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`IPR2018-00520
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SMR AUTOMOTIVE SYSTEMS USA, INC.,
`Petitioner,
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`v.
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`MAGNA MIRRORS OF AMERICA, INC.,
`Patent Owner.
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`
`Case IPR2018-00520
`Patent No. 8,267,534
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`DECLARATION OF MICHAEL NRANIAN IN SUPPORT OF PATENT
`OWNER MAGNA MIRRORS OF AMERICA, INC.’S PRELIMINARY
`RESPONSE
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`Patent Owner Magna - Ex. 2001, Cover
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`IPR2018-00520
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`TABLE OF CONTENTS
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`I.
`INTRODUCTION AND QUALIFICATIONS .................................... 1
`SUMMARY OF MATERIALS REVIEWED AND CONSIDERED .. 7
`II.
`III. LEVEL OF ORDINARY SKILL IN THE ART .................................. 7
`IV. BACKGROUND LAW ....................................................................... 11
`V. OPINIONS .......................................................................................... 12
`A. Disclosures of Lynam ‘026 That Appear in the ‘451 Patent .... 12
`B.
`Henion ‘013 Discloses A Trailer Towing Mirror ..................... 14
`C.
`SMR Fails To Demonstrate A Motivation To Combine
`Henion ‘013 And Platzer ‘956. ................................................. 18
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`Patent Owner Magna - Ex. 2001, p. i
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`I.
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`INTRODUCTION AND QUALIFICATIONS
`1.
`I have been retained by patent owner Magna Mirrors of America, Inc.
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`(“Magna”) to provide my opinion on certain matters regarding SMR Automotive
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`Systems USA Inc. (“SMR”)’s Petition for Inter Partes Review of U.S. Patent No.
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`8,267,534 (“the ‘534 patent”).
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`2.
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`All statements herein made of my own knowledge are true, and all
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`statements herein based on information and belief are believed to be true. I am
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`over 21 years of age and am competent to make this declaration.
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`3.
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`At this stage, I have been asked to provide my opinions on certain
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`discrete issues that are relevant to Magna’s Preliminary Patent Owner Response. I
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`have not been asked to and do not opine regarding the ultimate issues addressed by
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`SMR’s proposed grounds. The fact that I do not opine on any given issue in this
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`declaration should not be construed as agreement with SMR’s positions. I reserve
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`the right to provide additional opinions in the event that an IPR is instituted.
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`4.
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`I am being compensated at the rate of $350 per hour for time
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`preparing this declaration. My compensation is not contingent on the outcome of
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`this proceeding.
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`5.
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`Although I have a law degree, and I am licensed to practice before the
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`United States Patent and Trademark Office, I have not been asked to opine on any
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`legal issues. I will not be giving any legal opinions throughout this declaration and
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`Patent Owner Magna - Ex. 2001, p. 1
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`throughout my work on this matter. My opinions provided herein are based on my
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`engineering, technical, scientific, and business education and experience.
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`6. My academic background is in engineering. I possess a Bachelor of
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`Science in Electrical and Computer Engineering, a Master of Science in Electrical
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`Engineering, a Bachelor of Science in Chemical Engineering and a Juris Doctor
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`from Wayne State University. I also received a Master of Business Administration
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`from the University of Michigan. I also am a licensed Professional Engineer,
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`Certified Project Management Professional, as well as a Lean Six Sigma Black
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`Belt certified through the American Society for Quality and the International
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`Quality Federation.
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`7.
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`I have extensive industry experience in the automotive industry for
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`multiple companies. Specifically, I worked as a design engineer, senior project
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`engineer, design analysis engineer, technical specialist, and engineering manager
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`in the automotive industry from 1985 to 2007. This included experience at Ford,
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`General Motors, and Allied Signal. I worked at Allied Signal from 1992 to 1993,
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`General Motors from 1993 to 1995, and Ford Motor Company from 1985 to 1992,
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`and from 1995 to 2007.
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`8. While at Ford, General Motors, and Allied Signal, I worked as a
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`Product Design Engineer, a Senior Project Engineer, a Technical Specialist, a
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`Design Analysis Engineer, and an Engineering Manager. My work included the
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`design and development of automotive safety systems and components for various
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`different types of automotive applications. This included, among other things,
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`testing and development of systems and components for active and passive safety.
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`9.
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`Areas of my work included both active and passive sensing systems
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`which can be used in the vehicle interior or exterior, including the design and
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`development of sensing components and systems that incorporate electromagnetic
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`wave sensing and visual perception (including, but not limited to, vision, camera,
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`radar, lidar, infrared ultraviolet, night vision, mirrors, and other optical devices,
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`including those containing lenses and mirrors) as well as acoustical sensing. Areas
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`of my work also specifically included vision systems, occupant ergonomic
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`evaluations, user and occupant audio and visual perception, visual interfaces and
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`displays, infrared, vision, mirrors, lenses, camera, sonar, acoustic, radar, lidar,
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`sensing and detection technologies and systems. I also worked on sensing systems
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`for various automotive applications, including sensor fusion technologies, for
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`image and object detection, discrimination, and identification and the appropriate
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`status notifications to vehicle drivers and occupants, and visual perception
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`techniques and methods.
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`10. My work specifically involved the testing and development of the
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`aforementioned systems. This included both laboratory tests and technology
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`assessments, as well as testing in various real world driving situations and traffic
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`events.
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`11. My responsibilities also included technology assessments and proper
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`supplier and sourcing evaluation and selection, quoting and bidding, and the
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`overall source selection for numerous technologies. For example, while at Allied
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`Signal, I specifically prepared numerous extensive proposals and responses for
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`many different domestic, European, Asian, and Pacific Rim requests for quotations
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`(“RFQs”) in the hopes of winning awards as the Tier 1 supplier chosen for many
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`original equipment manufacturer (“OEM”) programs. I was involved in both
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`winning awards and non-winning awards on numerous programs for different
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`OEMs. While at General Motors and Ford, I was an integral part of many cross-
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`functional teams involved in the sourcing selection, request for information
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`(“RFI”) and RFQ processes and evaluations, and ultimate evaluation and decision
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`as to which suppliers were chosen for purchase order (“PO”) awards on numerous
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`vehicle programs.
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`12. My responsibilities also included ensuring compliance with Federal
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`Motor Vehicle Safety Standards (FMVSS), Economic Commission for Europe
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`(“ECE”) regulations, Industry Standards, Corporate Standards, various
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`international government regulations, and Due-Care Requirements. I also testified
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`as a corporate representative and expert witness on behalf of Ford. In that role, I
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`have analyzed, verified, and testified regarding compliance with FMVSS
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`requirements, including FMVSS 111.
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`13. My work over the years has also included analyses involving
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`statistical information from the National Automotive Sampling System (NASS)
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`and Fatality Analysis Reporting System (FARS) databases. My work also
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`involved extensive inspection, investigation, and analysis of field events involving
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`automotive safety systems. I am also certified in accident reconstruction through
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`Northwestern University, and I have performed numerous real-world assessments
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`of accident causation as part of my investigations. I have specifically assessed
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`accidents involving lane change incidents.
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`14.
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`I also conducted numerous system and component evaluations,
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`laboratory tests, supplier and technology assessments, quality and reliability
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`evaluations, as well as developed design validation plans and reports and failure
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`modes and effects analyses to design and develop automotive safety, sensing,
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`vison, and electrical electronic systems, including the integration of sensor fusion
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`technologies. I also conducted numerous vehicle test track (I am qualified as a
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`Ford Level II certified test track driver), rough road, obstacle, lane change,
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`braking/stopping, maneuverability, on-road, off-road, as well as numerous crash
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`and sled tests, for vehicular safety systems testing, development, design, prove-out,
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`verification, and validation.
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`15. Subsequent to my employment at Ford, I worked as a Systems
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`Engineer for Raytheon and General Dynamics, as well as a contractor and civilian
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`employee for the U.S. Army. My work has included, among other things, sensor
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`development and visual perception, including camera, optical systems, viewers,
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`lenses, mirrors, and visual displays. I currently work at the Tank and Automotive
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`Research, Development and Engineering Center (TARDEC) in Warren, Michigan,
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`where I work on systems for military ground vehicle systems, which extensively
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`involve the application of automotive technologies, including those related to
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`automotive safety systems.
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`16. My current responsibilities include working with internal scientists,
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`researchers and technical staff, as well as outside collaborators and universities, to
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`develop technologies, innovation, and inventions for the protection of our soldiers
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`and the enhancement of our soldiers’ survivability in military vehicles. My
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`responsibilities include and have included technologies involving camera and
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`vision systems (including those involving mirrors and lenses), Command, Control,
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`Communications, Computers, Intelligence, Surveillance and Reconnaissance
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`(C4ISR) systems, 360-degree surveillance, optical systems, visual perception and
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`identification, interface displays, acoustic, ultrasonic, infrared, radar, night vision,
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`and electromagnetic wave sensing, sensor fusion integration, algorithm, and
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`pattern recognition development, sensor information discrimination and
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`identification, active and passive safety system development, and occupant injury
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`mitigation.
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`17.
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`I have been qualified to testify as an expert in over 20 cases involving
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`automotive safety systems.
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`18.
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`I understand that my curriculum vitae, which includes a more detailed
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`summary of my background, experience, and publications, is being submitted
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`concurrently.
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`II.
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`SUMMARY OF MATERIALS REVIEWED AND CONSIDERED
`19. The opinions contained in this Declaration are based on the
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`documents I reviewed and my knowledge and professional judgment. In forming
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`the opinions expressed in this Declaration, I reviewed SMR’s Petition and all
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`Exhibits thereto, as well as SMR’s Petition and Exhibits in IPR2018-00491
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`IPR2018-00505, IPR2018-00506, IPR2018-00517, IPR2018-00533, IPR2018-
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`00536, IPR2018-00541, IPR2018-00545.
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`20. My opinions are further guided by my understanding of the
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`knowledge of a person of ordinary skill in the art (as further defined below) as of
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`the claimed May 20, 2003 priority date of the ‘534 patent.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`21.
`I understand that patent validity is assessed from the standpoint of a
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`person of ordinary skill in the art (POSA) at the time of the invention.
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`22.
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`I understand that SMR has asserted that a POSA at the relevant time
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`would have had “a M.S. in Optics, Optical Engineering, or similar studies in a
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`related field (e.g., Physics or Mechanical Engineering) with 2-3 years of
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`experience in the optics/mechanical industry.” I disagree.
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`23. A POSA in the field of the ‘534 patent would necessarily have
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`experience working in the automotive industry. The ‘534 patent claims are
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`directed to “[a]n exterior rearview mirror assembly suitable for a motor vehicle.”
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`Ex. 1001, claim 1. According to the specification, the specific problem that the
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`claimed invention solves is to “reduce[], if not eliminate[], an automobile’s blind
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`spot.” Id., 20:21. The specification explains that the claimed invention does so in
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`a manner that is superior to prior art blind spot mirrors for several reasons. For
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`example, first, it “provides a seamless rearvision function whereby the image of a
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`side approaching/side overtaking other vehicle is substantially seamlessly
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`maintained as the image of the overtaking or approaching vehicle transitions from
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`being principally and substantially viewed by the driver of the vehicle … in the
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`plano reflective element to be seen in the auxiliary reflective element.” Id., 20:28-
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`36. Second, the claimed invention allows “a driver [to] simultaneously and
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`similarly move the auxiliary element and the plano element so as to position their
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`respective rearward fields of view, and to achieve this within the relatively
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`restricted space available in a standard automobile-sized exterior sideview mirror
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`assembly.” Id., 12:44-50. And third, the claimed invention “has manufacturing
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`advantages, particularly for exterior sideview mirror assembly manufacturers who
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`can procure a plano-multiradius reflective element assembly module from a mirror
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`reflector supplier and then mount the plano-multiradius reflective element
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`assembly module onto an actuator.” Id., 15:14-20.
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`24. A mechanical engineer, optical engineer, or someone with an M.S. in
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`optics who does not have experience in the automotive industry would not be
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`familiar with the requirements necessary in order to provide an exterior automotive
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`mirror that is useful and convenient to drivers without being distracting, that is
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`desirable for automobile original equipment manufacturers (OEMs), and that
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`complies with federal regulatory requirements. For example, the ‘534 patent
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`specification discloses that the plano element should be of a size sufficient “to
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`provide the driver of the automobile a view of a level road surface extending to the
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`horizon from a line, perpendicular to a longitudinal plane tangent to the driver’s
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`side of the automobile at the widest point, extending 8 feet out from the tangent
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`plane 35 feet behind the driver’s eyes.” Id., 12:65-13:3; see also id., 15:29-47
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`(describing similar requirement). A POSA would recognize that this field of view
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`is consistent with the requirements of FMVSS 111. Ex. 1040, 20. A person
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`without experience in the automotive industry would not necessarily have the
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`understanding and experience of designing, developing, and testing vehicle
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`components and systems to comply with this requirement and the other
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`requirements of FMVSS, while also still meeting the stringent automotive industry
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`standards and rigorous requirements for reliability, quality, durability,
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`performance, manufacturing, and assembly. A person without experience in the
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`automotive industry would also not necessarily understand that vehicle
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`components and systems must also be designed and developed to meet due care
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`requirements, beyond the minimal safety standards established by FMVSS
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`regulations. This requires work in the automotive industry and an understanding of
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`how automobiles are used in the real world.
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`25. For example, in applications specific to this patent, an engineer with
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`experience in the automotive industry would understand the added complexities in
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`designing automotive side-view mirror systems that safely provide the requisite
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`information to the driver (such as whether a vehicle is in the blind spot) to
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`maximize the ability of the driver to visually perceive and cognitively understand
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`the information. An engineer with experience in the automotive industry would
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`also understand the need to minimize driver confusion regarding objects appearing
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`in the side view mirror and the need to minimize driver distraction and enable the
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`driver to focus attention on the view forward of the vehicle. Engineers with
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`experience in the automotive industry would recognize that the ‘534 patent alludes
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`to these types of design considerations when it discusses, for example, that the
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`Patent Owner Magna - Ex. 2001, p. 10
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`invention “provides a seamless rearvision function whereby the image of a side
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`approaching/side overtaking other vehicle is substantially seamlessly maintained as
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`the image of the overtaking or approaching vehicle transitions from being
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`principally and substantially viewed by the driver of the vehicle … in the plano
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`reflective element to be seen in the auxiliary reflective element.” Ex. 1001, 20:28-
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`36.
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`26. Based on the field that the ‘534 patent is directed to, the levels of
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`education and experience of persons working in the field in the relevant time, the
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`types of problems encountered in the field, and the sophistication of the
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`technology, a POSA at the time of the ‘534 patent priority date would have had a
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`M.S. in an engineering discipline relevant to automotive component design (e.g.,
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`electrical engineering, mechanical engineering, or optical engineering), as well as
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`2-3 years of experience in the automotive industry designing components for
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`automobiles.
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`IV. BACKGROUND LAW
`27.
`I have been informed that claims of unexpired patents in an IPR are
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`given their broadest reasonable interpretation, when reading the claims in light of
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`the specification and the teachings in the patent. I also have been informed that the
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`broadest reasonable interpretation should account for how the claims themselves
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`and the specification inform a POSA as to which ordinary definition the patentee
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`was using. I further have been informed that claims should not be construed so
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`broadly that they are unreasonable under general claim construction principles.
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`V. OPINIONS
`A. Disclosures of Lynam ‘026 That Appear in the ‘451 Patent
`28.
`I understand that SMR asserts that each limitation of claims 1-20 of
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`the ‘534 patent are disclosed by U.S. Patent App. Pub. No. 2002/0072026 (“Lynam
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`‘026”).
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`29. Lynam ‘026 is a published patent application that is a continuation-in-
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`part of the application that issued as U.S. Pat. No. 6,522,451 (“the ‘451 patent”).
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`30. The majority of the material from Lynam ‘026 that SMR maps to the
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`claims of the ‘534 patent also appears in the ‘451 patent. Exhibit 2012 is an
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`annotated copy of Lynam ‘026, with the paragraphs that also appear in the ‘451
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`patent highlighted.
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`31. SMR’s mapping of the disclosures of Lynam ‘026 to the claim
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`limitations of the ‘534 patent demonstrates that the ‘451 patent also fully discloses
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`the majority of the claim limitations of the ‘534 patent as arranged in the ‘534
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`patent. The limitations of claims 1-20 of the ‘534 patent for which SMR relies on
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`one or more paragraphs of Lynam ‘026 that also appear in the ‘451 patent are
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`shown in the chart below.
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`Patent Owner Magna - Ex. 2001, p. 12
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`Limitation
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`Preamble,
`1[a], [b], 7[a],
`[b], 13[a], [b]
`1[c], 7[c],
`13[c]
`1[d], 7[d],
`13[d]
`7[f], 13[g]
`13[f]
`2, 8, 14
`3, 4, 9, 10, 15,
`16
`15, 11, 17
`6, 12, 18
`19
`20
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`Lynam ‘026 disclosure cited by SMR
`that also appears in the ‘451 patent
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`¶¶ 41, 57, 59, 61, Figs. 1, 2, 3, 7
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`¶¶ 41-42, 45, 50-53, Figs. 2, 3, 5A-C,
`6-7
`¶¶ 5, 42-43, 46, 49, 57-59, 61, 83, Figs.
`3, 5A-H, 6-7
`¶¶ 43, 48, 55
`¶¶ 52, 58-59, Fig. 6
`¶¶ 42, 50, 51-52, 59, 61, Figs. 3, 6
`¶¶ 43, 50, 83, Fig. 3
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`Fig. 6
`¶ 52, Fig. 5G
`¶¶ 59, 61, Figs. 3, 6-7
`¶ 59
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`Pages of SMR
`Petition Where
`Limitation Is
`Discussed
`Petition, 34-36, 38, 39
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`Petition, 36-37, 38, 39
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`Petition, 37-38, 39
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`Petition, 38, 39
`Petition, 39-40
`Petition, 40-41
`Petition, 41-42
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`Petition, 42-43
`Petition, 43-44
`Petition, 44
`Petition, 44
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`32.
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`I agree with SMR that each of the paragraphs of Lynam ‘026 cited
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`above disclose the limitations of the ‘534 patent claims for which SMR cites those
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`paragraphs. Because each of these paragraphs also appear in the ‘451 patent, the
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`‘451 patent discloses all of the limitations of the ‘534 that appear in the chart
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`above.
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`B. Henion ‘013 Discloses A Trailer Towing Mirror
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`33. Larger vehicles such as pickup trucks and sport utility vehicles are
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`often equipped with a towing hitch that can be used to tow a trailer, camper, boat,
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`mobile home, horse carrier, or a similar object. The presence of the trailer presents
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`additional difficulties for the driver, and specialized mirrors, commonly called
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`trailer towing mirrors, are used to address the particular challenge of towing a
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`trailer.
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`34.
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` Many towed objects block the view of the towing vehicle’s inside
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`rearview mirror. A driver towing such a trailer needs to rely solely on the side
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`view mirrors when attempting to see if there are any obstacles behind the vehicle.
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`The side view mirrors therefore need to provide a view around the trailer and need
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`to have a clear view along the side of the trailer.
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`35. Having a clear view along the side of the trailer is particularly
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`important when parking or backing up. The driver must rely on the side view
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`mirrors to clearly see the sides of the trailer to avoid hitting objects (such as an
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`adjacent parked car, the side of a loading dock, or the sides of a garage stall) when
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`backing into a parking space.
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`36. A trailer towing mirror that features a spotting mirror may be
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`designed to give the spotting mirror a field of view that extends further skyward
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`and further downward towards the road surface, so that the driver can see the top
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`and bottom of the side of the trailer. The spotting mirror may be designed to
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`provide a view of the side of the trailer so that the driver can position the field of
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`view of the main plano mirror element further outward away from the side of the
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`vehicle without losing sight of the side of the vehicle.
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`37. Because they are designed for larger vehicles such as trucks and
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`SUVs, trailer towing mirrors are typically larger than a mirror on a smaller car.
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`Cars typically have smaller mirrors than trucks and SUVs for styling reasons,
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`because a smaller mirror is more aesthetically pleasing on a smaller vehicle than a
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`large mirror. A smaller mirror also has aerodynamic benefits because its smaller
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`front surface area creates less drag. This improves a vehicle’s fuel efficiency.
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`38. A POSA would have understood that the primary reference SMR
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`asserts for ground 2, WO 2001/44013 (“Henion ‘013”) discloses a trailer towing
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`mirror for at least two reasons. First, the inboard location of the spotter mirror is
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`ideally suited for viewing along the side of the vehicle and along the side of the
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`trailer being towed, not viewing into a blind spot. The ‘534 patent specification
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`discusses this as a benefit of a spotting mirror that is positioned at the inboard edge
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`of a mirror assembly. See Ex. 1001, 12:24-30 (inboard spotter configuration
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`“allows the driver [to] view the side of the vehicle (something many drivers desire
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`in order to have a frame of reference for their rearward field of view) while
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`facilitating having a wide field of view for the plano portion”). An inboard lower
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`spotter that views along the side of the vehicle will allow the driver to look to the
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`location where he or she would expect to see along the side of the vehicle, the side
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`of the mirror closest to the equipped vehicle. In contrast, if an inboard lower
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`spotter were to be used to view the blind spot, there would be a discontinuity for
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`the driver when the view of the passing vehicle moves from the outboard edge of
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`the main plano mirror to the inboard spotter as the passing vehicle moves forward
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`in the adjacent lane and into the blind spot. This has the potential to cause driver
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`confusion, which is dangerous. A driver often must rely on a momentary glance to
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`determine the location of a vehicle in an adjacent lane while also maintaining
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`cognitive and visual awareness of objects and vehicles in the direction of travel. If
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`a driver takes longer to process information provided by the sideview mirror
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`assembly because it is confusing, that risks distracting the driver from hazards that
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`are present in the direction of travel. Rear-end collisions account for thousands of
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`incidences of death and serious injury every year, and driver distraction or loss of
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`focus on the view ahead are leading causes of rear end collisions.
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`39. Second, the inboard lower location of the auxiliary reflective element
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`on a smaller mirror would conflict with the requirements of FMVSS. FMVSS 111
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`requires that a driver-side exterior mirror provides a unit magnification view of a
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`level road surface extending to the horizon from a line, perpendicular to a
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`longitudinal plane tangent to the driver’s side of the automobile at the widest point,
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`extending 8 feet out from the tangent plane 35 feet behind the driver’s eyes. Ex.
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`1040, 20. This target that must be visible in the driver-side mirror is depicted in
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`Fig. 15 of the ‘534 patent, which is reproduced below.
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`40. An auxiliary reflective element placed at the upper outboard portion
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`of the mirror assembly does not interfere with the FMVSS 111 requirement, as
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`shown in Fig. 15. However, an inboard lower auxiliary reflective element would
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`interfere, unless the mirror was large enough to allow for extra space below the
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`triangle-shaped region 240. A trailer towing mirror would typically be large
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`enough to accommodate Henion ‘013’s non-plano inboard lower auxiliary
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`reflective element and still meet the FMVSS 111 requirement via the large plano
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`(unit magnification) main reflective element. For this reason too, a POSA would
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`therefore have understood that Henion ‘013 discloses a trailer towing mirror.
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`C.
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`SMR Fails To Demonstrate A Motivation To Combine Henion
`‘013 And Platzer ‘956.
`41. SMR contends that a POSA would have been motivated to combine
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`Henion ‘013 with Platzer ‘956, predicating its argument on an assertion that they
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`both “disclose the same major components.” Petition, 47. However, Henion ‘013
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`and Platzer ‘956 are structurally very different. Platzer ‘956’s auxiliary reflective
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`element is located in “the upper and outer quadrant of the rearview mirror,” (Ex.
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`1013, 15:16-17), while the Figs. 1-4 embodiments of Henion ‘013 that SMR relies
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`on have a lower, inboard-located auxiliary mirror (Petition, 58). As discussed
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`above, the location of the auxiliary reflective element in Henion ‘013 informs a
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`POSA that Henion ‘013 discloses a trailer towing mirror. There is no motivation
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`for a POSA to start with a trailer towing mirror to arrive at the claimed inventions
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`of the ‘534 patent.
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`42. Moreover, the location of the auxiliary mirror affects the overall field
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`of view provided by the mirror assembly. A mirror assembly with an inboard
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`auxiliary mirror element, as depicted in Henion ‘013, is incapable of having the
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`field of view as depicted in Fig. 1 of Platzer ‘956, which illustrates the field of
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`view of Platzer ‘956’s angled mirror, because Fig. 1 depicts the field of view of an
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`assembly with an outboard-located auxiliary mirror element. For example, Fig. 1
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`of Platzer ‘956, which is reproduced below, shows that the fields of view of the
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`primary and auxiliary mirror elements do not overlap, which is only possible
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`because the auxiliary mirror is located at the outboard edge of the main mirror. If
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`an inboard auxiliary reflective element were similarly directed outward, then there
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`would necessarily be some degree of overlap between the fields of view of the two
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`mirror elements because the auxiliary field of view would begin at the inboard
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`edge of the main mirror element and cross over the main plano mirror element’s
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`field of view as it extends further outward from the main mirror element’s field of
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`view. Furthermore, such a mirror would be confusing and potentially dangerous,
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`as discussed above in ¶ 38.
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`43. Moreover, SMR does not address why a POSA would have plucked
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`certain features from Platzer ‘956 but not other features, other than the hindsight
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`from the impermissible use of the claims of the ‘534 patent as a roadmap. For
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`example, all of the claims of the ‘534 patent require overlap between the mirror
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`fields of view. Platzer ‘956, as depicted in Fig. 1 above, does not have any overlap
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`in the fields of view of its mirror elements. Ex. 1013, Fig. 1, 8:26-31, 12:9-11. If a
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`POSA were to look to Platzer ‘956 to determine the proper field of view of a
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`mirror assembly that is intended to solve the blind spot problem, then there is no
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`reason why a POSA would have relied on only the angular relationships between
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`the spotting mirror and primary mirror that Platzer ‘956 discloses. A POSA
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`relying on Platzer ‘956 would have adopted all of Platzer’ 956’s field of view
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`teachings, including the teaching to position the spotting mirror so that its field of
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`view does not overlap with the main mirror field of view. A mirror assembly with
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`such non-overlapping fields of view would not meet the claims of the ‘534 patent.
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`Patent Owner Magna - Ex. 2001, p. 21
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`All statements made herein of my own knowledgeare true, andall
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`statements made on information and belief are believed to be true. Further, I am
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`aware that these statements are made with the knowledgethat willful false
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`statements and the like so made are punishable by fine or imprisonment,or both,
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`—under 18U.S.C.§1001. I declare under penalty ofperjury that theforegoingis”
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`true and correct.
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`Date: Aen / 30 201g
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`gm
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`Patent Owner Magna- Ex. 2001, p. 22
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