throbber
Petitioner’s Demonstrative Exhibits
`
`Motherson Innovations Co., Ltd.,
`v.
`Magna Mirrors of America, Inc.
`
`IPR2020-00777
`U.S. Patent No. 10,261,648
`July 13, 2021
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`

`

`Instituted Grounds
`
`Ground
`1(a)
`1(b)
`1(c)
`1(d)
`2(a)
`2(b)
`
`35 U.S.C. §
`103
`103
`103
`103
`103
`103
`
`Reference(s)
`
`Lupo
`Lupo, McCabe
`Lupo, Tsuyama
`Lupo, McCabe, Tsuyama
`Tsuyama
`Tsuyama, McCabe
`
`Challenged Claims
`1, 3, 5-13, 15
`2, 16-17, 19-36
`4
`18
`1, 5, 8-9, 12, 15
`2, 16, 19-20, 24-27, 31, 33, 36
`Paper 1 at 5; Paper 7 at 45.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`

`

`Petitioner:
`“Peripheral exterior surface portion”
`is not required by all embodiments
`
`Exterior Mirror Reflective Element Fixedly
`Attached At Said Mirror Head
`1. An exterior rearview mirror
`assembly configured for mounting at
`an exterior portion of a vehicle, said
`exterior rearview mirror assembly
`comprising:
`a mirror head;
`an exterior mirror reflective element
`fixedly attached at said mirror head;
`an attachment portion configured for
`attachment at an exterior portion of a
`vehicle equipped with said exterior
`rearview mirror assembly . . .
`
`Patent Owner:
`“Exterior mirror reflective element
`fixedly attached to a peripheral
`exterior surface portion of said
`mirror head”
`
`Paper 9 at 11; Paper 13 at 2-4.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 at 76:38-46; Paper 13 at 2-4.
`
`4
`
`

`

`Exterior Mirror Reflective Element Fixedly
`Attached At Said Mirror Head
`
`Ex. 1001 at 71:35-72:14; Paper 13 at 2-4.
`
`Ex. 1001 at 58:49-52; Paper 13 at 2-4.
`
`Ex. 1001 at 36:23-67, Fig. 40; Paper 13 at 2-4.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`

`

`Mirrors Fixedly Attached To The
`Mirror Head Are Not New
`Lupo (1991)
`Tsuyama (2001)
`
`Ex. 1003, Fig. 1; Paper 1 at 20.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1005, Fig. 5;
`Paper 1 at 50-52.
`
`6
`
`

`

`Mirrors Fixedly Attached To The
`Mirror Head Are Not New
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Ex. 1005, Figs. 1, 5; Paper 1 at 50-52;
`Paper 13 at 29.
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror
`Reflective Element Is Fixedly Attached
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`

`

`The Mirror Head Must Comprise A Bracket To Which Said
`Exterior Mirror Reflective Element Is Fixedly Attached
`
`Figure 56 is the
`preferred embodiment.
`
`Petitioner:
`Fixedly attached does not require
`direct attachment
`
`Patent Owner:
`“A bracket that is directly
`attached to said exterior mirror
`reflective element.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Paper 1 at 5-6; Paper 9 at 11; Ex. 1001, Fig. 56; Paper 13 at 4-6.
`
`

`

`The Mirror Head Must Comprise A Bracket To Which Said
`Exterior Mirror Reflective Element Is Fixedly Attached
`
`Figures 68-68D are missing
`elements and do not show
`direct attachment.
`
`Ex. 1020 Nranian Tr. at 98:18-23; Paper 13 at 8-11.
`
`Ex. 1001, Figs 68-68A; Paper 13 at 8-11.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`

`

`Lupo And Uken Both Include “A Mirror Head Comprising A Bracket”
`That Attaches The Mirror Head To The Rest Of The Assembly
`
`Ex. 1001, Fig. 56; Paper 13 at 4-6.
`
`Ex. 1003, Fig. 1; Paper 1 at 19-20; Paper 13 at 4-6.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`

`

`Lupo And Uken Both Include “A Mirror Head Comprising A Bracket”
`That Attaches The Mirror Head To The Rest Of The Assembly
`
`Paper 6 at 17-18; Paper 9 at 15-17.
`
`Ex. 1003, Fig. 1; Paper 1 at 19-20; Paper 13 at 4-6.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`Rounded Front Perimeter Edge
`Yaw And Roll
`
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`

`

`Rounded Edges Are Not Defined To 2.5 mm
`
`Interior Mirror Embodiment
`
`Ex. 1001 at 9:38-47; Paper 13 at 11-12.
`
`Exterior Mirror Embodiment
`
`Ex. 1001 at 58:65-59:4; Paper 13 at 11-12.
`
`“Optionally . . . may be incorporated”
`
`Ex. 1001 at 58:49-52; Paper 13 at 2; 11-13.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`

`

`Rounding Edges Was A Well-Known
`Manufacturing Process
`McCabe
`
`Ex. 1004 at 46:29-33, 59:3-8; Paper 1 at 34; Paper 13 at 24.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`

`

`Mirrors With Electro-optic and Electrochromic
`Reflective Elements Are Not New
`McCabe
`Uken
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Ex. 1004, Fig. 37; Ex. 1001, Fig 72; Paper 1 at 35-38; Paper 13 at 24-25.
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`Yaw And Roll
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`

`

`Yaw And Roll Adjustment Of Said Exterior Mirror Reflective
`Element Relative To The Exterior Portion Of The Equipped Vehicle
`
`Roll
`
`“first actuator . . . pivot[s] . . . mirror head
`housing . . . about the first pivot axis [] to
`laterally adjust the rearward field of view”
`Yaw
`
`“second actuator . . . rotate[s] or pivot[s] outer
`bracket 620 relative to the side of the vehicle . . .
`about the second pivot axis [] to vertically adjust
`the rearward field of view for the driver”
`
`Ex. 1001 at 59:26-32, Fig. 57; Paper 13 at 14-15.
`
`Ex. 1001 at 59:32-37, Fig. 58A; Paper 13 at 14.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`

`

`Yaw And Roll Adjustment Of Said Exterior Mirror Reflective
`Element Relative To The Exterior Portion Of The Equipped Vehicle
`
`Roll
`
`“. . . the arm may be rotated about its
`longitudinal axis to further adjust the
`arm and the attachment element and the
`reflective element relative to the side of
`the vehicle (thus providing independent
`and/or cooperative pitch, yaw and roll
`adjustment of the reflective element
`relative to the side of the vehicle).”
`
`Ex. 1001 at 68:43-50; Paper 13 at 15-16.
`
`Ex. 1001, Fig. 68; Paper 13 at 16.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`

`

`Lupo Rolls About Axis B
`And Yaws About Axis A
`
`Roll
`
`Ex. 1003, Fig. 2; Paper 1 at 26-27; Paper 13 at 21-22.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Yaw
`
`20
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`Cooperatively Operable Actuators
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`

`

`Lupo’s Motors Are Cooperatively Operable
`
`Lupo
`
`* * *
`
`* * *
`
`Ex. 1003 at 9-11, Fig. 4; Paper 1 at 29-31; Paper 13 at 22-23; Ex. 1002 ¶¶ 128-132.
`
`22
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`
`Cooperatively Operable Actuators
`Support Structure Adjustable About Multiple Degrees Of Freedom
`Fixedly Attached By Use Of An Adhesive
`
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`

`

`Support Structure Adjustable About
`Multiple Degrees of Freedom
`
`Second Movable
`Support (51)
`
`Ex. 1003, Fig. 3; Paper 1 at 21.
`
`Ex. 1003, Fig. 2; Paper 1 at 20-25; Paper 13 at 19-21.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`Fixedly Attached By Use Of An Adhesive
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`

`

`Fixedly Attached By Use Of An Adhesive
`
`Tape Addition
`
`Hook 31, Ribs 32,
`and Tape 20
`
`Ex. 1003, Fig. 1; Paper 1 at 46-48; Paper 9 at 26-27.
`
`Ex. 1005, Fig. 5; Paper 1 at 46-48; Paper 9 at 26-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`

`

`Fixedly Attached By Use Of An Adhesive
`
`Tape Addition
`
`Ex. 1003, Fig. 1; Paper 1 at 46-48; Paper 9 at 26-27.
`
`Ex. 1001 at Fig. 56; Paper 13 at 5.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`

`

`Unpatentability
`
`Exterior Mirror Reflective Element Fixedly Attached At Said Mirror Head
`
`Mirror Head Comprises A Bracket To Which Said Exterior Mirror Reflective Element Is
`Fixedly Attached
`
`Rounded Front Perimeter Edge
`
`Yaw And Roll
`
`Cooperatively Operable Actuators
`
`Support Structure Adjustable About Multiple Degrees Of Freedom
`
`Fixedly Attached By Use Of An Adhesive
`Tsuyama Renders Obvious An Exterior Rearview Mirror Assembly
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`

`

`Tsuyama’s Mirror Assembly Can Be
`Implemented As An Exterior Rearview Mirror
`
`Ex. 1005 at 12:4-10; Paper 13 at 29-30.
`
`Ex. 1005 at 1:18-34; Paper 1 at 49, 57-58; Paper 13 at 27-30;
`Ex. 1002 at ¶¶ 222-224; Ex. 1002 at ¶¶ 239-241.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`

`

`Tsuyama’s Motors Are Cooperatively Operable
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`Ex. 1005 at 11:14-37, Figs. 2, 15; Paper 1 at 59-60, 64-65; Ex. 1002 ¶¶ 251-254.
`
`

`

`CERTIFICATE OF SERVICE
`Under 37 C.F.R. § 42.6, I hereby certify that on July 1, 2021, I served a copy
`
`of the foregoing document on counsel of record by delivering a copy via e-mail to the
`
`addresses listed below:
`
`
`
`Dennis J. Abdelnour: dabdelnour@honigman.com
`
`Timothy A. Flory: tflory@honigman.com
`
`David J. Thomas: dthomas@honigman.com
`
`Counsel for Patent Owner, Magna Mirrors of America, Inc.
`
`
`
`
`
`Date: July 6, 2021
`
`
`
`
`
`
`
`
`
`By: /s/ Kenneth S. Luchesi
`Kenneth S. Luchesi
`Reg. No. 58,673
`JONES DAY
`901 Lakeside Ave.
`Cleveland, OH 44114
`Telephone: (216) 586-7059
`Facsimile: (216) 579-0212
`Email: kluchesi@jonesday.com
`Counsel for Petitioner
`
`

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