UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`TOYOTA MOTOR CORPORATION,
`Petitioner
`
`v.
`
`GENERAL ELECTRIC CO.,
`Patent Owner
`_________________________
`
`Case IPR2019-00011
`Patent No. 7,723,932
`_________________________
`
`DECLARATION OF MAHDI SHAHBAKHTI, PH.D.
`REGARDING U.S. PATENT NO. 7,723,932
`
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`TOYOTA EXHIBIT 1002
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`

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`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`VI.
`
`Contents
`Introduction......................................................................................................6
`
`Background and Qualifications .......................................................................7
`
`Legal Standards .............................................................................................11
`
`The
`
`A.
`
`B.
`
`.................................................................13
`
`...................................................................................13
`
`Claim Construction..............................................................................18
`
`1.
`
`2.
`
`..................................................................................18
`
`...................................................................19
`
`A Person of Ordinary Skill in the Art............................................................20
`
`......................................................................................21
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`The Kira Reference .............................................................................21
`
`The Yamada Reference .......................................................................22
`
`The Kumar Reference .........................................................................24
`
`The Hanyu Reference..........................................................................25
`
`The Masahiko Reference.....................................................................27
`
`The Katsuta Reference ........................................................................29
`
`The Suzuki Reference ..........................................................................29
`
`VII. Anticipation of Claims 1, 2, 23, 24, and 30 Based on Kira ..........................30
`
`A.
`
`Kira Anticipates Claims 1, 2, 23, 24, and 30 ......................................30
`
`1.
`
`2.
`
`3.
`
`Independent Claim 1 .................................................................30
`
`Dependent Claim 2....................................................................35
`
`Dependent Claim 23 .................................................................37
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`4.
`
`5.
`
`Independent Claim 24 ...............................................................38
`
`Dependent Claim 30 .................................................................40
`
`VIII. Obviousness of Claim 3 Based on Kira ........................................................42
`
`1.
`
`Dependent Claim 3....................................................................42
`
`IX. Obviousness of Claims 4 and 18-21 Based on Kira and Kumar...................45
`
`A.
`
`B.
`
`Rationale to Combine Kira and Kumar ..............................................45
`
`Kira in view of Kumar Renders Obvious Claim 4..............................48
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Dependent Claim 4....................................................................48
`
`Dependent Claim 18 .................................................................49
`
`Dependent Claim 19 .................................................................51
`
`Dependent Claim 20 .................................................................52
`
`Dependent Claim 21 .................................................................53
`
`X.
`
`Obviousness of Claims 5, 14, 15, 17, and 22 Based on Kira in view of
`Hanyu.............................................................................................................55
`
`A.
`
`B.
`
`Rationale to Combine Kira and Hanyu...............................................56
`
`Kira in view of Hanyu Renders Obvious Claim 5, 14, 15, 17,
`and 22 ..................................................................................................57
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Dependent Claim 5....................................................................57
`
`Dependent Claim 14 .................................................................59
`
`Dependent Claim 15 .................................................................60
`
`Dependent Claim 17 .................................................................61
`
`Dependent Claim 22 .................................................................62
`
`XI. Obviousness of Claims 6-12 Based on Kira in view of Masahiko ...............63
`
`A.
`
`Rationale to Combine Kira and Masahiko..........................................63
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`B.
`
`Kira in view of Masahiko Renders Obvious Claims 6-12..................65
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`Dependent Claim 6....................................................................65
`
`Dependent Claim 7....................................................................66
`
`Dependent Claim 8....................................................................67
`
`Dependent Claim 9....................................................................69
`
`Dependent Claim 10 .................................................................70
`
`Dependent Claim 11 .................................................................71
`
`Dependent Claim 12 .................................................................73
`
`XII. Anticipation of Claims 24, 25, 30, 32, and 35 Based on Yamada.................74
`
`A.
`
`Yamada Anticipates Claims 24, 25, 30, 32, and 35 ............................74
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Independent Claim 24 ...............................................................74
`
`Dependent Claim 25 .................................................................79
`
`Dependent Claim 30 .................................................................80
`
`Independent Claim 32 ...............................................................81
`
`Dependent Claim 35 .................................................................85
`
`XIII. Obviousness of Claim 34 Based on Yamada.................................................86
`
`1.
`
`Dependent Claim 34 .................................................................86
`
`XIV. Obviousness of Claim 26 Based on Yamada in view of Katsuta..................88
`
`A.
`
`B.
`
`Rationale to Combine Yamada and Katsuta .......................................88
`
`Yamada in view of Katsuta Renders Obvious Claim 26 ....................89
`
`1.
`
`Dependent Claim 26 .................................................................89
`
`XV. Obviousness of Claims 27 and 28 Based on Yamada in view of Suzuki ......90
`
`A.
`
`Rationale to Combine Yamada and Suzuki .........................................90
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`B.
`
`Yamada in view of Suzuki Renders Obvious Claims 27 and 28 .........91
`
`1.
`
`2.
`
`Dependent Claim 27 .................................................................91
`
`Dependent Claim 28 .................................................................92
`
`XVI. Obviousness of Claims 29 and 31 Based on Yamada in view of Hanyu ......93
`
`A.
`
`B.
`
`Rationale to Combine Yamada and Hanyu .........................................93
`
`Yamada in view of Hanyu Renders Obvious Claims 29 and 31.........95
`
`1.
`
`2.
`
`Dependent Claim 29 .................................................................95
`
`Dependent Claim 31 .................................................................97
`
`XVII. Conclusion .....................................................................................................98
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`I.
`
`Introduction
`1.
`Toyota Motor Corporation, through its attorneys, has asked me,
`
`Mahdi Shahbakhti, Ph.D., to provide technical opinions regarding U.S. Patent No.
`
`7,723,932, its claims, and prior art references relating to propulsion systems for
`
`hybrid vehicles. For the reasons summarized in this declaration, it is my opinion
`
`the Kira and Yamada references (U.S. Patent Pub. No. 2004/0069548 and Japanese
`
`Patent Pub. 2004-260904, respectively), either alone or in combination with other
`
`prior art, disclose or render obvious
`
`932
`
`2.
`
`I am providing the requested opinions and making this declaration in
`
`support of a petition for inter partes review of
`
`932 patent. I have no stake in
`
`the outcome of the inter partes review.
`
`3.
`
`932
`
`patent, reviewing the materials mentioned in this declaration, and forming my
`
`technical opinions. My compensation does not depend, in any way, on the
`
`opinions I reach or the outcome of the inter partes review proceeding.
`
`4.
`
`All statements made herein of my own knowledge are true, and all
`
`statements made herein based on information and belief are believed to be true. I
`
`understand that willfully making any false, fictitious, or fraudulent statement or
`
`representation in this proceeding may be punishable by fine or imprisonment, or
`
`both, under Section 1001 of Title 18 of the United States Code.
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`II.
`
`Background and Qualifications
`5.
`I am an Associate Professor of Mechanical Engineering and an
`
`Affiliated Associate Professor of Electrical and Computer Engineering at Michigan
`
`Technological University.
`
`6.
`
`Before joining Michigan Technological University in August of 2012,
`
`I spent two years as a post-doctoral scholar at the Mechanical Engineering
`
`Department at the University of California, Berkeley. My post-doctorate work
`
`focused on developing control systems for automotive applications, including
`
`powertrains and others.
`
`7.
`
`I earned a Ph.D. in Mechanical Engineering from the University of
`
`Alberta in 2009 and a Masters degree from KNT University of Technology in
`
`2003. My research activities in the past 18 years have centered on propulsion
`
`systems, energy systems, and related control systems for automotive applications.
`
`8.
`
`I also have direct industry experience. From 2001 to 2004, I worked
`
`as a researcher it the automotive industry. During this time, I was involved in
`
`research and development work on powertrain management systems for gasoline
`
`and natural gas vehicles. In the past eight years, I have performed controls-related
`
`research sponsored by various automotive companies such as Ford Motor
`
`Company, Toyota Motor Corporation, General Motors Corporation, Hitachi, and
`
`Denso.
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`9.
`
`I have experience with hybrid and electric vehicles, including research
`
`projects relating to the Chevy Volt, a plug-in hybrid electric passenger car sold by
`
`General Motors. I reg
`
`10.
`
`I teach courses in the area of Thermodynamics, and Energy-Thermal-
`
`Fluids. These courses explain the fundamentals of energy flows in engineering
`
`systems including HVAC, internal combustion engines, heat pumps, hybrid
`
`electric vehicles, and energy conversion systems.
`
`11.
`
`I have supervised/mentored 104 graduate and undergraduate students,
`
`including 21 PhD, 56 MS and 27 BS students in Mechanical Engineering and
`
`Electrical Engineering Departments in three academic institutions during 2010-
`
`2018. These mentorships have been in the area of modeling, experimental studies
`
`(including instrumentation), and control of automotive, heating, ventilation, and
`
`air-conditioning (HVAC), and energy systems.
`
`12. My current research activity at Michigan Tech focuses on increasing
`
`efficiency of energy systems through utilization of advanced control techniques,
`
`focusing on the transportation and building sectors. Past academic and industrial
`
`research experience includes system identification, physical modeling and control
`
`of dynamic systems including combustion engines, vehicle emission aftertreatment
`
`systems, hybrid electric vehicles, and HVAC systems.
`
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`13.
`
`I am Associate Editor (2014- ), Guest editor (2017) for International
`
`Journal of Powertrains (Inderscience), and also Associate editor (2017- ) for
`
`ASME Journal of Dynamic Systems, Measurement, and Controls.
`
`14.
`
`I have served on the US Department of Energy (DOE), and United
`
`ndation (NSF) review panels in the areas of energy
`
`systems, and controls in the past five years. I have also been reviewer for (i)
`
`international grant proposals from funding agencies from Croatia, France,
`
`Germany, and Netherlands, (ii) US Academy of Engineering for the Research
`
`Program of the US DRIVE Partnership, (iii) 24 international journals mostly in the
`
`area of controls and energy systems, (iv) Springer International Publishing for
`
`books in the area of automotive controls and propulsion systems.
`
`15.
`
`I am an active member of ASME Dynamic Systems & Control
`
`Division (DSCD), serving as the chair of the Energy Systems (ES) technical
`
`committee (149 members) and secretary of the Automotive Transportation Systems
`
`(ATS) technical committee (156 members), chairing (27 sessions) and co-
`
`organizing sessions (> 60 sessions) in the areas of modeling, fault diagnosis, and
`
`control of automotive systems, and energy/HVAC systems in American Control
`
`Conference, SAE World Congress, and ASME Dynamic Systems Control
`
`Conferences.
`
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`16.
`
`I have won the following awards for my work relating to modeling
`
`and control of automotive systems:
`
`Society of Automotive Engineers (SAE) International Ralph R.
`
`engineering educator
`
`Best Paper Award, ASME Automotive and Transportation
`
`Systems Technical Committee ASME Dynamic Systems Control
`
`Conference, 2015.
`
`Best Paper Award, ASME Automotive and Transportation
`
`Systems Technical Committee ASME Dynamic Systems Control
`
`Conference, 2012.
`
`Best Presentation in the Session, American Control Conference
`
`(ACC), 2012, 2015, 2016.
`
`Best Presentation Award, SAE Int. Powertrain, Fuels &
`
`Lubricants Conference, Baltimore, MD, USA, 2016.
`
`Canada National Sciences and Engineering Research Council
`
`(NSERC) Postdoctoral Fellowship (for research in the area of automotive
`
`controls), 2010 - 2012.
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`Andrew Stewart Memorial Graduate Prize, University of
`
`Alberta, 2009.
`
`David Morris Graduate Scholarship in Automotive
`
`Engineering, University of Alberta, 2008.
`
`Lehigh Inland Cement Graduate Scholarship in Environmental
`
`Studies, University of Alberta, 2007.
`
`Winning Team (first prize) of a Total of 66 Research Teams
`
`from 26 Canadian Universities, Canada AUTO21 High Qualified Personnel
`
`Competition, Windsor, Canada, June 11-13, 2007.
`
`Chevron Graduate Scholarship in Natural Gas Engineering,
`
`University of Alberta, 2005.
`
`17. My curriculum vitae has been submitted as Exhibit 1003 to this
`
`proceeding. My publications relating to automotive controls and HVAC systems
`
`are found at http://pages.mtu.edu/~mahdish/Shahbakhti_Publications.html. This
`
`includes 143 peer-reviewed publications. These research publications have been
`
`recognized and cited over 1500 times from 45 different countries (Source: Google
`
`Scholar).
`
`III. Legal Standards
`
`18.
`
`It is my understanding that there are two ways that prior art references
`
`can render a patent claim unpatentable: anticipation and obviousness. Counsel has
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`informed me that the petitioner has the burden in an IPR to show unpatentability
`
`by a preponderance of the evidence.
`
`19.
`
`I also understand that there is a set process as follows: a) the claims of
`
`a patent are properly construed, b) then, you must compare the claim language to
`
`the prior art on a limitation-by-limitation basis. If the prior art reference contains
`
`all the elements of the claim language (explicitly or inherently), arranged as in the
`
`claims, then that is considered anticipation.
`
`20.
`
`I understand that an invention is obvious when the differences
`
`between the subject matter sought to be patented and the prior art are such that the
`
`subject matter as a whole would have been obvious at the time of the invention to a
`
`person having ordinary skill in the art. For this reason, I have been asked to
`
`consider the level of ordinary skill in the field that someone would have had at the
`
`time of the claimed invention.
`
`21. Counsel has also instructed me that in an obviousness determination
`
`the factors to consider are: (1) the scope and content of the prior art, (2) the
`
`differences between the prior art and the asserted claims, (3) the level of ordinary
`
`skill in the pertinent art, and (4) the existence of secondary considerations of
`
`nonobviousness. Secondary considerations include: a long felt need; commercial
`
`success; unexpected results; praise of the invention; licensing; copying; failure of
`
`others; and skepticism by experts.
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`22. Counsel has also instructed me that an obviousness inquiry may
`
`involve assessing the motivation of a person of ordinary skill to combine
`
`references. The prior art references themselves may provide a suggestion,
`
`motivation, or reason to combine, but other sources may also support a rationale
`
`for combining two or more prior art references.
`
`23.
`
`It is also my understanding through counsel that the combination of
`
`familiar elements according to known methods is likely to be obvious when it does
`
`no more than yield predictable results. It is further my understanding that a proper
`
`obviousness analysis focuses on what was known or obvious to a person of
`
`ordinary skill in the art, not just the patentee.
`
`24.
`
`I have been informed that, in this proceeding, claim terms in the 932
`
`patent must be given their broadest reasonable interpretation in light of the patent
`
`specification.
`
`IV. The 932 Patent and Claim Terms
`
`The
`
`A.
`
`25.
`
`-known propulsion
`
`patent discusses conventional hybrid propulsion systems in its Background section.
`
`(
`
`-64.) These conventional systems, which have been used for
`
`decades, are known to include an engine and a storage device connected to drive
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`motors for propelling a vehicle. (
`
`, 1:36-50.) The drive motors are also
`
`known to sometimes have regenerative braking capabilities in which energy is
`
`recovered during braking and transferred to the storage device. (
`
`, 1:10-
`
`56.) Based on my experience and familiarity with the art, these were very common
`
`features in hybrid vehicles in 2007.
`
`26.
`
`conventional components: (1) an engine 112, (2) an alternator/generator 114
`
`connected to engine 112, (3) a first drive motor 120 that receives energy from
`
`engine 112 for propelling the vehicle, (4) a first energy storage device 132, and (5)
`
`a second drive motor 136 that receives energy from first energy storage device 132
`
`for propelling the vehicle and supplies energy to first energy storage device 132
`
`during regenerative braking. (
`
`atent, 7:18-30, 7:48-51.) These features are
`
`highlighted in Figure 1 below:
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`(
`
`27.
`
`)
`
`first traction drive system 110 is electrically decoupled from a second traction
`
`drive system 130. (
`
`-34.) Figure 1 shows this embodiment below:
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`(
`
`28.
`
`)
`
`where a first traction drive system 210 is electrically coupled to a second traction
`
`drive system 230. (
`
`-31.) Figure 2 shows this embodiment below:
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`(
`
`).) Neither of these configurations are new.
`
`Further, the use of different voltages between the different traction drive systems,
`
`29.
`
`drive systems, which are functionally the same as the second traction drive system,
`
`may be added as well. (
`
`-45, 8:20-27.) In the same way as the
`
`second traction drive system, the prior art discloses these additional features as
`
`well.
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`B.
`
`Claim Construction
`
`1.
`
`30.
`
`It is my opinion that the broadest reasonable interpretation of
`
`oupled is
`
`interpretation, which is
`
`2
`
`patent.
`
`31.
`
`-board heat engine coupled to an
`
`alternator that converts the mechanical output power of the engine into an
`
`(
`
`-46.)
`
`to a diesel engine 112 via an alterna
`
`(
`
`, 7:20-21.) The
`
`connections. (
`
`, 2:28-30, 2:36-37, claim 1.)
`
`refers to connections that are either mechanical or electrical.
`
`32.
`
`support this interpretation. Merriam-
`
`defines
`
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`English Dictionary
`
`connect (one thing) to (another). (Ex-1021 at 385-86.) These dictionary definitions
`
`(Ex-1020, 286.) Collins
`
`confirm the meaning
`
`33.
`
`in the
`
`to mean
`
`2.
`
`34.
`
`I have been informed that this term should be construed to cover the
`
`corresponding structure described in the specification and equivalents thereof. The
`
`storage device and for
`
`be one propulsion means for supplying energy to a first energy storage device and
`
`(
`
`-47.)
`
`In addition,
`
`supply energy to the first energy storage device and to receive energy from the first
`
`he only corresponding structure described in
`
`patent that is capable of performing the function of both supplying energy to and
`
`receiving energy from an energy storage device are electric drive motors 136, 146,
`
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`236, 246, 336, and 346. It is my opinion that the
`
`in this
`
`patent should therefore be construed to be one of the electric drive motors 136,
`
`146, 236, 246, 336, and 346.
`
`V.
`
`A Person of Ordinary Skill in the Art
`
`35.
`
`I have been asked to consider the qualifications and knowledge of a
`
`person having ordinary skill in the art in May 2007, when
`
`932 patent was
`
`filed.
`
`36. A person of ordinary skill in the art in May 2007 would have at least a
`
`electrical engineering and 2 years work
`
`experience with hybrid vehicle propulsion systems or equivalent graduate study.
`
`37.
`
`This skilled artisan would have taken classes or had work experience
`
`in hybrid vehicles and propulsion systems. This experience would enable the
`
`skilled artisan to understand the various arrangements of propulsion systems and
`
`the energy transfer between components within hybrid vehicles described in the
`
`932 patent and the prior art.
`
`38.
`
`In May 2007, I was earning a Ph.D. in in Mechanical Engineering at
`
`the University of Alberta. My work focused on automotive control systems. I was
`
`at least a person of ordinary skill in the art at that time. Since completing my
`
`doctorate, I have continued to research and publish in the area of automotive
`
`controls, including controls for hybrid and electric vehicles.
`
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`VI.
`
`A.
`
`The Kira Reference
`
`39. Kira
`
`having multiple traction drive systems. Kira
`
`of the propulsion system of hybrid vehicle V with three traction drive systems:
`
`(Kira, Fig. 1 (annotations added).) The first traction drive system includes an
`
`engine E, a generator G, a low-voltage battery Bl, and a sub rear motor Ms for
`
`driving rear wheels Wr. (Kira, [0037], [0038].)
`
`Ms . . . is driven by direct current from the low-voltage battery Bl which is charged
`
`(Kira, [0043].)
`
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`40.
`
`The second traction drive system includes a high-voltage battery Bh
`
`with a higher voltage than low-voltage battery Bl and a front motor M for driving
`
`front wheels Wf. (Kira, [0037], [0038].) The third traction drive system includes
`
`a main rear motor Mm also connected to high-voltage battery Bh and for driving
`
`rear wheels Wr. (Kira, [0037], [0038].)
`
`otor M . . . is
`
`driven by converting a direct current of the high-voltage battery Bh to a three-
`
`phase alternating current at the power drive unit Pf, and similarly, the main rear
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`motor Mm . . . is driven by converting the direct-current of the high-voltage battery
`
`Bh to a three-phase alternating-
`
`(Kira, [0043].)
`
`motor Mm are driven by driving force from the front wheels Wf and the rear
`
`wheels Wr so that the front motor M and the main rear motor Mm are made to
`
`function as a generator, whereby the high-voltage battery Bh is charged by
`
`(Kira, [0043].)
`
`B.
`
`The Yamada Reference
`
`41.
`
`Yamada
`
`system having multiple traction drive systems. (Yamada, Abstract, [0014], [0017],
`
`[0018], [0178].) Figure 20 shows one embodiment of Yamada
`
`with at least two traction drive systems:
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`(Yamada, Fig. 20 (annotations added).) As shown in Figure 20, the first traction
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`drive system includes a motor generator MG1 connected to an engine 240 and a
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`motor generator MG2 connected to motor generator MG1. (Yamada, [0178],
`
`[0179].) Motor generator MG1 generates electricity through the rotational force of
`
`the engine 240, and then
`
`30, which converts the voltage and drives motor generator MG2 to propel the
`
`vehicle. (Yamada, [0180], [0191].) During some operations, motor generator
`
`MG2 operates using a boosted voltage Vm that has been boosted or increased from
`
`battery voltage Vb. (Yamada, [0212].)
`
`42.
`
`The second traction drive system includes a battery 10 connected to a
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`motor generator MG3. (Yamada, [0214].) Motor generator MG3 receives battery
`
`voltage Vb from battery 10 and drives the rear wheels. (Yamada, [0193].) In
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`generator MG3 is driven in regeneration mode and the generated electric power is
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`(Yamada, [0214].)
`
`The Kumar Reference
`
`Like Kira, Kumar discloses a hybrid propulsion system having
`
`C.
`
`43.
`
`multiple traction drive systems. Figure 4 illustrates a schematic of one exemplary
`
`traction drive system used in the Kumar hybrid propulsion system:
`
`(Kumar, Fig. 4.) As shown in Figure 4, the traction drive system includes traction
`
`motor(s) 108 that receive energy from a power source (i.e., an engine) 102 and/or
`
`an energy capture and storage device (i.e., a battery) 204. (Kumar, [0056]-[0059].)
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`44. Kumar discloses that the traction motor(s) 108 are capable of
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`performing dynamic braking. As shown in Figure 4 above, the traction motor(s)
`
`108 are connected to braking grids. D
`
`extent that energy storage 204 is unable to receive and/or store all of the dynamic
`
`braking energy, the excess energy is routed to braking grids 110 for dissipation as
`
`(Kumar, [0058].)
`
`45. Kumar also discloses that it was well known to use one or more
`
`auxiliary electrical systems to power various electrical components, such as
`
`battery chargers, field exciters, power steeri
`
`(Kumar,
`
`[0015].) The auxiliary electrical systems may be driven by a generator connected
`
`to power source 102 or a separate axle drive generator. (Kumar, [0015].) In some
`
`other embodiments in Kumar, the auxiliary electrical systems may also receive
`
`energy from an energy storage device or electrical bus. (Kumar, [0100], [0110],
`
`and [0113] and Figs 9A-G.)
`
`D.
`
`46.
`
`The Hanyu Reference
`
`Like Kira, Hanyu discloses a hybrid propulsion system with an
`
`engine, a battery, and a plurality of motor generators. (Hanyu at Abstract, Fig. 1.)
`
`As shown in Figure 1 of Hanyu below, the engine and battery are connected to first
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`and second motor generators for generating electricity to propel the vehicle.
`
`(Hanyu, [0036].)
`
`(Hanyu, Fig. 1.)
`
`47.
`
`The battery 23 shown in Hanyu includes two battery modules 23a and
`
`23b. (Hanyu, [0040].) Hanyu
`
`to change the output voltage VB
`
`(Hanyu, [0041].) Specifically, as
`
`shown in Figure 2 of Hanyu
`
`switch 24p is opened, battery modules 23a and 23b connect with each other in
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`series and voltage VB of battery 23 increases. Also, when switch 24p is closed and
`
`switch 24s is opened, battery modules 23a and 23b connect with each other in
`
`parallel and voltage VB
`
`(Hanyu, [0041].) Figure 2 below
`
`illustrates a schematic of the switch 24:
`
`(Hanyu, Fig. 2.) As shown in Fig. 2, switch 24 allows battery modules 23a and
`
`23b to be connected in series or in parallel.
`
`E.
`
`The Masahiko Reference
`
`48.
`
`Like Kira, Masahiko discloses a vehicle that is an electric vehicle or
`
`at least partially battery-powered. As part of Masahiko
`
`-powered vehicle,
`
`Masahiko discloses a device for heating or cooling battery cells that provide
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`energy to a drive motor. (Masahiko, Abstract, [0022], [0023].) Figures 1 and 3
`
`illustrate one embodiment of Masahiko
`
`-adjusting device:
`
`(Masahiko, Figs. 1 and 3.) As shown in Figure 3, a battery case 5 includes
`
`multiple battery housing spaces 9 for housing multiple battery cells 3 (shown only
`
`in Fig. 1). (Masahiko, [0024].) The temperature-
`
`Peltier
`
`heating or cooling depending on the
`
`direction of an electric current supplied by a voltage being impressed, and heat or
`
`cool the battery cells 3 to change the temperature of such, and are positioned at
`
`each of the battery cells 3 so as to be able to change the temperature of all of the
`
`battery cells 3.
`
`(Masahiko, [0026].) In my opinion, a person skilled in the art
`
`would understand a Peltier element to be a device/substance that allows for heating
`
`and cooling by converting electrical energy to thermal energy for thermal
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`conditioning of different parts of the battery. The temperature-adjusting device
`
`. . . for detecting the temperature
`
`temperature control means that acts so as to cause the
`
`temperature of the Peltier element 17 to change in accordance with the temperature
`
`of the battery cell 3 detected by the battery temperature sensor 39
`
`(Masahiko,
`
`[0031], [0034].)
`
`F.
`
`The Katsuta Reference
`
`49.
`
`Like Yamada, Katsuta discloses a drive system for a hybrid vehicle.
`
`(Katsuta at Title.) In Katsuta, the drive system includes an engine 64 and a battery
`
`50 connected to two motor generators 70, 72 for propelling the vehicle. (Katsuta,
`
`[0015].)
`
`50. Katsuta also discloses a buck-boost converter, which boosts a battery
`
`voltage to be used by the motor generators. (Katsuta, [0015], [0016].) According
`
`to Katsuta,
`
`the voltage between the terminals of the main battery 50 is around 200
`
`~ 300 V, the normal operating voltage of the electric motor unit 52 is around 500
`
`V, and the buck-boost converter 54 accomplishes voltage conversion between
`
`(Katsuta, [0016].)
`
`G.
`
`51.
`
`The Suzuki Reference
`
`Like Yamada, Suzuki discloses a drive system for a vehicle (i.e.,
`
`multi-car train). More specifically, Suzuki discloses a drive system for a vehicle
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`having a plurality of batteries connected to an inverter and multiple motors per car
`
`for propelling the train/vehicle. (Suzuki at Abstract, [0008].)
`
`52.
`
`Suzuki
`
`ated voltage of the battery 5 is
`
`limited by the volume that can be installed on the car as a battery, and is lower (for
`
`example, 200 V) than the rated direct-current voltage of the inverter 2 (for
`
`example, 1,500 V). Consequently, at times of power exertion by the train, the
`
`battery voltage needs to be boosted to the rated voltage of the inverter, and in
`
`addition, during times of braking, the inverter voltage needs to be reduced to the
`
`battery voltage in order to recover regenerative energy generated in the alternating-
`
`(Suzuki, [0009].)
`
`VII. Anticipation of Claims 1, 2, 23, 24, and 30 Based on Kira
`
`53.
`
`It is my opinion that Kira anticipates claims 1, 2, 23, 24, and 30 because
`
`it teaches every feature in the claims, either expressly or inherently.
`
`A.
`
`Kira Anticipates Claims 1, 2, 23, 24, and 30
`
`1.
`
`Independent Claim 1
`
`a.
`
`54. Kira
`
`of an engine, batteries, and motors used to propel a hybrid vehicle. (Kira, [0037],
`
`[0038].) For example