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Board Agreed With Patent Owner And Invited Further Record Evidence
`
`Inst. Dec. at 15.
`
`13 July 2021
`
`22
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`Claim 9 Shifts The Coordinate System…
`
`9. The exterior rearview mirror
`assembly of claim 1, wherein said
`multi-axis adjustment mechanism is
`operable for yaw and roll adjustment
`of said exterior mirror reflective
`element relative to the exterior
`portion of the equipped vehicle at
`which said exterior rearview mirror
`assembly is attached.
`
`13 July 2021
`
`23
`
`Ex. 2010, ¶ 9.
`
`Demonstrative Exhibit, Not Evidence
`
`
`
`…But Does Not Reorient It
`
`Patent Owner’s Expert Nranian:
`
`“…the frame of reference set forth in
`the claims does not change the
`ordinary direction of the pitch, yaw,
`and roll coordinates known to one of
`skill in the art. … it shifts that
`coordinate system from the center of
`the vehicle (the vehicle as whole), to
`the side of the vehicle (the exterior
`portion of the equipped vehicle at
`which said exterior rearview mirror
`assembly is attached).”
`
`Ex. 2010, ¶ 9; see also id. ¶¶ 7-14.
`
`13 July 2021
`
`24
`
`Ex. 2010, ¶ 9.
`
`Demonstrative Exhibit, Not Evidence
`
`
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