UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`POWER-PACKER NORTH AMERICA, INC.
`d/b/a GITS MANUFACTURING CO.,
`Petitioner,
`
`v.
`
`G.W. LISK COMPANY, INC.,
`Patent Owner.
`
`________________
`
`
`Case No. IPR2017-02034
`U.S. Patent No. 6,601,821
`Issue Date: August 5, 2003
`PROPORTIONAL CONTROL VALVE ASSEMBLY FOR
`EXHAUST GAS RECIRCULATION SYSTEM
`
`
`____________________________________________________________
`
`DECLARATION OF
`PROFESSOR KEVIN C. CRAIG, Ph. D.
`
`
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`POR0001
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`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`POWER-PACKER NORTH AMERICA, INC.
`d/b/a GITS MANUFACTURING CO.,
`Petitioner,
`
`v.
`
`G.W. LISK COMPANY, INC.,
`Patent Owner.
`
`________________
`
`
`Case No. IPR2017-02034
`U.S. Patent No. 6,601,821
`Issue Date: August 5, 2003
`PROPORTIONAL CONTROL VALVE ASSEMBLY FOR
`EXHAUST GAS RECIRCULATION SYSTEM
`
`
`____________________________________________________________
`
`DECLARATION OF
`PROFESSOR KEVIN C. CRAIG, Ph. D.
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`POR0001
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`The undersigned, Kevin C. Craig, Ph. D., Professor of Mechanical
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`Engineering and Director of the Center for Innovation and the Mechatronics
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`Laboratory at Hofstra University, declares under penalty of perjury in accordance
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`with the laws of the United States of America, that the following is true:
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`I.
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`Background and Experience
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`1.
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`In 1973, I received a B.S. in Engineering from the United States
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`Military Academy at West Point, NY. After a commission as an Officer in the U.S.
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`Army, I attended Columbia University, where I received an M.S. in Mechanical
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`Engineering in 1977, an M.Phil. in 1981, and a Ph.D. in Mechanical Engineering in
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`1986.
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` While in graduate school at Columbia, I also worked as a professional
`2.
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`engineer. In particular, from 1977-80, I worked as an Engineer in the mechanical-
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`nuclear design department of Ebasco Services, Inc., a major engineering firm in
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`New York City. And from 1980-81, I worked as a Research Engineer in the Xerox
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`Corporation’s Palo Alto Research Center in Palo Alto, CA, and Mechanical
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`Engineering Sciences Laboratory in Sleepy Hollow, NY.
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`3.
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`Also during graduate school, I taught and received tenure at two
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`universities. From 1981-84, I was an Assistant Professor in the Department of
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`Engineering at the U.S. Merchant Marine Academy; and from 1984-89, I was an
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`Associate Professor in the Department of Engineering at Hofstra University.
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`POR0002
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`4.
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`After receiving my Ph.D., from 1987-89, I worked as a Research
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`Engineer in the Automation and Robotics Laboratory at the U.S. Army Armament
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`Research, Development, and Engineering Center (ARDEC).
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`5.
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`From 1989-2008, I was a Professor of Mechanical Engineering in the
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`Department of Mechanical, Aerospace, and Nuclear Engineering at Rensselaer
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`Polytechnic Institute (RPI). While I was at RPI, from 2002-05, I also served as the
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`Chair of the Engineering Science Interdisciplinary Program and the Director of
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`Core Engineering in the Office of the Dean of the School of Engineering.
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`6.
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`From 2008-14, I was the Greenheck Endowed Chair in Engineering
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`Design in the College of Engineering at Marquette University.
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`7.
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`And from 2014-present, I have been a Professor of Mechanical
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`Engineering in the School of Engineering and Applied Science at Hofstra
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`University, where I am also the Director of the Center for Innovation, the
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`Mechatronics Laboratory, and the Mechatronics Certificate Program for Practicing
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`Engineers.
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`8.
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`Over my career, I have taught every major course in the mechanical
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`engineering curriculum, including but not limited to Statics, Dynamics, Strength of
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`Materials, Machine Design, Machine Dynamics, Modeling and Analysis of
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`Dynamic Systems, Feedback Control Systems, Digital Control Systems,
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`POR0003
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`Thermodynamics, Fluid Mechanics, Heat Transfer, Electronic Instrumentation, and
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`Design of Mechanical Systems.
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`9.
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`I have also developed and taught several innovative courses, all with
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`extensive laboratory and studio components. My innovative courses include, but
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`are not limited to, Engineering Problem Solving; Modeling, Analysis, and Control
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`of Dynamic Systems; Mechatronics; Senior Multidisciplinary Design; and Fluid
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`Power Mechatronics.
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`
`10.
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`I have received several noteworthy awards over the course of my
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`career. In 1987, the ASEE awarded me their New Engineering Educator
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`Excellence Award, a national award. RPI awarded me the three highest teaching
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`awards they confer: in 2000, the Lewis T. Assini Undergraduate Teaching and
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`Counseling Award; and in 2006, the RPI Trustees’ Outstanding Teacher Award,
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`and the School of Engineering Education Excellence Award. In 2011, IBM
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`awarded me their Faculty Innovation Award. In 2013, the ASEE awarded me their
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`North-Midwest Section Best Teacher Award; and the Marquette University
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`Mechanical Engineering Department awarded me their Best Teacher Award. And
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`in 2014, the ASME awarded me their Oustanding Design Educator Award, a
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`society award.
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` Based upon my experience and education, I consider myself a person
`11.
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`of at least ordinary skill in the art of mechanical engineering, and I further consider
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`POR0004
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`myself knowledgeable about the qualifications and perspective of a person of
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`ordinary skill in the art of mechanical engineering (“a POSA”). In particular, a
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`POSA would have had at least a B.S. degree in mechanical engineering, or an
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`equivalent field of study, with at least five years of professional work experience in
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`the characterization and use of hydraulic and/or pneumatic devices. Superior
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`qualifications in either education or experience could compensate for a deficit in
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`the other.
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`12.
`
`I submit this declaration in support of G.W. Lisk Company, Inc.
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`(“Lisk”), and against institution of inter partes review of U.S. Patent No.
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`6,601,821 (“the ’821 patent”). The opinions set forth herein are based on my
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`education, training, and years of experience in the field of mechanical engineering,
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`as well as my review of the relevant materials.
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`II. Materials Reviewed
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` When reviewing the documents discussed below and forming the
`13.
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`opinions set forth in this declaration, I have attempted to do so from the
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`perspective of a POSA at the time of the earliest filing date of the ’821 patent,
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`which I understand to be November 17, 2000.
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`14.
`
`In preparing this declaration, I have reviewed the following
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`documents:
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`
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`U.S. Patent No. 6,601,821 (“the ’821 patent”)
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`- 4 -
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`POR0005
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`
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`U.S. Patent No. 4,201,116 (“Martin”)
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`Certified English translation of German Published Examined
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`Application No. 1268494 (“Eggers”)
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`U.S. Patent No. 6,006,732 (“Oleksiewicz”)
`
`III. The ’821 Patent
`
`
`
` The ’821 patent is entitled “Proportional Control Valve Assembly for 15.
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`Exhaust Gas Recirculation System.”
`
`A. Technological Background
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`
`
` The ’821 patent describes and claims a valve assembly that is 16.
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`particularly useful as an exhaust gas recirculation (EGR) valve. As the
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`specification of the ’821 patent states, “[e]mission control systems for internal
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`combustion engines recirculate a portion of the exhaust gases emitted from the
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`engines back through the combustion process to lower harmful emissions.” ’821
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`patent at 1:16-19. Mixing the exhaust gases with fresh air/fuel mixtures lowers the
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`fuel’s combustion temperature and reduces the formation of harmful compounds
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`such as nitrous oxide. See id. at 1:22-25.
`
` Traditional EGR valves use electromechanical solenoids to generate
`17.
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`the actuating force necessary to regulate the flow rate of exhaust gas. In contrast,
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`instead of using electromechanical force, the ’821 patent’s valve uses fluid
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`pressure to provide the actuating force necessary to regulate the flow rate of
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`- 5 -
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`POR0006
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`exhaust gas. In particular, according to the Abstract, the invention is “[a] two-stage
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`proportional control valve assembly [that] regulates flow of a first fluid such as
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`engine exhaust gas using a second fluid such as engine oil for power.” ’821 patent
`
`Abstract. The Abstract further explains, “[a] directional valve under control of an
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`electrical actuator regulates flows of the second fluid to operate a fluid-powered
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`actuator. A mechanical connection between the fluid-powered actuator and a
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`[flow-regulating valve] enables the electrical actuator to [control the flow-
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`regulating valve indirectly.]” Id. As the patent explains, “[s]ince the electrical
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`control signals are not required to provide the force for opening or closing the
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`exhaust valve, my new two-stage proportional flow control valve assembly
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`conserves electrical power for other functions.” Id. at 1:35-39.
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`18.
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`I have been provided the following color-coded versions of Figures 2
`
`and 3 from the ’821 patent:
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`- 6 -
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`POR0007
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`1:1------—‘.*\I
`I
`
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`M"'1’
`-' ”Luann-M5“7'1;
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`I Gzfl'rgfilWIIllfrfl-l
`1141/
`_'____
`
`
`
`II ‘I'W'__\.‘m_\_#!" 130 ..................................
`
`16\|f 1
`I
`1
`as
`24
`I
`I
`I ________________
`F—‘LJJ
`l
`LI:
`11
`1
`*
`I
`|
`l
`1
`|
`l
`I
`1
`|
`___.J
`L____
`1
`1
`l
`'
`
`.
`
`.
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`5&2.
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`
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`3:57
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`————
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`wag!
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`113
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`126
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`- 7 -
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`POR0008
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`POR0008
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` Based on my reading of the ’821 patent, the color-coding in the
`19.
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`images above accurately depicts the following components in the illustrated
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`device: (1) a directional valve (orange), (2) the flow of engine oil (gold), (3) a
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`double-acting actuator (light blue), connected to (4) a flow-regulating valve (dark
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`blue), which regulates (5) the flow of exhaust gas (violet).
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`B. Claim Construction
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`20.
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`I understand that, when construing the meaning of terms used in
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`the ’821 patent’s claims, those terms are to be given their broadest reasonable
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`interpretation as understood by a POSA consistent with the ’821 patent’s
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`specification. I understand that the POSA is deemed to read claim terms not only in
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`the context of the particular claim in which the term appears, but also in the
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`context of the entire patent, including the specification.
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` The entire specification of the ’821 patent relates to EGR valves. The
`21.
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`patent’s title indicates that the control valve assembly is “for [an] exhaust gas
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`recirculation system.” The Abstract refers to regulating the flow rate of exhaust
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`gas. The Background section of the specification explains the utility of EGR
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`valves. Every example and drawing in the ’821 patent is of an EGR valve. A
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`POSA would have had this context in mind when analyzing the specification and
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`interpreting the terms used in the claims, and I have interpreted the claim terms of
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`the ’821 patent in view of this context.
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`POR0009
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`22.
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`I have been asked to interpret the following claim terms in the ’821
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`patent: (1) flow-regulating valve; (2) directional valve; (3) two-stage; and (4)
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`proportional.
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`1.
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`The Valve Terms (“Flow-Regulating Valve” & “Directional
`Valve”)
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`
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` The ’821 patent’s claims differentiate between and require the use of 23.
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`both a “flow-regulating valve” and a “directional valve.” E.g., ’821 Patent at
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`claim 1. In particular, independent claim 1 requires “a flow-regulating valve that
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`regulates a flow of a first fluid”; and “a directional valve that controls a flow of the
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`second fluid to the double-acting actuator.”
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` Similarly, independent claim 12 specifies “[a] method of controlling
`24.
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`flow rates of a first fluid utilizing fluid pressure supplied by a second fluid.” ’821
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`Patent at claim 12. Like the apparatus of claim 1, the method of claim 12 requires
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`use of “a directional valve that controls a flow of the second fluid to a double-
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`acting actuator,” as well as “a flow-regulating valve that controls the flow rates of
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`the first fluid.” Id.
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` The ’821 patent’s claims and specification provide context informing
`25.
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`a POSA’s understanding of “flow-regulating valve” and “directional valve.” The
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`following chart lists passages from the claims and specification that a POSA would
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`consider when interpreting these terms:
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`- 9 -
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`POR0010
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`“flow-
`regulating
`valve”
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`“directional
`valve”
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`The Claims
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`“…a flow-regulating valve that regulates a flow of a first fluid…”
`7:15-16 (claim 1).
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`“…a flow-regulating valve that controls flow rates of the first fluid
`for changing flow rates of the first fluid through the flow-regulating
`valve…” 8:61-64 (claim 12) (emphasis added).
`
`The Specification
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`“The invention features a two-stage proportional flow control valve
`assembly that is particularly useful for regulating exhaust flow
`rates in exhaust gas recirculating systems of internal combustion
`engines. Electrical control signals from an engine control module
`(ECM) regulate the exhaust flow rates through an exhaust valve
`utilizing engine oil pressure to produce a hydraulic actuating force.”
`1:29-35 (emphasis added).
`
`“An exemplary two-stage proportional flow control valve assembly
`adapted for use as an exhaust gas recirculating valve incorporates an
`exhaust valve that regulates exhaust flow rates recirculated to an
`engine and a directional valve that utilizes engine oil pressure for
`regulating opening and closing of the exhaust valve proportional to
`control signals from an engine control module (ECM)” 1:40-46
`(emphasis added).
`The Claims
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`“…a directional valve that controls a flow of the second fluid to the
`double-acting actuator…” 7:21-22 (claim 1).
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`“…the directional valve being movable…between… (a) a first
`position that directs a flow…to the first surface of the double-acting
`actuator and (b) a second position that directs a flow…to the second
`surface of the double-acting actuator.” 7:35-41 (claim 1).
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`“…moving the directional valve…between a first position that
`directs a flow…to a first surface of the double-acting actuator and
`second position that directs a flow…to a second surface of the
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`- 10 -
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`POR0011
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`double-acting actuator…” 8:42-47 (claim 12).
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`The Specification
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`“The directional valve controls flow…to the fluid-powered actuator
`to adjust the position of the exhaust valve proportional to the control
`signal.” 1:52-55.
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`
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` As the above passages show, the ’821 patent’s claims and 26.
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`specification consistently describe the “flow-regulating valve” as a valve that
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`regulates a fluid’s flow rate. In contrast, the ’821 patent’s claims and specification
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`consistently describe the “directional valve” as a valve that controls or directs fluid
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`flow to one of two sides of a double-acting actuator. Based on the distinct usage of
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`different terms to refer to separate components of the valve assembly, a POSA
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`would interpret a “flow-regulating valve” and a “directional valve” to be designed
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`to fulfill different primary functions. In particular, based on the claims and portions
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`of the specification cited above, a POSA would understand a “flow-regulating
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`valve” to be “a valve designed principally for regulating a fluid’s flowrate”; and a
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`“directional valve” to be “a valve designed principally for controlling the direction
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`of a fluid’s flow into different paths.”
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`2.
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`“Two-Stage”
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` A POSA would be familiar with the term “two-stage” as it relates to a
`27.
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`valve assembly. A POSA would understand a “two-stage” valve assembly to be an
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`- 11 -
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`POR0012
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`assembly that contains two valves, such that one valve is used to regulate the
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`movement of the other.
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` The ’821 patent uses the term “two-stage” consistent with a POSA’s
`28.
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`understanding of that term. In particular, the specification of the ’821 patent
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`describes a valve assembly wherein a directional valve controls flow of oil to either
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`side of a double-acting actuator, which adjusts the position of a flow-regulating
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`valve. See, e.g., ’821 patent at 1:40-55; 3:61-67; 4:28-35; 7:13-41; Figure 2.
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` Based on a POSA’s understanding of the term “two-stage” and
`29.
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`the ’821 patent’s usage of the term “two-stage” consistent with that understanding,
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`a POSA would understand “two-stage” as it is used in the ’821 patent to mean “a
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`valve assembly wherein one valve controls or regulates a second valve.”
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`3.
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`“Proportional”
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`
`
` A POSA would also be familiar with the term “proportional” as it 30.
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`relates to a valve assembly. A POSA would understand a “proportional” valve
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`assembly to be one that moves in proportion to a control signal of varying strength.
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`In other words, a stronger control signal would cause the valve assembly to move a
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`greater distance, while a weaker control signal would cause the valve assembly to
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`move a relatively lesser distance.
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` The ’821 patent uses the term “proportional” consistent with a
`31.
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`POSA’s understanding of that term. For example, the specification states that “[a]n
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`POR0013
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`electrical actuator…converts the control signals of varying current into
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`proportional forces.” Id. at 2:8-11 (emphasis added). And in the Detailed
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`Description of the invention, the ’821 patent states: “The change in position of the
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`piston head 62 along with the dual poppet head body 36…is substantially
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`proportional to the change in the solenoid actuating force.” Id. at 6:20-23.
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` The ’821 patent consistently describes the change in position of the
`32.
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`flow-regulating valve (e.g., the dual poppet head) as being proportional to a
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`“control signal” or a “solenoid actuating force.” A POSA would understand that a
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`“control signal” or “solenoid actuating force” refers to the amount of current, and
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`that the proportional valves disclosed in the ’821 patent would be controlled in
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`proportion with varying levels of current supplied to the solenoid. Accordingly,
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`and in line with a POSA’s understanding of the term “proportional” valve, a POSA
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`would understand the term “proportional” valve as it is used in the ’821 patent to
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`mean a valve “controlled relative to the strength of an electrical control signal of
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`varying current.”
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`IV. Non-Anticipation: The Differences Between the Prior Art and the ’821
`Patent
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`33.
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`I am informed by counsel that, in order to anticipate a patent, a prior-
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`art reference must disclose all of the limitations found in the claims of the patent. I
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`am further informed by counsel that, for a reference to anticipate a patent, it must
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`disclose those limitations as they are arranged in the patent’s claims. I am further
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`POR0014
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`informed by counsel that Petitioner argues that Martin anticipates claims 1-10 and
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`12-22 of the ’821 patent, and that Eggers anticipates claims 1-5, 12-13, and 16-18
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`of the ’821 patent. For the following reasons, I disagree.
`
`A. Martin
`
` The “Martin” reference is U.S. Patent No. 4,201,116, entitled
`34.
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`“Electro-Hydraulic Proportional Control Servo Valve.” The following illustration
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`is from Figure 1 of Martin, which is representative of the valve assembly that
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`Martin discloses:
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`- 14 -
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`POR0015
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` Martin does not disclose all of the limitations that appear in the claims
`35.
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`of the ’821 patent. In particular, Martin fails to disclose a flow-regulating valve.
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`Rather, a POSA would understand that the main control spool in Martin—spool 20
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`in Figure 1—is a directional valve that directs flows to either side of a double-
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`acting actuator, shown as 18 in Figure 1.
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` The “Summary of the Invention” in Martin provides further evidence
`36.
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`that a POSA would not interpret Martin to disclose a flow-regulating valve. In
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`particular, Martin states that the “[m]ain control valve…operates a double acting
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`cylinder.” Martin at 2:20-21. A POSA would understand that directional valves,
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`not flow-regulating valves, are used to operate double-acting cylinders as those
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`components are disclosed in Martin.
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` Because Martin fails to disclose a flow-regulating valve, Martin does
`37.
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`not anticipate claim 1 of the ’821 patent.
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`B.
`
`Eggers
`
` The “Eggers” reference is German Patent Application No. 1,268,494,
`38.
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`entitled “Pulse-Controlled Actuating Device.” The following is Figure 1 from
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`Eggers, which is representative of the valve assembly that Eggers discloses:
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`- 15 -
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`POR0016
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` Like Martin, Eggers fails to disclose all of the limitations claimed in 39.
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`the ’821 patent. In particular, Eggers does not disclose a proportional valve
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`assembly. As discussed above, a POSA would understand “proportional” valve as
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`it is used in the ’821 patent to mean a valve that is “controlled relative to the
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`strength of an electrical control signal of varying current,” such that the valve
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`would move a shorter or further distance in response to an electrical control signal
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`- 16 -
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`POR0017
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`of lesser or greater strength. Eggers, however, uses a stepper motor, shown as
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`number 15 in Figure 1, to incrementally change the length of cable 14 to move the
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`pilot spool, which in turn directs flow to either side of the double-acting actuator.
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`Eggers states: “a stepper motor…adjusts the actuating drive by one distance unit
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`with each pulse.” Eggers at 4:4-6 (emphasis added). In other words, Eggers’ valve
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`is not “controlled relative to the strength of an electrical control signal of varying
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`current,” because the stepper motor provides only an input that incrementally
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`changes the length of cable 14. The stepper motor does not change the strength of
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`the input based on the strength of an electrical control signal. Thus, the position of
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`the valve disclosed in Eggers is not adjusted in proportion to the strength of a
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`control signal, but rather incrementally by changing the length of cable 14, where
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`the valve moves a number of steps it is commanded to move (i.e., one step per
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`pulse).
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` Because Eggers fails to disclose a proportional valve assembly,
`40.
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`Eggers does not anticipate the ’821 patent.
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`V. Non-Obviousness: The Lack of a Reason or Motivation to Combine
`Prior Art References
`
`
`41.
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`I am informed by counsel that an invention may also be rendered
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`invalid if a combination of two or more prior art references would have rendered
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`the subject matter recited in a claim obvious to a POSA at the time of invention. I
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`am further informed by counsel that Petitioner argues that the combination of
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`- 17 -
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`POR0018
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`Martin and/or Eggers with a third reference—Oleksiewicz—would have rendered
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`the subject matter recited in the ’821 patent’s claims obvious to a POSA at the time
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`of the invention. For the following reasons, I disagree.
`
`A. Oleksiewicz
`
` The Oleksiewicz reference is U.S. Patent No. 6,006,732, entitled
`42.
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`“Balanced Flow EGR Control Apparatus.” Like the ’821 patent, Oleksiewicz
`
`relates specifically to EGR systems in internal combustion engines. Oleksiewicz at
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`1:5-15.
`
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`43.
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`In contrast, neither Martin nor Eggers relate specifically to valve
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`assemblies used in internal combustion engines, let alone EGR valve assemblies in
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`internal combustion engines. Rather, Martin relates simply to solenoid-operated
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`directional control valves, Martin at 1:5-7, and Eggers relates specifically to an
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`actuating device that is controlled by means of electrical unit pulses, Eggers at
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`1:23-25.
`
` Moreover, while the valve assemblies disclosed in Martin and Eggers
`44.
`
`entail the use of double-acting actuators, the valve assembly in Oleksiewicz is not
`
`adapted for use with a double-acting actuator, but rather only with a linear actuator
`
`such as a solenoid. When a linear actuator like a solenoid actuates a valve, the
`
`power to move the valve comes directly from the electromechanical energy
`
`generated by the solenoid. In contrast, in a double-acting actuator, compressed air
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`- 18 -
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`POR0019
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`or liquid is supplied to both sides of a piston, with the pressure on one side of the
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`piston being greater, which achieves the movement required to actuate the valve.
`
`In a double-acting actuator, the compressed air or liquid supplied to the piston
`
`provides the energy required to move the valve.
`
` Given the different fields to which Martin, Eggers, and Oleksiewicz
`45.
`
`relate—solenoid-operated control valves in Martin, actuating devices controlled by
`
`means of electrical unit pulses in Eggers, and EGR systems in internal combustion
`
`engines in Oleksiewicz—a POSA would have had no reason to combine any of
`
`these references to arrive at the invention disclosed in the ’821 patent.
`
`B.
`
`Eggers and Martin.
`
` Counsel informs me that Petitioner argues that claims 1-10 and 12-22
`46.
`
`of the ’821 patent are obvious in view of the combination of Eggers and Martin. In
`
`particular, Petitioner contends that it would have been obvious for a POSA to
`
`incorporate into Eggers the proportional control mechanism disclosed in Martin to
`
`allow finer, more precise, and thus more accurate control of the valve position. I
`
`disagree.
`
` A POSA reading Eggers would not have modified it with any other
`47.
`
`actuating device, because the whole point of the valve in Eggers was to overcome
`
`problems associated with known actuating devices by using a pulse-controlled
`
`actuating device. In particular, Eggers states that “[v]arious actuating devices in
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`- 19 -
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`POR0020
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`which an electrodynamic force element…adjusts a control element are known.”
`
`Eggers at 2:3-4. Eggers then describes several disadvantages of previously known
`
`actuating devices, and describes how the invention disclosed in Eggers “is based
`
`on the object of eliminating the disadvantages mentioned,” id. at 4:1, by using a
`
`“pulse-controlled actuating device,” id. at 4:8. Accordingly, a POSA would
`
`understand that Eggers is directed specifically toward the use of a “pulse-
`
`controlled actuating device.” A POSA would not seek to modify Eggers by
`
`including a very distinct actuating device as disclosed, for example, by Martin,
`
`because such modification would go against the actual teachings of Eggers.
`
`C. Martin and Oleksiewicz
`
` Counsel informs me that Petitioner contends that claims 11 and 19 of
`48.
`
`the ’821 patent are obvious in view of the combination of Martin and Oleksiewicz.
`
`In particular, Petitioner contends that Oleksiewicz discloses a duel poppet-head
`
`valve that is pressure balanced with respect to exhaust fluid flows. Petitioner
`
`further contends that a POSA reading Martin would have been motivated to
`
`substitute a poppet-head valve, such as the one disclosed by Oleksiewicz, for the
`
`“spool-based” valve disclosed in Martin to reduce leakage and improve efficiency.
`
`I disagree.
`
` A POSA reading Martin would not have modified the main control
`49.
`
`spool with any other type of valve, because the specific purpose to which Martin is
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`- 20 -
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`POR0021
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`directed is to provide an electrohydraulic proportional control servo valve wherein
`
`the main control valve thereof is a conventional directional control valve. The
`
`entire disclosure of Martin relates to directional valves. In the very first line of the
`
`patent, in fact, Martin discusses the field of “solenoid operated directional control
`
`valves.” Martin at 1:6. And throughout the specification, Martin repeatedly refers
`
`to the “main control valve spool.” Martin at 1:19-20, 24-25, 30, 40. A POSA
`
`would understand such references to the “main control valve spool” to refer to a
`
`spool-type directional control valve. Accordingly, a POSA would understand that
`
`Martin is directed specifically toward a spool-type directional control valve. A
`
`POSA would not seek to modify Martin with a poppet-head valve as disclosed, for
`
`example, by Oleksiewicz, because such modification would go against the actual
`
`teachings of Martin.
`
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`50.
`
`I have made all statements in this declaration on the basis of personal
`
`knowledge unless otherwise specifically noted.
`
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`Dated: December 20, 2017
`
`
`Kevin C. Craig, Ph.D.
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`POR0022
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