Case 2:18-cv-00320-MSD-LRL Document 31-11 Filed 11/01/18 Page 1 of 4 PageID# 280
`
`Exhibit K
`
`Jaguar Land Rover Ltd.
`Exhibit 2015
`Bentley v. Jaguar
`IPR2019-01502
`
`Ex. 2015-0001
`
`

`

`Case 2:18-cv-00320-MSD-LRL Document 31-11 Filed 11/01/18 Page 2 of 4 PageID# 281
`
`Nothing in its way: The Land Rover LR3 can go anywhere you want thanks
`to the new Terrain Response system
`
`The Gazette (Montreal)
`
`November 15, 2004 Monday, Final Edition
`
`Copyright 2004 CanWest Interactive, a division of CanWest Global Communications Corp. All Rights Reserved
`
`Section: DRIVING; Pg. E5
`
`Length: 883 words
`
`Byline: JOHN LeBLANC, CanWest News Service
`
`Body
`
`At the North American launch of the all-new Land Rover LR3, you quickly got a sense from the marketing folks that
`this was a big deal.
`
`The LR3 is the first Land Rover developed under the stewardship of the Ford Motor Company, which bought the
`British marque from BMW in 2000. The LR3 is one of only nine models introduced since 1948, and the first to be
`launched in an urban setting.
`
`Effectively replacing the aging Discovery model (the LR3 label is only being used in Canada and the U.S.), the LR3
`is entering a very crowded sport-utility vehicle arena, with traditional SUV buyers moving toward more car-like
`vehicles faster than the price of gas can rise at the pumps.
`
`To be successful, the new LR3 needs to be outstanding.
`
`"And we think it is,'' confided the executive vice-president of Land Rover North America, Richard Beattie. He
`described the LR3 as "a true Land Rover, benefiting from its clean design, versatility and outstanding driving
`experience.''
`
`Externally, you might mistake the LR3 for the granddaddy Range Rover. Believe me, the likeness is intentional.
`
`LR3 design director Geoff Upex emphasized that the LR3 was designed from the inside, prioritizing passenger
`comfort and ergonomics with a fold-flat interior and optional seating for up to seven adults.
`
`The interior roominess betters such midsize premium SUV competitors as Lexus's GX 470. Much of this packaging
`success can be attributed to what Land Rover calls its integrated body-frame body structure, unique to Land Rover
`and quelling any rumours that the LR3 is based on a Ford Explorer.
`
`Combining the benefits of a stiff monocoque with the strength and off-road toughness of a traditional separate
`chassis frame, the LR3's structure allows Land Rover to aspire to sedan-like on-road attributes, while continuing its
`expected high standards of off-road performance.
`
`To substantiate Beattie's claims, Land Rover had journalists battle morning traffic in Montreal as a way to get to the
`extremely off-road Land Rover Experience Driving School, just north of Montebello.
`
`On pavement, the LR3 was very responsive, due largely to the most powerful Land Rover engine ever. All LR3s
`come with a new 4.4-litre derivative of Jaguar's 4.2-litre V-8 engine that yields 300 horsepower and 315 pound-feet
`of torque in the LR3.
`
`Ex. 2015-0002
`
`

`

`Case 2:18-cv-00320-MSD-LRL Document 31-11 Filed 11/01/18 Page 3 of 4 PageID# 282
`Page 2 of 3
`Nothing in its way: The Land Rover LR3 can go anywhere you want thanks to the new Terrain Response
`system
`
`The engine is mated to a six-speed, automatic transmission with CommandShift (what Land Rover titles its
`manumatic function) and a two-speed transfer case with an electronically lockable centre differential. As with all
`Land Rover vehicles, the LR3 has permanent four-wheel-drive, with power normally split 50/50 between axles.
`
`I certainly felt all 2,629 kilograms of the LR3's weight on some of the twisty rural Quebec back roads. The LR3
`doesn't have the same sort of dexterity as some of the new car-based SUVs, such as Cadillac's SRX or Infiniti's
`FX45, but those vehicles would be shaking in their radials if presented with what Land Rover had planned for us
`later in the day.
`
`In an afternoon spent tilting the LR3 sideways at angles exceeding 30 degrees, plowing through bogs and slithering
`down mudslides, the LR3 - unlike its driver - never complained or felt challenged.
`
`Partnering with veteran Land Rover Experience trainer Don Floyd (better known to me now as "God''), and with the
`new LR3's technological "helpers,'' my confidence grew quickly as our caravan of LR3s progressed through the
`challenging course.
`
`Land Rover fans are already familiar with Hill Descent Control (HDC), which lets you crawl your way down the
`steepest grade without having to use your brakes or ruin a good pair of shorts. The new, really gee-whiz party trick
`on the LR3 is what Land Rover calls Terrain Response.
`
`With a dial on the console, the driver can select from five modes ranging from "Mud and Ruts'' to "Sand and
`Dunes.'' Terrain Response then optimizes the various electro-mechanical bits built into the LR3. Based on how
`most SUV drivers use their vehicles, I looked for the "Malls and Schools'' setting, to no avail.
`
`Before attempting to get my LR3 up a near vertical wall with boulders the size of grizzly bears, God, er, Floyd, had
`me engage the "Rock Crawl'' setting. This adjusted the traction control, electronic throttle, HDC, ride height, antilock
`braking and centre and rear differentials for maximum performance. It also had me looking like Sir Edmund Hillary,
`minus the frostbite.
`
`Bruce Rosen, vice-president of marketing for Land Rover Canada, mentioned that the company rolled over almost
`6.5 million kilometres testing the new LR3, more than any other previous model. After trials in northern Ontario,
`Land Rover wisely made the cold climate package (heated front windshield and wipers) standard on Canadian
`LR3s.
`
`When the LR3 goes on sale this fall, Land Rover will be asking $61,900 for the SE and $67,900 for the HSE, which
`adds a touchscreen, voice-activated navigation system, upgraded audio, bigger wheels and tires, Bi-xenon
`headlights and memory seats.
`
`That's a noticeable step up from current Discovery pricing, but for the best Land Rover ever, consider it a big deal.
`
`--------
`
`2005 Land Rover LR3
`
`Price: $61,900 to $67,900
`
`Arriving: This fall
`
`Engine: 4.4-litre, V-8
`
`Power: 300 horsepower
`
`315 pound-feet of torque
`
`Notables:
`
`Ex. 2015-0003
`
`

`

`Case 2:18-cv-00320-MSD-LRL Document 31-11 Filed 11/01/18 Page 4 of 4 PageID# 283
`Page 3 of 3
`Nothing in its way: The Land Rover LR3 can go anywhere you want thanks to the new Terrain Response
`system
`
`Terrain Response electronic mechanical controls.
`
`Optional seating for seven.
`
`Ottawa Citizen
`
`Graphic
`
`Color Photo: COURTESY OF FORD; The Land Rover LR3, the company's new entry into the SUV segment, has
`off-road ruggedness and on-road drivability.
`
`Load-Date: November 15, 2004
`
`End of Document
`
`Ex. 2015-0004
`
`