IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`
`MASSACHUSETTS INSTITUTE
`
`OF TECHNOLOGY, and ETHANOL
`BOOSTING SYSTEMS, LLC,
`
`CA. No. 19-cv-196-CFC-SRF
`
`Plaintiffs,
`
`JURY TRIAL DEMANDED
`
`v.
`
`FORD MOTOR COMPANY,
`
`Defendant.
`
`JOINT CLAIM CONSTRUCTION CHART
`
`Pursuant to Paragraph 15 of the Court’s Scheduling Order (BI. 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 number of 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
`
`FORD Ex. 1144, page 1
`IPR2020-00013
`
`

`

`construction. To the extent the Court would prefer to address indefiniteness issues
`
`at claim construction, the parties can supplement this document.
`
`The Parties 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—to which each claims
`
`priority. Below is a key for such materials:
`
`Exhibit
`
`Document Description
`
`1 .
`
`
`U.S. Patent Application No. 10/991,774, dated November 18, 20041
`I U.S. Patent No. 8,069,839 B2 (Cohn, et al.), dated December 6, 2011
`
`I U.S. Patent No. 9,255,519 B2 (Cohn, et a1), dated February 9, 2016
`
`l—____
`
`.
`
`U.S. Patent No. 9,810,166 B2 (Cohn, et a1), dated November 7, 2017
`
`2 3 4
`
`
`
`
`
` ,—
`U.S. Patent No. 10,138,826 B2 (Cohn, et al.), dated November 27, 2018
`Excerpts ofthe File History for U.S. Patent Application No. 10/991,774 I
`
`(’033 File History)
`|
`
`5 6
`
`7.
`
`Excerpts of the File History for U.S. Patent No. 9,810,166 B2 (’166 File
`History)
`
`
`
`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 constructions in its
`
`claim construction order:
`
`
`
`|_ Term
`Construction
`
`1
`
`“injection of fuel into an intake
`“port injection” / “port fuel injection”
`
`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 Couit’s convenience the
`parties cite to this document in lieu ofthe individual specifications.
`
`FORD Ex. 1144, page 2
`IPR2020-00013
`
`

`

`
`
`[’839 (Claim 1), ’166 (Claims 1, 19)] / [’839
`(Claim 7), ’166 (Claims 1, 7, 10-12, 19, 22-
`
`23), ’826 (Claims 1, 12,21, 31)]
`
`“direct injection” / “direct fuel injection”
`
`“direct injection of fuel into a
`cylinder”2
`
`[’839 (Claims 1, 8), ’166 (Claims 1,5, 16,
`18, 19, 21-22, 26-28, 30), ’826 (Claims 1,
`12)] / [’166 (Claims 1, 19)]
`
`“first fueling system that directly injects
`fuel” / “first fueling system” / “first
`fueling system that uses direct injection”
`
`Plain and ordinary meaning3
`
`[’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
`into a region outside of the cylinder” /
`“second fueling system” / “second fueling
`system using port fuel injection”
`
`Plain and ordinary meaning
`
`[’519 (Claim 1)] / [’826 (Claims 1, 12, 21,
`
`23, 24, 3o, 31)] / [’826 (Claims 21, 31)]
`
`2 The parties agree that, by agreeing to this construction of the phrases “direct
`injection” and “direct fuel injection,” Ford has not waived its argument that the type
`of fuel required to be used in direct injection is 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.
`
`3 The parties agree that, by agreeing to this construction of the phrases “first fueling
`system that directly injects fuel,” “first fueling system,” and “first fueling system
`that uses direct injection,” Ford has not waived its argument that each requires 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.
`
`3
`
`FORD Ex. 1144, page 3
`IPR2020-00013
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`

`

`
`
`“employs spark retard so as to reduce the
`amount of fuel that is introduced into the
`
`“uses spark retard so as to reduce
`the amount of fuel that is
`
`cylinder by the first fueling system”
`
`introduced into the cylinder by
`direct injection”
`
`[’519 (Claim 1)]
`
`“spark retard is employed [to/so] as to
`reduce the amount of fuel that is provided
`by the first fueling system to zero”
`
`[’519 (Claims 2, 16)]
`
`“spark retard is used so as to
`reduce to zero the amount of fuel
`that is provided by direct
`injection”
`
`
`
`
`
`“input”
`
`“information, including one or
`more signals”
`[’519 (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 US. 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:
`Plain and ordinary (no construction
`needed).
`
`I Ford’s Construction:
`“Torque is the measure ofa turning or
`rotational force on an object. Torque is
`calculated by multiplying force and
`distance. it is a vector quantity,
`Alternatively, if construed, “measure of
`a turning or rotating force on an object.” meanlng It has bOth a directlon and a
`magnitude.”
`
`_j
`
`
`
`Intrinsic Support:
`
`Intrinsic Support:
`
`
`
`1- Ex. 2 (’839 Patent) at 5:42-6:27;
`1 (Orig. App1.)atpassim.
`0 Ex.
`
`Claims 1, 2, 7, 8, 13, 15, 16, 19,
`
`
`
`FORD Ex. 1144, page 4
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`

`

`
`
`
`
`
`
`
`
`Ex. 2 (’839 Patent) at Claims 1-2,
`7—8.
`
`Ex. 3 (’519 Patent) at Claims 1, 3-
`4, 6, 10-11, 15, 18-20, 22, 26, 29.
`
`Ex. 4 (’166 Patent) at Claims 1-4,
`7-8,10,14-16,19—21,23,26—28.
`
`Ex. 5 (’826 Patent) at Claim 1—8,
`10—15,20-24,29-33.
`
`and 20.
`
`Ex. 3 (’519 Patent) at 5:61-6:45;
`Claims 1, 3, 4, 6, 7, 10, 11, 15,
`18, 19, 20, 22,26, and 29.
`Ex. 4 (’166 Patent) at 624-55;
`Claims 1, 2, 3, 4, 6, 7, 8, 9, 10,
`14,15,16,19,20,21,23,26,27,
`
`1
`'
`
`28, and 29.
`
`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.
`
`“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 (Claims 1, 4), ’166 (Claims 7-8, 19)]
`
`
`
`
`Plaintiffs’ Construction:
`
`
`Ford’s Construction:
`
`Plain and ordinary (no construction
`needed).
`
`“a range of torque values from one
`specific value of torque to another
`specific value oftorque”
`
`Alternatively, if construed, “range of
`torque values from one value of torque
`
`to another value of torque.”
`
`Ex. 3 (’519 Patent) at 5:61-6:62;
`Claims 1, 3, 4, 6, 7, 1o, 11, 15,
`
`18, 19,20, 22,26, and 29.
`
`Intrinsic Support:
`
`Ex. 1 (Orig. Appl.) at 8:21-24,
`9:3-10.
`
`EX. 3 (’519 Patent) at Claim 20.
`
`Ex. 4 (’166 Patent) at Claim 8;
`see also Ex. 4 (’166 Patent) at
`Claims 9, 10, 20, 29.
`
`Ex. 5 (’826 Patent) at Claim 1;
`see also Ex. 5 (’826 Patent) at
`Claims 12, 22-25, 30, 31.
`
`24, 25,28, 29, 30, 31, 32, and
`
`33.
`
`
`
`
`
` Intrinsic Support:
`
`Ex. 4 (’166 Patent) at 6:4—7z5;
`Claims 1, 2, 3, 4, 6, 7, 8, 9, 10,
`
`14,15,16,19, 20, 21, 23,26, 27,
`
`28, and 29.
`
`Ex. 5 (’826 Patent) at 6:6—727;
`Claims 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
`
`11, 12, 13, 14, 15, 20, 21,22, 23,
`
`FORD Ex. 1144, page 5
`lPR2020-00013
`
`

`

`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:
`
`Plain and ordinary (no construction
`needed).
`
`“Above a selected torque value the
`ratio of fuel that is directly injected to
`fuel that is port injected is always
`
`increasing” Intrinsic Support:
`
`
`Intrinsic Support:
`
`1 (Orig. Appl.) at 4:17-26,
`0 Ex.
`9:13-14,5:25-26,6:5-7,10:16-20,
`12:8—9.
`
`0 Ex. 2 (’839 Patent) at Claims 1—6.
`
`0 See also Ex. 6 (’033 File History)
`at EBS00000018—28, at -21, ~26;
`
`and EBSOOOOOO91—103, at —94,
`—100.
`
`0 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.
`
`I Ex. 6 (’033 Patent Pros. History)
`at EBSOOOOOO34-38; arid
`EBS00000054-103.
`
`
`
`l
`
`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 the first fueling system” [’826
`(Claims 13—15)] / “fuel is provided by a first fueling system” [’826
`(Claim 31)]
`
`
`Ford’s Construction:
`‘2 Plaintiffs’ Construction:
`
`needed).
`
`Alternatively, if construed, “fuel is
`provided by a first fueling system using
`direct injection” [’826 (Claim 31)]
`should be construed to mean “fuel is
`
` Plain and ordinary (no construction
`
`directly injected into a cylinder” and the
`
`remainder should be construed to mean
`
`“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”
`
`FORD Ex. 1144, page 6
`lPR2020-00013
`
`

`

`
`
`“fuel that is directly injected into a
`cylinder.”
`
`Intrinsic Support:
`
`Intrinsic Support:
`
`1 (Orig. Appl.) at 5:25-26,
`Ex.
`625-7, 325-8, 1218-9; see also Ex.
`1 (Orig. Appl.) at 3:8-1 1, 511—2,
`10:16-20, FIG. 3.
`
`- Ex. 2 (’839 Patent) at Claims 1, 8-
`11,15.
`
`0 See also Ex. 6 (’033 File History)
`at EBSOOOOOOl8-28, at -21, -26;
`and EBSOOOOOO91-103, at -97-99.
`
`0 See also Ex. 7 (’166 File History)
`at EBS00001959—75, at -l964,
`-l971-72.
`
`
`
`
`
`Ex. 2 (’839 Patent) at Title;
`Abstract; 1:14-17, 42—62; 1:66-
`2:40; 2:61—6:67; Claims 1,2, 3,
`4,5,9,10,1l,15,16,17,18,19,
`20; Figs. 1, 2, 3, 4, and 5.
`
`Ex. 4 (’166 Patent) at Title;
`Abstract; 1:35-38, 1:65—2:19;
`2:23—67; 3:21-7:25; Claims 1, 2,
`3, 4, 5, 6, 7, 8, 9, 10, ll, l2, l3,
`14, 15, 16, 18, 19, 20, 21, 22, 23,
`27,28, 29, 30; Figs. 1,2, 3,4,
`and 5.
`
`Ex. 5 (’826 Patent) at Title;
`Abstract; 1:38-41, 221-22; 2:26-
`323; 3:24-7:37; Claims 1,2, 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.
`
`Ex. 6 (’033 Patent Pros. History)
`at EBS00000034-38; and
`EBS00000054-103.
`
`Ex. 7 (’166 Patent Pros. History)
`at EBS-OOOOl998—2033.
`
`
`
`
`
`5.
`“highest loads” [’839 (Claim 6)]
`
`l Plaintiffs’ Construction:
`l Ford’s Construction:
`
`Plain and ordinary (no construction
`
`“Highest torques”
`
`needed).
`
`Alternatively, if construed, “engine’s
`highest torques at a given engine
`
`speed.”
`
`FORD Ex. 1144, page 7
`lPR2020-00013
`
`

`

`
`
`Intrinsic Support:
`
`1 (Orig. Appl.) at 8:22-25; see
`0 Ex.
`also Ex.
`1 (Orig. Appl.) at 8:6—
`9:11.
`
`- Ex. 2 (’839 Patent) at Claims 1, 6,
`18.
`
`I Ex. 2 (’839 Patent) at 1:56—62;
`Claims 6 and 18.
`
` Intrinsic Support:
`
`torque” Intrinsic Support:
`
`
`
`0 See also Ex. 7 (’166 File History)
`
`at EBSOOOO2038—45, at —2044-45.
`
`“decreases with decreasing torque” [’519 (Claim 1)]
`6.
`
`
`Ford’s Construction:
`_ Plaintiffs’ Construction:
`Plain and ordinary (no construction
`needed).
`
`“always decreasing with decreasing
`
`1 (Orig. Appl.) at 3:2-5, 9:12—
`0 Ex.
`14; see also Ex.
`1 (Orig. Appl.) at
`3:18—25, 4:21—27, 826—9111.
`
`0 Ex. 3 (’519 Patent) at Claims 1—3,
`
`5—6, 9—1 1.
`
`0 See also Ex. 6 (’033 File History)
`at EBSOOOOOOl8—28, at -21, —26;
`
`and EBSOOOOOO9l-103, at —97-
`100.
`
`Intrinsic Support:
`
`0 Ex. 3 (’519 Patent) at Abstract;
`1:47-50;2:5—14;3:21-31;5:46-
`
`57; 5:61—6:45; Claims 1,2, 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;
`
`Fig. 2;
`
`0 Ex. 6 (”033 Patent Pros. History)
`at EBSOOOOOO34—38; and
`EBSOOOOOOS4—103.
`
`
`
`7.
`
`Plaintiffs’ Construction:
`
`“closed loop control that utilizes a sensor that detects knock” [’519
`(Claim 1)] / “input from the knock sensor 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)]
`
`Ford’s Construction:
`i
`
`Plain and ordinary (no construction
`needed).
`
`Alternatively, if construed, “closed loop
`control that utilizes a sensor that detects
`
`“a microprocessor that uses a direct
`feedback input signal from a knock
`sensor” / “a direct feedback input
`signal from the knock sensor is used by
`a microprocessor to control” / “a direct
`
`
`knock” (Claim 1) should be construed to
`
`
`
`8
`
`FORD Ex. 1144, page 8
`IPR2020—00013
`
`

`

`
`
`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
`
`Intrinsic Support:
`
`Intrinsic Support:
`
`If construed, “input from the knock
`sensor is utilized in a closed loop
`control system that controls” (Claim 14)
`should be construed to mean “input
`from the knock sensor is used by a
`feedback system that controls.”
`
`
`
` is used.”
`
`0 Ex. 1 (Orig. Appl.) at 3:18—25,
`4:21—27, 9:26-28, FIG 1 & 5.
`0 Ex. 3 (’519 Patent) at Claims 1, 2,
`5, 10, 13, 14, 18, 19, 24, 25, 27,
`29.
`
`- See also Ex. 6 (’033 File History)
`at EBSOOOOOO91-103, at —99-100.
`
`- See also Ex. 7 (’166 File History)
`at EB800002038-45, at -44—45.
`
`0 Ex. 3 (’519 Patent) at 2:35-45;
`3:13—31; Claims 1, 13, 14, 18,
`19, 24, 25, 29; Figs 1 and 5-
`
`
`
`FORD Ex. 1144, page 9
`IPR2020-00013
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`

`

`Dated: September 24, 2019
`
`Respectfully submitted,
`
`FARNAN LLP
`
`
`/s/ Michael J. Farnan
`
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`(302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Attorneys for Plaintifi’
`
`MORRIS, NICHOLS, ARSHT &TUNNELL
`LLP
`
`/s/ Rodger D. Smith 11
`Rodger D. Smith 11 (#3778)
`Michael J. Flynn (#5333)
`Taylor M. Haga (#6549)
`1201 North Market Street
`PO. Box 1347
`Wilmington, DE 19899
`(302) 65 8-9200
`rsmith@mnat.com
`mflynn@mnat.com
`thaga@mnat.com
`
`Attorneys for Defendant
`
`10
`
`FORD Ex. 1144, page 10
`IPR2020-00013
`
`

`

`EXHIBIT 1
`
`FORD Ex. 1144, page 11
`IPR2020-00013
`
`

`

`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 following is a
`
`Specification:
`
`Atiomey Docket No.2 0492611-0598
`Express Mall No. EV196632874US
`Dale 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 antilcnock agent
`
`which is a liquid fuel with a higher octane number than gasoline such as ethanol to improve
`
`engine efficiency.
`
`It is known that the efficiency ofspark ignition (SI) gasoline engines can be increased by
`
`high compression ratio operation and particularly by engine downsizing. The engine downsizing
`
`is made possible by the use of substantial pressure boosting from either turbocharging or
`
`supercharging. Such pressure boosting makes it possible to obtain the same performance in a
`
`significantly smaller engine. 83, J. Stokes, et al., “A Gasoline Engine Concept For Improved
`
`Fuel Economy — The Lean-Boost System,” SAE Paper 2001 -Ol-2902. The use ofthese
`
`techniques to increase engine efficiency, 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 compression ratio operation and high pressure boosting can be used to
`
`increase engine efficiency by up to twenty-five percent.
`
`Octane number represents the resistance of a fuel to knocking but the use of higher
`
`octane gasoline only modestly alleviates the tendency to knock. For example, the difference
`
`between regular and premium gasoline is typically six octane numbers. That is significantly less
`
`than is needed to realize fully the efficiency benefits of high compression ratio or turbocharged
`
`operation. There is thus a need for a practical means for achieving a much higher level of octane
`
`enhancement so that engines can be operated much more efficiently.
`
`It is known to replace a portion of gasoline with small amounts of ethanol added at the
`
`refinery. Ethanol has a blending octane number (ON) of 1 10 (versus 95 .or premium gasoline)
`
`(see l.B. Heywood, “Internal Combustion Engine Fundamentals,” McGraw Hill, 1988, p. 477)
`
`and is also attractive because it 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 ethanol that is readily available is much smaller than that of gasoline because of the relatively
`
`limited amount of biomass that is available for its production. An object of the present invention
`
`10
`
`15
`
`20
`
`25
`
`30
`
`Attorney Docket No.: 0492611-0598
`Express Mall No. EV196632874US
`Date of Flllng: November 18, 2004
`Customer Number: 24280
`
`Page 2 of 14
`
`EBS-00000176
`
`FORD Ex. 1144, page 13
`IPR2020-00013
`
`

`

`is to minimize the amount of ethanol or other antiknock agent that is used to achieve a given
`
`level of engine efficiency increase. By restricting the use of ethanol to the relatively small
`
`fraction of time in an operating cycle when it is needed to prevent knock in a higher load regime
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`and by minimizing its use at these times, the amount of ethanol that is required can be limited to
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`a relatively small fraction of the fuel used by the spark ignition gasoline engine.
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`10
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`15
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`20
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`Summagy of the Invention
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`In one aspect, the invention is a fuel management system for efficient operation of a
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`spark ignition gasoline engine including a source of an antiknock agent such as ethanol. An
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`injector directly injects the ethanol into a cylinder of the engine and a fuel management system
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`controls injection of the antiknock agent into the cylinder to control knock with minimum use of
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`the antiknock agent. A preferred antiknock agent is ethanol. Ethanol has a high heat of
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`vaporization so that there is substantial cooling of the air-fuel charge to the cylinder when it is
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`injected directly into the engine. This cooling effect reduces the octane requirement of the
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`engine by a considerable amount in addition to the improvement in knock resistance from the
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`relatively high octane number of ethanol. Methanol, tertiary butyl alcohol, MTBE, ETBE, and
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`TAME may also be used. Wherever ethanol is used herein it is to be understood that other
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`antiknock agents are contemplated.
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`The fuel management system uses a fuel management control system that may use a
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`microprocessor that Operates in an open loop fashion on a predetermined correlation between
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`octane number enhancement and fraction of fuel provided by the antiknock agent. To conserve
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`the ethanol, it is preferred that it be added only during portions of a drive cycle requiring knock
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`resistance and that its use be minimized during these times. Alternatively, the gasoline engine
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`may include a knock sensor that provides a feedback signal to a fuel management
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`microprocessor system to minimize the amount of the ethanol added to prevent knock in a closed
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`25
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`loop fashion.
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`In one embodiment the injectors stratify 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.
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`In another embodiment of this aspect of the invention, the system includes a measure of
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`30
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`the amount of the antiknock agent such as ethanol in the source containing the antilmock agent to
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`control turbocharging, supercharging or spark retard when the amount of ethanol is low.
`
`Altomey Docket No.: 0492611—0596
`Express Mall No. EV196632874US
`Data of Flllng: November 18, 2004
`Customer Number: 24280
`
`Page 3 of 14
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`EBs-ooooo177
`
`FORD Ex. 1144, page 14
`IPR2020-00013
`
`

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`The direct injection of ethanol provides substantially a 13°C drop in temperature for
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`every ten percent of fuel energy provided by ethanol. An instantaneous octane enhancement of
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`at least 4 octane numbers may be obtained for every 20 percent of the engine’s energy coming
`from the ethanol.
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`Brief Description of the Drawing
`
`Fig. 1 is a block diagram of one embodiment of the invention disclosed herein.
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`Fig. 2 is a graph of the drop in temperature within a cylinder as a function of the fraction
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`of energy provided by ethanol.
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`Fig. 3 is a schematic illustration of the stratification of cooler ethanol charge using 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 ofan embodiment ofthe invention in which the fuel
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`management microprocessor is used to control a turbocharger and spark retard based upon the
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`amount of ethanol in a fuel tank.
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`Description of the Preferred Embodiment
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`With reference first to Fig. l, 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
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`system 14 controls the direct injection of an antiknock agent such as ethanol from an ethanol
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`tank 16. The fuel management microprocessor system 14 also controls the delivery of gasoline
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`from a gasoline tank 18 into engine manifold 20. A turbocharger 22 is provided to improve the
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`torque and power density of the engine 10. The amount of ethanol injection is dictated either by
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`a predetermined correlation between octane number enhancement and fraction 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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`new. the knock sensor 12 as an input to the fuel management microprocessor 14. In both
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`situations, the fuel management processor 14 will minimize the amount of ethanol 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
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`10
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`20
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`25
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`Attorney Docket No.: 049261143598
`Express Mall No. EV196632874US
`Date of Filing: November 18. 2004
`Customer Number: 24280
`
`Page 4 of 14
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`EBS-00000178
`
`FORD Ex. 1144, page 15
`IPR2020-00013
`
`

`

`amount of ethanol. Recent advances in fuel injector and electronic control technology allows
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`fuel injection directly into a spark ignition engine rather than into the manifold 20. Because
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`ethanol has a high heat of vaporization there will be substantial cooling when it is directly
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`injected into the engine 10. This cooling effect further increases knock resistance by a
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`considerable amount. In the embodiment of Fig. 1 port fuel injection of the gasoline in which
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`the gasoline is injected into the manifold rather than directly injected into the cylinder is
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`preferred because it is advantageous in obtaining good air/fuel mixing and combustion stability
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`that are difficult to obtain with direct injection.
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`10
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`15
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`20
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`25
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`Ethanol has a heat of vaporization of 840kJ/kg, while the heat of vaporization of gasoline
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`is about SSOkJ/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. That is, for equal amounts of energy the required heat of vaporization of
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`ethanol is about four times higher than that of gasoline. The ratio of the heat of vaporization per
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`unit air required for stoichiometric combustion is about 94 kJ/kg of air for ethanol and 24 kJ/kg
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`of air for gasoline, or a factor of four smaller. Thus, the net effect of cooling the air charge is
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`about four times lower for gasoline than for ethanol (for stoichiometric mixtures wherein the
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`amount of air contains oxygen that is just sufficient to combust all of the fuel).
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`In the case of ethanol direct injection according to one aspect of the invention, the charge
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`is directly cooled. The amount of cooling due to direct injection of ethanol is shown in Fig. 2.
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`It
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`is assumed that the air/fuel mixture is stoichiometric without exhaust gas recirculation (EGR),
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`and that gasoline makes up the rest of the fuel. It is fiirther 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 ethanol injection 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.
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`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
`
`Attomay Docket No.: 0492611-0598
`Express Mail No. EV196632874US
`Date of Flllng: November 18. 2004
`Customer Number: 24280
`
`Page 5 of 14
`
`EBB-00000179
`
`FORD Ex. 1144, page 16
`IPR2020-00013
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`

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`the engine operates at twice the stoichiometric air/fuel ratio, the numbers indicated in Fig. 2
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`decrease by about a factor of 2 (the contribution of the ethanol itself and the gasoline is relatively
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`modest). Similarly, for a 20% EGR rate, the cooling effect of the ethanol decreases by about
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`25%.
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`The octane enhancement effect 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 number required
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`by the engine, as discussed by Stokes, et a1. Thus the contribution is about five octane numbers
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`per 30K drop in charge temperature. As ethanol can decrease the charge temperature by about
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`120K, then the decrease in octane number required by the engine due to the drop in temperature,
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`for 100% ethanol, is twenty octane numbers. Thus, when 100% of the fuel is provided by
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`ethanol, the octane number enhancement is approximately thirty-five octane numbers with a
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`twenty octane number enhancement coming from direct injection cooling and a fifieen octane
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`number enhancement coming from the octane number of ethanol. From the above
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`considerations, it can be projected that even if the octane enhancement from direct cooling is
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`significantly lower, a total octane number enhancement of at least 4 octane numbers should be
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`achievable for every 20% of the total fuel energy that is provided by ethanol.
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`Alternatively the ethanol and gasoline can be mixed together and then port injected
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`through a single injector per cylinder, thereby decreasing the number ofinjectors that would be
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`used. However, the air charge cooling benefit from ethanol would be lost.
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`Alternatively the ethanol and gasoline can be mixed together and then port fuel injected
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`using a single injector per cylinder, thereby decreasing the number of injectors that would be
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`used. However, the substantial air charge cooling benefit from ethanol would be lost. The
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`volume of fuel between the mixing point and the port fuel injector should be minimized in order
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`to meet the demanding dynamic cctane-erfirancemcnt requirements of the engine.
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`Relatively precise determinations of the actual amount of octane enhancement fiom given
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`amounts of direct ethanol injection can be obtained from laboratory and vehicle tests in addition
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`to detailed calculations. These correlations can be used by the fuel management microprocessor
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`system 14.
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`Attorney Docket No.: 0492611-0598
`Express Mail No. EV196632874US
`Date of Flllng: November 18. 2004
`Customer Number: 24280
`
`Page 6 of 14
`
`EBS-00000180
`
`FORD Ex. 1144, page 17
`IPR2020-00013
`
`

`

`An additional benefit of using ethanol for octane enhancement is the ability to use it in a
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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 ethanol is added to
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`gasoline at a refinery. Moreover, the water provides an additional cooling (due to vaporization)
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`that further increases engine lmock resistance.
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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
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`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.
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`Further decreases in the required ethanol for a given amount of octane enhancement can
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`be achieved with stratification (non-uniform deposition) of the ethanol addition. Direct injection
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`can be used to place the ethanol near the walls of the cylinder where the need for knock
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`reduction is greatest. The direct injection may be used in combination with swirl. This
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`stratification of the ethanol in the engine further reduces the amount of ethanol needed to obtain
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`a given amount of octane enhancement. Because only the ethanol is directly injected and
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`because it is stratified both by the injection process and by thermal centrifugation, the ignition
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`stability issues associated with gasoline direct injection (GDI) can be avoided.
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`It is preferred that ethanol be added to those regions that make up the end-gas and are
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`prone to auto-ignition. These regions are near the walls of the cylinder. Since the end-gas
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`contains on the order of 25% of the fuel, substantial decrements in the required amounts of
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`ethanol can be achieved by stratifying the ethanol.
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`In the case of the engine 10 having substantial organized motion (such as swirl), the
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`cooling will result in forces that thermally stratify the discharge (centrifugal separation of the
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`regions at different density due to different temperatures). The effect of ethanol addition is to
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`increase gas density since the temperature is decreased. With swirl the ethanol mixture will
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`automatically move to the zone where the end-gas is, and thus increase the anti-knock
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`effectiveness of the injected ethanol. The swirl motion is not affected much by the compression
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`stroke and thus survives better than tumble-like motion that drives turbulence towards top-dead-
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`center (TDC) and then dissipates. It should be pointed out that relatively modest swirls result in
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`10
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`l5
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`20
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`25
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`Attorney Docket No.: 0492611-0598
`Express Mall No. EV196632874US
`Date of Filing: November 18. 2004
`Customer Number: 24280
`
`Page 7 of 14
`
`EBS-00000181
`
`FORD Ex. 1144, page 18
`IPR2020-00013
`
`

`

`large separating (centrifugal) forces. A 3m/s swirl motion in a 5cm radius cylinder generates
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`accelerations of about 200m/sz, or about 20g’s.
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`Fig. 3 illustrates ethanol direct injection and swirl motion for achieving thermal
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`stratification. Ethanol is predominantly on an outside region which is the end-gas region. Fig. 4
`
`illustrates a possible stratification of the ethanol in an inlet manifold with swirl motion and
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`thermal centrifugation maintaining stratification in the cylinder. In this case of port injection of
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`ethanol, however, the advantage of substantial charge cooling may be lost.
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`With reference again to Fig. 2, the effect of ethanol addition all the way up to 100%
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`ethanol injection is shown. At the point that the engine is 100% direct ethanol injected, there
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`10
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`may be issues of engine stability when operating with only stratified ethanol injection that need
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`to be addressed. In the case of stratified operation it may also be advantageous to stratify the
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`injection of gasoline in order to provide a relatively uniform equiv