IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`MASSACHUSETTS INSTITUTE
`OF TECHNOLOGY,and ETHANOL
`BOOSTING SYSTEMS, LLC,
`Plaintiffs,
`
`C.A. No. 19-cv-196-CFC-SRF
`JURY TRIAL DEMANDED
`
`Vv.
`
`FORD MOTOR COMPANY,
`
`Defendant.
`
`JOINT CLAIM CONSTRUCTION CHART
`
`Pursuant to Paragraph 15 of the Court’s Scheduling Order (D.I. 17), Plaintiffs
`
`Ethanol Boosting Systems, LLC and the Massachusetts Institute of Technology and
`
`Defendant Ford Motor Company(collectively, “the Parties”) jointly provide this
`
`Joint Claim Construction Chart (1) identifying for the Court the 7 terms and phrases
`
`that Ford has identified for construction and (2) setting forth each party’s proposed
`
`constructions with citations only to intrinsic evidence.
`
`As set forth in its invalidity contentions, and as identified in the initial
`
`exchange of claim terms for construction, Ford also believes that a numberof claim
`
`terms at issue in the patent are indefinite. However,it is the parties’ understanding
`
`that
`
`the Court prefers to address indefiniteness issues separately from claim
`
`FORDEx. 1144, page 1
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`construction. To the extent the Court would prefer to address indefiniteness issues
`
`at claim construction, the parties can supplement this document.
`
`TheParties also attach a separate text-searchable PDF of each of the patents
`
`in issue, as well as U.S. Patent Application No. 10/991,774—10 which each claims
`
`priority. Below is a key for such materials:
`
`5 6
`
`7,
`
`I.
`
`Agreed Claim Constructions
`
`The parties have stipulated to the following constructions for the following
`
`claim terms and respectfully request that the Court include these constructionsin its
`
`claim construction order:
`
`| Term
`Construction
`
`“port injection” / “port fuel injection”
`“injection of fuel into an intake
`port or intake manifold”
`
`
`
`
`' Because each of the asserted patents shares a common specification with that
`included in U.S. Patent Application No. 10/991,774, for the Court’s convenience the
`parties cite to this documentin lieu of the individual specifications.
`
`FORDEx. 1144, page 2
`IPR2020-00013
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`
`
`
`
`
`2 3 4
`
`
`Exhibit|Document Description
`U.S. Patent Application No. 10/991,774, dated November 18, 2004!
`| U.S. Patent No. 8,069,839 B2 (Cohn,et al.), dated December 6, 2011
`| U.S. Patent No. 9,255,519 B2 (Cohn,et al.), dated February 9, 2016
`U.S. Patent No. 9,810,166 B2 (Cohn,et al.), dated November 7, 2017
`,
`
`U.S. Patent No. 10,138,826 B2 (Cohn,et al.), dated November 27, 2018
`
`Excerpts of the File History for U.S. Patent Application No. 10/991,774
`(033 File History)
`
`Excerpts of the File History for U.S. Patent No. 9,810,166 B2 ('166 File
`History)
`
`

`

`
`[°839 (Claim 1), 7166 (Claims1, 19)]/[°839
`(Claim 7), °166 (Claims1, 7, 10-12, 19, 22-
`23), 826 (Claims 1, 12, 21, 31)]
`
`“direct injection” / “direct fuel injection”|“direct injection of fuel into a
`cylinder’?
`
`[°839 (Claims 1, 8), 166 (Claims 1, 5, 16,
`18, 19, 21-22, 26-28, 30), °826 (Claims1,
`12)] /[’166 (Claims 1, 19)]
`“first fueling system that directly injects
`Plain and ordinary meaning?
`fuel” / “first fueling system”/ “first
`fueling system that uses direct injection”
`
`[°519 (Claims 1, 13)] /[’519 (Claims 1-3, 5,
`10-11, 13-14, 16-18, 21, 24-25, 27-30), °826
`(Claims 2-4, 13-21, 23-26, 29-33)] / [’826
`(Claims 1, 12)]
`“second fueling system that injects fuel
`Plain and ordinary meaning
`into a region outside of the cylinder” /
`“second fueling system”/ “second fueling
`system using port fuel injection”
`
`
`
`
`
`
`[519 (Claim 1)] / [826 (Claims1, 12, 21,
`23, 24, 30, 31)] /[’826 (Claims21, 31)]
`
`* The parties agree that, by agreeing to this construction of the phrases “direct
`injection” and “direct fuel injection,” Ford has not waived its argumentthat the type
`of fuel required to be used in direct injection is a fuel that contains an anti-knock
`agentthat is not gasoline, and that is different from the fuel usedfor port injection/in
`the second fueling system.
`3 Theparties agree that, by agreeing to this construction ofthe phrases“first fueling
`system that directly injects fuel,” “first fueling system,” and “first fueling system
`that uses direct injection,” Ford has not waived its argumentthat each requiresa fuel
`that contains an anti-knock agent that is not gasoline, and that is different from the
`fuel used for port injection/in the second fueling system.
`
`3
`
`FORDEx. 1144, page 3
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`
`
`“employs spark retard so as to reduce the | “uses spark retard so as to reduce
`amount of fuel that is introduced into the|the amountof fuel thatis
`cylinder bythe first fueling system”
`introduced into the cylinder by
`direct injection”
`
`[?519 (Claim 1)]
`
`“spark retard is used so as to
`“spark retard is employed [to/so] as to
`reduce the amountoffuel that is provided|reduce to zero the amountoffuel
`by thefirst fueling system to zero”
`that is provided by direct
`injection”
`
`
`
`
`
`[519 (Claims2, 16)]
`“input”
`
`“information, including one or
`more signals”
`(7519 (Claim 13-14)]
`
`The parties further state that, to narrow the issues in dispute, Plaintiffs have
`
`agreed not to assert Claims 29 and 30 of U.S. Patent No. 10,138,826.
`
`II.
`
`Disputed Claim Constructions
`
`The following terms/phrases remain in dispute:
`
`1.
`
`“torque” [°839 (Claims 1-2, 7-8), °519 (Claims 1, 3-4, 6, 10-11, 15,
`18-20, 22, 26, 29), 166 (Claims 1-4, 7-8, 10, 14-16, 19-21, 23, 26-28),
`826 (Claim 1-8, 10-15, 20-24, 29-33)]
`Plaintiffs’ Construction:
`| Ford’s Construction:
`Plain and ordinary (no construction
`“Torque is the measure of a turning or
`needed).
`rotational force on an object. Torqueis
`calculated by multiplying force and
`distance. It is a vector quantity,
`Alternatively, if construed, “measure of
`a turning orrotating force on an object.”|Meaning it has both a direction and a
`magnitude.”
`
`
`
`Intrinsic Support:
`Intrinsic Support:
`e Ex. 2 (839 Patent) at 5:42-6:27;
`e Ex.
`1 (Orig. Appl.) at passim.
`Claims1, 2, 7, 8, 13, 15, 16, 19,
`
`FORD Ex. 1144, page 4
`IPR2020-00013
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`
`
`P|
`
`
`
`

`

`
`
`
`
`
`e Ex. 2 (839 Patent) at Claims 1-2,
`7-8,
`
`e Ex. 3 (519 Patent) at Claims 1, 3-
`4,6, 10-11, 15, 18-20, 22, 26, 29.
`e Ex. 4(7166 Patent) at Claims 1-4,
`7-8, 10, 14-16, 19-21, 23, 26-28.
`e Ex. 5 (826 Patent) at Claim 1-8,
`10-15, 20-24, 29-33.
`
`
`
`and 20.
`
`|
`|
`
`e Ex. 3 (519 Patent) at 5:61-6:45;
`Claims1, 3, 4, 6, 7, 10, 11, 15,
`18, 19, 20, 22, 26, and 29,
`° Ex.4(°166 Patent) at 6:4-55;
`Claims 1, 2, 3, 4, 6, 7, 8, 9, 10,
`14, 15, 16, 19, 20, 21, 23, 26, 27,
`28, and 29.
`e Ex. 5 (826 Patent) at 6:6-57;
`Claims 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
`11, 12, 13, 14, 15, 20, 21, 22, 23,
`24, 25, 28, 29, 30, 31, 32, and
`33,
`
`2.
`
`“torque range” [’519 (Claims 19, 20, 22), ’166 (Claims 1, 10, 14-16,
`20, 28, 29), °826 (Claims 1-15, 20-25, 28-33)] / “range of torque”
`[519 (Claims1, 4), 166 (Claims 7-8, 19)]
`
`
`Plaintiffs’ Construction:
`Plain and ordinary (no construction
`needed).
`
`
`Ford’s Construction:
`“a range of torque values from one
`specific value of torque to another
`specific value of torque”
`
`
`
` Intrinsic Support:
`
`Alternatively, if construed, “range of
`torque values from one value of torque
`to another value of torque.”
`
`Intrinsic Support:
`e Ex. 1 (Orig. Appl.) at 8:21-24,
`9:3-10.
`
`e Ex. 3 (’519 Patent) at Claim 20.
`e Ex. 4 (166 Patent) at Claim 8;
`see also Ex. 4 (166 Patent) at
`Claims 9, 10, 20, 29.
`e Ex. 5 (’826 Patent) at Claim 1;
`see also Ex. 5 (826 Patent) at
`Claims 12, 22-25, 30, 31.
`
`e Ex. 3 (519 Patent) at 5:61-6:62;
`Claims 1, 3, 4, 6, 7, 10, 11, 15,
`18, 19, 20, 22, 26, and 29.
`e Ex. 4 (166 Patent) at 6:4-7:5;
`Claims 1, 2, 3, 4, 6, 7, 8, 9, 10,
`14, 15, 16, 19, 20, 21, 23, 26, 27,
`28, and 29.
`e Ex. 5 (826 Patent) at 6:6-7:7;
`Claims 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
`11, 12, 13, 14, 15, 20, 21, 22, 23,
`24, 25, 28, 29, 30, 31, 32, and
`33,
`
`FORD Ex. 1144, page 5
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`3;
`
`“above a selected torque value the ratio of fuel that is directly
`injected to fuel that is port injected increases”[’839 (Claim 1)]
`
`Ford’s Construction:
`Plaintiffs’ Construction:
`“Above a selected torque value the
`ratio of fuel that 1s directly injected to
`fuel that 1s port injected 1s always
`
`Plain and ordinary (no construction
`needed).
`
`increasing” Intrinsic Support:
`
`
`1 (Orig. Appl.) at 4:17-26,
`e Ex.
`9:13-14, 5:25-26, 6:5-7, 10:16-20,
`12:8-9.
`
`e Ex. 2 (839 Patent) at Claims 1-6.
`e See also Ex. 6 (033 File History)
`at EBS00000018-28, at -21, -26;
`and EBS00000091-103, at -94,
`-100.
`
`Intrinsic Support:
`e Ex. 2 (839 Patent) at Abstract;
`1:29-32, 54-62; 3:2-12; 5:27-38;
`5:42-6:27; Claims 1, 2, 3, 4, 5, 6,
`7, 8, 15, 16, 17, 18, 19, 20; and
`Fig. 2.
`e Ex. 6 (’033 Patent Pros. History)
`at EBS00000034-38; and
`EBS00000054-103.
`
`
`
`|
`
`4,
`
`“fuel that is directly injected” [’839 (Claim 1)] / “directly injected
`fuel” [’839 (Claims 2-5)] / “fuel provided by direct injection”[’166
`(Claims 5, 16, 27, 28)] / “fueling that is provided by the first fueling
`system” [’826 (Claims 3-8)]/ “fueling from the first fueling system”
`[°166 (Claim 10)] / “fuel provided by thefirst fueling system” [’826
`(Claims 13-15)] / “fuel is provided by a first fueling system” [’826
`(Claim 31)]
`
`Plaintiffs’? Construction:
`
`Ford’s Construction: Plain and ordinary (no construction
`
`needed).
`
`‘‘a fuel that contains an anti-knock
`agent that is not gasoline, and that is
`different from the fuel used for port
`injection/in the second fueling system”
`
`Alternatively, if construed, “fuel is
`provided bya first fueling system using
`direct injection” [’826 (Claim 31)]
`should be construed to mean “‘fuel is
`directly injected into a cylinder” and the
`
`remaindershould be construed to mean
`
`FORD Ex. 1144, page 6
`[PR2020-00013
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`

`
`
`
`“fuel that is directly injected into a
`cylinder.”
`Intrinsic Support:
`Intrinsic Support:
`e Ex. 1 (Orig. Appl.) at 5:25-26,
`e Ex. 2 (°839 Patent) at Title;
`6:5-7, 3:5-8, 12:8-9; see also Ex.
`Abstract; 1:14-17, 42-62; 1:66-
`1 (Orig. Appl.) at 3:8-11, 5:1-2,
`2:40; 2:61-6:67; Claims 1, 2, 3,
`10:16-20, FIG. 3.
`4,5, 9, 10, 11, 15, 16, 17, 18, 19,
`e Ex. 2 (°839 Patent) at Claims 1, 8-
`20; Figs. 1, 2, 3, 4, and 5.
`11,15.
`e Ex. 4 (7166 Patent) at Title;
`e See also Ex. 6 (’033 File History)
`Abstract; 1:35-38, 1:65-2:19;
`at EBS00000018-28, at -21, -26;
`2:23-67; 3:21-7:25; Claims 1, 2,
`and EBS00000091-103, at -97-99.
`3, 4,5, 6, 7, 8, 9, 10, 11, 12, 13,
`e See also Ex. 7 (’166 File History)
`14, 15, 16,18, 19, 20, 21, 22, 23,
`at EBS00001959-75, at -1964,
`27, 28, 29, 30; Figs. 1, 2, 3, 4,
`1971-72.
`and 5.
`e Ex. 5 (826 Patent) at Title;
`Abstract; 1:38-41, 2:1-22; 2:26-
`3:3; 3:24-7:37; Claims1, 2, 3, 4,
`5, 6, 7, 8,9, 10, 11, 12, 13, 14,
`15, 16, 17, 18, 19, 20, 21, 22, 23,
`24, 25, 26, 27, 28, 29, 30, 31, 32,
`33; Figs. 1, 2,3, 4, and 5.
`e Ex. 6 (033 Patent Pros. History)
`at EBS00000034-38; and
`EBS00000054-103.
`
`
`
`
`
`
`
`e Ex. 7 (166 Patent Pros. History)
`at EBS-00001998-2033.
`
`“highest loads”[839 (Claim 6)]
`5.
`
`
` | Plaintiffs’ Construction: | Ford’s Construction:
`Plain and ordinary (no construction
`“Highest torques”
`needed).
`
`Alternatively, if construed, “engine’s
`highest torques at a given engine
`speed.”
`
`FORDEx. 1144, page 7
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`

`Intrinsic Support:
`e Ex.
`| (Orig. Appl.) at 8:22-25; see
`also Ex.
`1 (Orig. Appl.) at 8:6-
`9:11.
`
`Intrinsic Support:
`e Ex. 2 (°839 Patent) at 1:56-62;
`Claims 6 and 18.
`
`e Ex. 2 (839 Patent) at Claims 1, 6,
`18.
`
`e See also Ex. 7 (166 File History)
`at EBS00002038-45, at -2044-45.
`
`“decreases with decreasing torque” [’519 (Claim 1)]
`6.
`
`
`
`Plaintiffs’ Construction:
`Ford’s Construction:
`Plain and ordinary (no construction
`“always decreasing with decreasing
`needed).
`torque”
`Intrinsic Support:
`Intrinsic Support:
`e Ex.
`1 (Orig. Appl.) at 3:2-5, 9:12-
`e Ex.3 (7519 Patent) at Abstract;
`14; see also Ex.
`1 (Orig. Appl.) at
`1:47-50; 2:5-14; 3:21-31; 5:46-
`3:18-25, 4:21-27, 8:6-9:11.
`57; 5:61-6:45; Claims 1, 2, 3, 4,
`e Ex. 3 (°519 Patent) at Claims 1-3,
`5, 6, 7, 8, 9, 10, 11, 12, 13, 14,
`5-6, 9-11.
`15, 16, 17, 18, 19, 20, 21, 22, 23,
`e See also Ex. 6 (°033 File History)
`24, 25, 26, 27, 28, 29, 30, 31;
`at EBS00000018-28,at-21, -26:
`Fig. 2;
`and EBS00000091-103, at -97-
`e Ex. 6 (°033 Patent Pros. History)
`100.
`at EBS00000034-38; and
`EBS00000054-103.
`
`
`
`
`
`
`
`
`
` Plaintiffs’ Construction:
`
`7.
`
`“closed loop control that utilizes a sensor that detects knock” [’519
`(Claim 1)]/ “input from the knocksensor is utilized in a closed loop
`control system that controls”[’519 (Claim 14)] / “where closed loop
`control with a knock detector is used” [’519 (Claim 18)]
`
`
`Plain and ordinary (no construction
`needed).
`
`Ford’s Construction:
`‘‘a microprocessorthat uses a direct
`feedback input signal from a knock
`sensor” / “‘a direct feedback input
`Alternatively, if construed, “closed loop|Signal from the knocksensoris used by
`
`control thatutilizes a sensor that detects|4 Microprocessorto control” /“a direct
`knock” (Claim 1) should be construed to
`
`8
`
`FORD Ex. 1144, page 8
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`

`
`
`mean “a feedback system that uses a
`sensor that detects knock.”
`
`feedback input signal from the knock
`detector is used by a microprocessor”
`
`If construed, “where closed loop control
`with a knock detector is used” (Claim
`18) should be construed to mean “where
`a feedback system with a knock sensor
`
`
`If construed, “input from the knock
`sensoris utilized in a closed loop
`control system that controls” (Claim 14)
`should be construed to mean “input
`from the knock sensoris used by a
`feedback system that controls.”
`
`is used.”
`
`Intrinsic Support:
`e Ex.
`1 (Orig. Appl.) at 3:18-25,
`4:21-27, 9:26-28, FIG 1 & 5.
`e Ex.3(’519 Patent) at Claims1, 2,
`5, 10, 13, 14, 18, 19, 24, 25, 27,
`29.
`e See also Ex. 6 (033 File History)
`at EBS00000091-103, at -99-100.
`e See also Ex. 7 (’166 File History)
`at EBS00002038-45, at -44-45.
`
`
`
` Intrinsic Support:
`
`e Ex.3 (519 Patent) at 2:35-45;
`3:13-31; Claims 1, 13, 14, 18,
`19, 24, 25, 29; Figs 1 and 5.
`
`
`
`FORDEx. 1144, page 9
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`Dated: September 24, 2019
`
`Respectfully submitted,
`
`FARNAN LLP
`
`/s/ Michael J. Farnan
`Brian E. Farnan (Bar No. 4089)
`MichaelJ. Farnan (Bar No. 5165)
`919 North MarketStreet, 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`(302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farmanlaw.com
`
`Attorneys for Plaintiff
`
`Morris, NICHOLS, ARSHT &TUNNELL
`LLP
`
`/s/ Rodger D. SmithII
`Rodger D. Smith II (#3778)
`Michael J. Flynn (#5333)
`Taylor M. Haga (#6549)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`rsmith@mnat.com
`mflynn@mnat.com
`thaga@mnat.com
`
`Attorneys for Defendant
`
`FORDEx. 1144, page 10
`IPR2020-00013
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`

`EXHIBIT |
`
`FORDEx. 1144, page 11
`IPR2020-00013
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`

`JOINT
`
`APPLICATION
`
`FOR
`
`UNITED STATES LETTERS PATENT
`
`TO THE ASSISTANT COMMISSIONER FOR PATENTS:
`
`BE IT KNOWN,that we,
`
`Daniel R. Cohn, Chestnut Hill, Massachusetts
`
`Leslie Bromberg, Sharon, Massachusetts
`
`John B, Heywood, Newton, Massachusetts
`
`have invented certain new and useful improvements in Fuel Management System for
`
`Variable Ethanol Octane Enhancement of Gasoline Engines of which the followingis a
`
`specification:
`
`Attlomey Docket No.: 0492611-0598
`Express Mali No. EV196632874US
`Date of Filing: November 18, 2004
`Customer Number: 24280
`
`EBS-00000175
`
`FORD Ex. 1144, page 12
`IPR2020-00013
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`

`Fuel Management System for Variable Ethanol Octane Enhancement
`
`of Gasoline Engines
`
`Background of the Invention
`
`This invention relates to spark ignition gasoline engines utilizing an antiknock agent
`whichis a liquid fuel with a higher octane numberthan gasoline such as ethanol to improve
`
`engine efficiency.
`
`It is knownthat the efficiency of spark ignition (SI) gasoline engines can be increased by
`
`high compressionratio operation andparticularly by engine downsizing. The engine downsizing
`
`is made possible by the use of substantial pressure boosting from either turbocharging or
`
`supercharging. Such pressure boosting makesit possible to obtain the same performancein a
`significantly smaller engine. See, J. Stokes, et al., “A Gasoline Engine Concept For Improved
`
`Fuel Economy — The Lean-Boost System,” SAE Paper 2001-01-2902. The use of these
`
`techniques to increase engineefficiency, however,is limited by the onset of engine knock.
`
`Knock is the undesired detonation of fuel and can severely damage an engine. If knock can be
`
`prevented, then high compressionratio operation and high pressure boosting can be used to
`
`10
`
`15
`
`increase engine efficiency by up to twenty-five percent.
`
`Octane numberrepresents the resistance of a fuel to knocking but the use ofhigher
`
`octane gasoline only modestly alleviates the tendency to knock. For example,the difference
`
`between regular and premium gasolineis typically six octane numbers. Thatis significantly less
`
`20
`
`than is neededto realize fully the efficiency benefits of high compressionratio or turbocharged
`
`operation. Thereis thus a need for a practical means for achieving a much higher level of octane
`
`enhancementso that engines can be operated much moreefficiently.
`
`It is known to replace a portion of gasoline with small amounts of ethanol addedat the
`
`refinery, Ethanol has a blending octane number (ON) of 110 (versus 95 for premium gasoline)
`(see J.B. Heywood,“Internal Combustion Engine Fundamentals,” McGraw Hill, 1988, p. 477)
`
`25
`
`andis also attractive becauseit is a renewable energy, biomass-derived fuel, but the small
`
`amounts of ethanol that have heretofore been added to gasoline have had a relatively small
`
`impact on engine performance. Ethanol is much more expensive than gasoline and the amount
`
`of ethanolthat is readily available is much smaller than that of gasoline becauseoftherelatively
`limited amount of biomass that is available for its production. An object of the present invention
`
`30
`
`Attomey Docket No.: 0492611-0598
`Express Mall No. EV196632874US
`Date of Filling: Novamber 18, 2004
`Customer Number: 24280
`
`Page 2 of 14
`
`EBS-00000176
`
`FORD Ex. 1144, page 13
`IPR2020-00013
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`

`is to minimize the amountofethanolor other antiknock agentthat is used to achieve a given
`level of engine efficiency increase. Byrestricting the use of ethanolto the relatively small
`fraction of timein an operating cycle whenit is needed to prevent knockin a higher load regime
`and by minimizingits use at these times, the amountofethanolthat is required can be limited to
`a relatively small fraction of the fuel used by the spark ignition gasoline engine.
`
`Summary ofthe Invention
`In one aspect, the invention is a fuel managementsystem forefficient operation of a
`spark ignition gasoline engine including a source of an antiknock agent such as ethanol. An
`injector directly injects the ethanol into a cylinder of the engine and a fuel management system
`controls injection of the antiknock agent into the cylinder to control knock with minimum use of
`the antiknock agent. A preferred antiknock agent is ethanol. Ethanol has a high heat of
`vaporization so that there is substantial cooling ofthe air-fuel charge to the cylinder whenit is
`injected directly into the engine. This cooling effect reduces the octane requirementofthe
`engine by a considerable amountin addition to the improvement in knockresistance from the
`relatively high octane numberof ethanol. Methanol, tertiary butyl alcohol, MTBE, ETBE,and
`
`TAMEmayalso be used. Wherever ethanol is used herein it is to be understood that other
`
`antiknock agents are contemplated.
`
`The fuel management system uses a fuel management control system that may use a
`
`microprocessor that operates in an open loop fashion on a predetermined correlation between
`
`20
`
`octane number enhancementand fraction of fuel provided by the antiknock agent. To conserve
`
`the ethanol, it is preferred that it be added only during portions of a drive cycle requiring knock
`
`resistance and that its use be minimized during these times. Alternatively, the gasoline engine
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`may include a knock sensorthat provides a feedback signal to a fuel management
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`microprocessor system to minimize the amountof the ethanol added to prevent knockin a closed
`
`25
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`loop fashion.
`
`In one embodimentthe injectorsstratify the ethanol to provide non-uniform deposition
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`within a cylinder. For example, the ethanol may be injected proximate to the cylinder walls and
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`swirl can create a ring of ethanol near the walls.
`
`In another embodimentof this aspect of the invention, the system includes a measure of
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`30
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`the amountof the antiknock agent such as ethanol in the source containing the antiknock agentto
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`control turbocharging, supercharging or spark retard when the amount ofethanolis low.
`Page 3 of 14
`
`Altorey Docket No.: 0492611-0598
`Express Mall No. EV186632874US
`Date of Fillng: November 18, 2004
`Customer Number: 24280
`
`EBS-00000177
`
`FORDEx. 1144, page 14
`IPR2020-00013
`
`

`

`The direct injection of ethanol provides substantially a 13°C drop in temperature for
`
`every ten percentof fuel energy provided by ethanol. An instantaneous octane enhancementof
`at least 4 octane numbers maybeobtained for every 20 percent ofthe engine’s energy coming
`from the ethanol.
`
`Brief Description of the Drawing
`
`Fig. 1 is a block diagram of one embodimentofthe invention disclosedherein.
`
`Fig. 2 is a graph of the drop in temperature within a cylinder as a function of the fraction
`
`of energy provided by ethanol.
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`Fig. 3 is a schematicillustration ofthe stratification of cooler ethanol chargeusing direct
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`injection and swirl motion for achieving thermal stratification.
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`Fig. 4 is a schematic illustration showing ethanol stratified in an inlet manifold.
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`Fig. 5 is a block diagram of an embodimentof the invention in which the fuel
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`management microprocessoris used to control a turbocharger and spark retard based upon the
`amountof ethanol in a fuel tank.
`
`15
`
`Description of the Preferred Embodiment
`
`With reference first to Fig. 1, a spark ignition gasoline engine 10 includes a knock sensor
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`12 and a fuel management microprocessor system 14. The fuel management microprocessor
`system 14 controls the direct injection of an antiknock agent such as ethanol from anethanol
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`tank 16. The fuel management microprocessor system 14 also controls the delivery of gasoline
`from a gasoline tank 18 into engine manifold 20. A turbocharger 22 is provided to improvethe
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`20
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`torque and powerdensity of the engine 10. The amountof ethanol injection is dictated cither by
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`a predetermined correlation between octane number enhancement andfraction of fuel that is
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`provided by ethanol!in an open loop system or by a closed loop control system that uses a signal
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`from the knock sensor 12 as afi inpiit to ine fuel management microprocessor 14. In both
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`25
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`situations, the fuel managementprocessor 14 will minimize the amount ofethanol added to a
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`cylinder while still preventing knock. It is also contemplated that the fuel management
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`microprocessor system 14 could provide a combination of open and closed loop control.
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`As show in Fig.1 it is preferred that ethanol be directly injected into the engine 10.
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`Direct injection substantially increases the benefits of ethanol addition and decreases the required
`
`Attomey Docket No.: 0492611-0596
`Express Mall No. EV196632874US
`Date of Filing: November 18, 2004
`Customer Number: 24280
`
`Page 4 of 14
`
`EBS-00000178
`
`FORD Ex. 1144, page 15
`IPR2020-00013
`
`

`

`amountof ethanol. Recent advancesin fuel injector and electronic control technology allows
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`fue) injection directly into a spark ignition engine rather than into the manifold 20. Because
`ethanol has a high heat of vaporizationthere will be substantial cooling whenitis directly
`injected into the engine 10. This cooling effect further increases knockresistance by a
`considerable amount. In the embodimentof Fig. 1 port fuel injection of the gasoline in which
`the gasolineis injected into the manifold rather than directly injected into the cylinderis
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`preferred becauseit is advantageousin obtaining good air/fuel mixing and combustionstability
`
`that are difficult to obtain with direct injection.
`
`Ethanolhas a heat of vaporization of 840kJ/kg, while the heat of vaporization of gasoline
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`is about 350kJ/kg. The attractiveness of ethanol increases when compared with gasoline on an
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`energy basis, since the lower heating value of ethanol is 26.9MJ/kg while for gasoline it is about
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`44MJ/kg. Thus, the heat of vaporization per Joule of combustion energy is 0.031 for ethanol and
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`0.008 for gasoline. Thatis, for equal amounts of energy the required heat of vaporization of
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`ethanol is about four times higherthanthat of gasoline. The ratio of the heat of vaporization per
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`15
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`unit air required for stoichiometric combustion is about 94 kJ/kg ofair for ethanol! and 24 kJ/kg
`
`of air for gasoline, or a factor of four smaller. Thus, the net effect of cooling the air chargeis
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`about four times lower for gasoline than for ethanol (for stoichiometric mixtures wherein the
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`amountofair contains oxygen that is just sufficient to combustall of the fuel).
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`20
`
`25
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`In the case of ethanoldirect injection according to one aspect of the invention, the charge
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`is directly cooled. The amountof cooling due to direct injection of ethanol is shown in Fig. 2.
`
`It
`
`is assumed that the air/fuel mixture is stoichiometric without exhaust gas recirculation (EGR),
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`and that gasoline makesupthe rest of the fuel. It is further assumed that only the ethanol
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`contributes to charge cooling. Gasoline is vaporized in the inlet manifold and does not
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`contribute to cylinder charge cooling. The direct ethanolinjection provides about 13°C of
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`cooling for each 10% ofthe fuel energy provided by ethanol.
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`It is also possible to use direct
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`injection of gasoline as well as direct injection of ethanol. However, under certain conditions
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`there can be combustion stability issues.
`
`The temperature decrement because of the vaporization energy of the ethanol decreases
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`with lean operation and with EGR, as the thermal capacity of the cylinder charge increases. If
`
`Attorney Docket No.: 0492611-0598
`Express Mall No. EV196632874US
`Date of Fillng: November 18, 2004
`Customer Number: 24280
`
`Page 5 of 14
`
`EBS-00000179
`
`FORD Ex. 1144, page 16
`IPR2020-00013
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`

`

`the engine operates at twice the stoichiometric air/fuel ratio, the numbersindicated in Fig. 2
`decrease by abouta factorof 2 (the contribution ofthe ethanolitself and the gasolineis relatively
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`modest). Similarly, for a 20% EGRrate, the cooling effect of the ethanol decreases by about
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`25%.
`
`The octane enhancementeffect can be estimated from the data in Fig. 2. Direct injection
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`of gasoline results in approximately a five octane number decrease in the octane numberrequired
`
`by the engine, as discussed by Stokes, ef a/. Thus the contributionis aboutfive octane numbers
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`per 30K drop in charge temperature. As ethanol can decrease the charge temperature by about
`
`120K,then the decrease in octane numberrequired by the engine dueto the drop in temperature,
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`for 100% ethanol, is twenty octane numbers. Thus, when 100% ofthe fuel is provided by
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`ethanol, the octane number enhancementis approximately thirty-five octane numbers with a
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`twenty octane number enhancement coming from direct injection cooling and a fifteen octane
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`number enhancement coming from the octane numberof ethanol. From the above
`
`considerations, it can be projected that evenif the octane enhancementfrom direct cooling is
`
`15
`
`significantly lower, a total octane number enhancementofat least 4 octane numbers should be
`
`achievable for every 20% ofthetotal fuel energy that is provided by ethanol.
`
`Alternatively the ethanol and gasoline can be mixed together and then port injected
`
`through a single injector per cylinder, thereby decreasing the numberof injectors that would be
`
`used. However, the air charge cooling benefit from ethanol would belost.
`
`20
`
`Alternatively the ethanol and gasoline can be mixed together and then port fuel injected
`
`using a single injector per cylinder, thereby decreasing the numberofinjectors that would be
`
`used, However, the substantial air charge cooling benefit from ethanol would be lost. The
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`volume of fuel between the mixing pointand the port fuel injector should be minimized in order
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`to meet the demanding dynamic octane-emiaiceient requirements of the engine.
`
`25
`
`Relatively precise determinations of the actual amount of octane enhancement from given
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`amountsof direct ethanol injection can be obtained from laboratory and vehicle tests in addition
`
`to detailed calculations. These correlations can be used by the fuel management microprocessor
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`system 14.
`
`Attorney Docket No.: 0492611-0598
`Express Mail No. EV196632874US
`Date of Filing: November 18, 2004
`Customer Number: 24280
`
`Page 6 of 14
`
`EBS-00000180
`
`FORD Ex. 1144, page 17
`IPR2020-00013
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`

`

`An additional benefit of using ethanol for octane enhancementis the ability to use it ina
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`mixture with water. Such a mixture can eliminate the need for the costly and energy consuming
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`water removal step in producing pure ethanol that must be employed when ethanolis added to
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`gasoline at a refinery. Moreover, the water provides an additional cooling (due to vaporization)
`
`that further increases engine knockresistance.
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`In contrast the present use of ethanol as an
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`additive to gasoline at the refinery requires that the water be removed from the ethanol.
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`Since unlike gasoline, ethanol is not a good lubricant and the ethanol fuel injector can
`
`stick and not open, it is desirable to add a lubricant to the ethanol. The lubricant will also
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`denature the ethanol and make it unattractive for human consumption.
`
`10
`
`Further decreases in the required ethanol for a given amountof octane enhancement can
`
`be achieved with stratification (non-uniform deposition) of the ethanol addition. Directinjection
`
`can be used to place the ethanol near the walls of the cylinder where the need for knock
`
`reduction is greatest. The direct injection may be used in combination with swirl. This
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`stratification of the ethanolin the engine further reduces the amountof ethanol needed to obtain
`a given amount of octane enhancement. Because only the ethanolis directly injected and
`becauseit is stratified both by the injection process and by thermalcentrifugation, the ignition
`stability issues associated with gasoline direct injection (GDI) can be avoided.
`
`20
`
`25
`
`It is preferred that ethanol be added to those regions that make up the end-gas andare
`prone to auto-ignition. These regions are near the walls of the cylinder, Since the end-gas
`contains on the order of 25% ofthe fuel, substantial decrements in the required amounts of
`ethanol can be achieved bystratifying the ethanol.
`
`In the case of the engine 10 having substantial organized motion (such as swirl), the
`cooling will result in forces that thermally stratify the discharge (centrifugal senaration of the
`regions at different density due to different temperatures). The cffect of ethanol addition is to
`increase gas density since the temperature is decreased. With swirl the ethanol mixturewill
`
`automatically move to the zone where the end-gas is, and thus increase the anti-knock
`effectiveness of the injected ethanol. The swirl motion is not affected much by the compression
`stroke and thus survivesbetter than tumble-like motion that drives turbulence towards top-dead-
`center (TDC) andthen dissipates. It should be pointed out that relatively modest swirls result in
`
`Attomey Docket No.; 0492611-0598
`Express Mall No. EV196632874US
`Date ofFiling: November 18, 2004
`Customer Number: 24260
`
`Page 7 of 14
`
`EBS-00000181
`
`FORD Ex. 1144, page 18
`IPR2020-00013
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`

`

`large separating (centrifugal) forces. A 3m/s swirl motion in a 5cm radius cylinder generates
`accelerations of about 200m/s”, or about 20g’s.
`
`Fig. 3 illustrates ethanol direct injection and swirl motion for achieving thermal
`
`stratification. Ethanol is predominantly on an outside region which is the end-gas region. Fig. 4
`
`illustrates a possible stratification of the ethanolin an inlet manifold with swirl motion and
`
`thermal centrifugation maintaining stratification in the cylinder. In this case ofport injection of
`
`ethanol, however, the advantage of substantial charge cooling maybelost.
`
`With reference again to Fig. 2, the effect of ethanol addition all the way up to 100%
`
`ethanolinjection is shown. Atthe point that the engine is 100% direct ethanol injected, there
`
`maybe issues of enginestability when operating with only stratified ethanol injection that need
`
`to be addressed. In the caseofstratified operation it may also be advantageousto stratify the
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`injection of gasoline in order to providearelatively uniform equivalence ratio across the cylinder
`
`(and therefore lower concentrations of gasoline in the regions where the ethanolis injected).
`
`This situation can be achieved,as indicated in Fig. 4, by placing fuel in the region of the inlet
`
`manifold that is void of ethanol.
`
`The ethanol used in the invention can either be contained in a separate tank from the
`
`gasoline or may b