UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`Washington, DC. 20436
`
`Before the Honorable Thomas B. Pender
`
`Administrative Law Judge
`
`
`In the Matter of
`
`
`
`
`
`
`
`
`
`CERTAIN THERMOPLASTIC-
`
`ENCAPSULATED ELECTRIC MOTORS,
`COMPONENTS THEREOF, AND
`VEHICLES CONTAINING SAME II
`
`Investigation No. 3 3 7-TA-1073
`
`EXPERT REPORT OF
`
`DR. HAMID A. TOLIYAT
`
`m MW
`
`Signed by: Dr. Hamid A. Toliyat, April 20, 2018
`
`PETITIONERS’ EXHIBIT 1136
`
`TOYOTA AND AISIN V. IV
`
`IPR2017-01494
`
`' PE'I'I'I'IUNEKS’ EXHIBIT 71156 7
`TOYOTA AND AISIN v. IV
`IPR2017-01495, IPR2017—01538 and IPR2017-01539
`
`Page 1 of 36
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`PETITIONERS’ EXHIBIT 1136
`TOYOTA AND AISIN v. IV
`IPR2017-01494
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`Page 1 of 36
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`TABLE OF CONTENTS
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`PAGE
`
`Introduction .......................................................................................................................... l
`
`II.
`
`III.
`
`IV.
`
`VI.
`
`VII.
`
`Qualifications and Experience ............................................................................................. 1
`
`Compensation ...................................................................................................................... 5
`
`Legal Principles ................................................................................................................... 6
`
`Materials Considered ........................................................................................................... 7
`
`Person of Ordinary Skill in the Art ...................................................................................... 8
`
`Claim Construction .............................................................................................................. 8
`
`VIII.
`
`No Motivation To Combine ................................................................................................. 9
`
`IX.
`
`Overview of the ’200 Patent .............................................................................................. 11
`
`A.
`
`B.
`
`The ’200 patent replaces a conventional metal stator assembly body with
`an encapsulating thermoplastic body to reduce stack up tolerances and
`manufacturing costs and increase motor efficiency and performance ................... 12
`
`The ’200 patent motor uses a thermoplastic material with a CLTE that
`causes the thermoplastic encapsulating stator assembly body and select
`metal parts to expand and contract at approximately the same rate at the
`operating temperatures of the motor. ..................................................................... 15
`
`Overview of the ’348 Patent .............................................................................................. 17
`
`XI.
`
`XII.
`
`Overview of the ’509 Patent .............................................................................................. 25
`
`Conclusion ......................................................................................................................... 33
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`Investigation No. 337-TA-1073
`REBUTTAL EXPERT REPORT OF DR. HAMID A. TOLIYAT
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`TABLE OF ABBREVIATIONS
`
`Inc.,
`Ad.Asin Holdings of
`Technical Center of America, Inc. and/or Aisin World Corporation
`of America
`
`Bayerische Motoren Werke AG, BMW of North America, LLC,
`and/or BMW Manufacturing Co., LLC
`DENSO CORPORATION and/or DENSO International America,
`Inc.
`
`Encap Technologies, Inc.
`Ford Motor Company
`Honda Motor Co., Ltd., Honda North America, Inc., American
`Honda Motor Co., Inc., Honda of America Mfg., Inc., Honda
`Manufacturing of Alabama, LLC and/or Honda R&D Americas, Inc.
`
`BMW
`
`DENSO
`
`Respondents
`
`
`
`'
`
`Toyota Motor Corporation, Toyota Motor North America, Inc.,
`Toyota Motor Sales, U.S.A., Inc., Toyota Motor Engineering &
`Manufacturing, North America, Inc., Toyota Motor Manufacturing,
`Indiana, Inc. and/or Toyota Motor Manufacturing, Kentucky, Inc.
`Aisin Seiki Co., Ltd., Aisin Holdings of America, Inc., Aisin
`Technical Center of America, Inc, Aisin World Corporation of
`America, Bayerische Motoren Werke AG, BMW of North America,
`LLC, BMW Manufacturing Co., LLC, DENSO CORPORATION,
`DENSO International America, Inc., Honda Motor Co., Ltd., Honda
`North America, Inc., American Honda Motor Co., Inc., Honda of
`America Mfg., Inc., Honda Manufacturing of Alabama, LLC, Honda
`R&D Americas, Inc., Mitsuba Corporation, American Mitsuba
`Corporation, Nidec Corporation, Nidec Automotive Motor
`Americas, LLC, Toyota Motor Corporation, Toyota Motor North
`America, Inc., Toyota Motor Sales, U.S.A., Inc., Toyota Motor
`Engineering & Manufacturing, North America, Inc., Toyota Motor
`Manufacturing, Indiana, Inc., and Toyota Motor Manufacturing,
`Kentucky, Inc.
`
`Investigation No. 337-TA-1073
`REBUTTAL EXPERT REPORT OF DR. HAMID A. TOLIYAT
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`I.
`
`Introduction
`
`1.
`
`My name is Dr. Hamid Toliyat. I have been retained by counsel for Complainant
`
`Intellectual Ventures II LLC as an expert in this Investigation to examine Whether United States
`
`Patent Nos. 7,154,200 (“the ’200 Patent”), 7,928,348 (“the ’348 Patent”), and the 7,683,509 (“the
`
`’509 Patent”) (collectively, “the Asserted Patents”) are valid.
`
`2.
`
`I expect to testify at trial as to the opinions set forth in this report and the bases for
`
`those opinions. In addition, I expect to testify in rebuttal to the positions taken by Respondents
`
`or their experts with regard to validity of the Asserted Patents.
`
`3.
`
`I reserve the right to revise, amend, or supplement this report and my opinions set
`
`forth in this report if I become aware of additional evidence or information, including documents
`
`or deposition testimony that were not available for review as of the date of this report.
`
`II.
`
`Qualifications and Experience
`
`4.
`
`I am a professor in the Department of Electrical and Computer Engineering,
`
`Texas A&M University.
`
`I have been active in the field of electrical engineering for over 30
`
`years and have been licensed as Professional Engineer in the State of Texas since 2006.
`
`I
`
`developed my engineering experience through a variety of academic and industrial projects.
`
`Some of the industrial projects I have worked on include turbo-generator exciter and auxiliary
`
`systems such as inverters and rectifiers, the design and construction of high voltage substations
`
`including the auxiliary power supplies, development of a high performance AC drive, and the
`
`design of a concentrated winding machine for a DC locomotive traction alternator. My academic
`
`projects include the analysis and design of electrical machines, variable speed drives for traction
`
`and propulsion applications, fault diagnosis of electric machinery, sensorless variable speed
`
`drives.
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`5.
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`I received a BS. degree from Sharif University of Technology, Tehran, Iran in
`
`1982, MS. degree from West Virginia University, Morgantown, WV in 1986, and Ph.D. degree
`
`from University of Wisconsin-Madison, Madison, WI in 1991, all in electrical engineering. My
`
`Ph.D. concentrated on industrial drives, electrical machines, power electronics, and power
`
`systems and controls. My Ph.D. dissertations was an “Analysis of Concentrated Winding
`
`Induction and Reluctance Motors for Adjustable Speed Drive Applications.” Following receipt
`
`of my Ph.D. degree, I joined the faculty of Ferdowsi University of Mashhad, Mashhad, Iran as an
`
`Assistant Professor of Electrical Engineering. In March 1994, I joined the Department of
`
`Electrical and Computer Engineering, Texas A&M University, Where I am currently a Raytheon
`
`endowed professor of electrical engineering.
`
`6.
`
`My work is directed to the control and flow of electric energy efficiency using
`
`advanced power electronics and electromechanical devices. It includes design and control
`
`strategies known as “fault tolerant design.” In fact, fault tolerance and durability plays a central
`
`role in the design and development of advanced auxiliary motor drives in off shore oil/gas
`
`applications, automotive, marine, and aerospace applications. My work also includes condition
`
`monitoring and fault diagnosis of electric machinery, high-speed, medium voltage motors and
`
`generators, electric and hybrid electric vehicles, and auxiliary power generators.
`
`7.
`
`My work has been recognized by a number of awards.
`
`I received the prestigious
`
`Nikola Tesla Field Award for “outstanding contributions to the design, analysis and control of
`
`fault-tolerant multiphase electric machines” from IEEE in 2014, the Cyril Veinott Award in
`
`Electromechanical Energy Conversion from the IEEE Power Engineering Society in 2004, Patent
`
`and Innovation Award from Texas A&M University System Office of Technology
`
`Commercialization’s in 2016 and 2007, TEES Faculty Fellow Award in 2006, Distinguished
`
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`Teaching Award in 2003, ED. Brockett Professorship Award in 2002, Eugene Webb Faculty
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`Fellow Award in 2000, and Texas A&M Select Young Investigator Award in 1999.
`
`I also
`
`received the Space Act Award from NASA in 1999, and the Schlumberger Foundation Technical
`
`Awards in 2000 and 2001. I am a member of Sigma Xi.
`
`8.
`
`I have supervised more than 85 graduate students, post-doctoral research, and
`
`research engineers. As a teacher, I stress the use of interdisciplinary ideas. Rather than teaching
`
`students to specialize in a narrow area, I try to provide valuable perspective on how ideas relate
`
`with concepts students have already seen in other classes. With these interdisciplinary goals in
`
`mind, I have purposely taught courses in two different areas within my department: power
`
`electronics, and electric machinery.
`
`I have developed and taught three new courses in the area of
`
`electromechanical motion devices. These are:
`
`- ECEN 611 General Theory of Electromechanical Motion Devices, 3 credits;
`
`0 ECEN 612 Computer Aided Design of Electromechanical Motion Devices, 4
`
`credits; and,
`
`o ECEN 442/742 DSP-Based Electromechanical Motion Control, 3 credits.
`
`9.
`
`I have been a guest lecturer and designed and taught a number of short courses
`
`over the past 20 years. Many of these engagements were for industrial manufacturers, defense
`
`agencies, and academic institutions. For example, I have lectured at General Motors, Texas
`
`Instruments, Whirlpool, Samsung, LG Electronics, Hyundai, United Technologies, Black &
`
`Decker, TECO-Westinghouse, Emerson, General Atomics, and General Electric on topics
`
`including electric drives for electric and hybrid vehicles, switched reluctance motor drives,
`
`permanent magnets motors, wind power generators and converters, recent advances in modern
`
`electric machines and power electronics converters, design and performance improvement of
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`electromechanical devices, research activities at the EMPE Lab, high frequency power
`
`converters, and electric motors and power converters for electric and hybrid electric vehicles.
`
`10.
`
`My work has been cited by my colleagues more than 18,000 times. I have
`
`published over 480 technical papers, presented more than 95 invited lectures all over the world,
`
`and have 22 issued and pending US. patents. I authored DSPBased Electromechanical Motion
`
`Control, CRC Press, 2003, and co-authored Electric Machines — Modeling, Condition
`
`Monitoring, and Fault Diagnosis, CRC Press, Florida, 2013.
`
`I am the co-editor of Handbook of
`
`Electric Motors - 2nd Edition, Marcel Dekker, 2004.
`
`I have also contributed to a number of text
`
`book chapters, including:
`
`0 Power Electronic Converters and Systems — Frontiers and Applications, edited by
`
`AM. Trzynadlowski, IET Press, 2016, pp. 75-110;
`
`0 Power Electronicsfor Renewable Energy Systems, Transportation and Industrial
`
`Applications, H. Abu-Rub et al., Wiley & Sons, 2014, pp. 107-135;
`
`0 Third Edition of: Power Electronics Handbook, Muhammad H. Rashid, Butterworth—
`
`Heinemann Publishing, 2011, pp. 1155-1176;
`
`0 Second Edition of: Power Electronics Handbook, Muhammad H. Rashid, Academic
`
`Press, 2006;
`
`o
`
`The Power Electronics Handbook, Timothy L. Skvarenina, Editor-in—Chief, CRC
`
`Press, 2002; and,
`
`0 Comprehensive Dictionary ofElectrical Engineering, Phillip Laplante, Editor-in-
`
`Chief, CRC Press, 1999.
`
`11.
`
`I have been involved heavily in the Institute of Electrical and Electronics
`
`Engineers, commonly referred to as the IEEE, for many years.
`
`I am an IEEE fellow. I was an
`
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`Editor of IEEE Transactions on Energy Conversion, and was a Chair of the IEEE-IAS Industrial
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`Power Conversion Systems Department of IEEE-IAS.
`
`I was the General Chair of the 2005 IEEE
`
`International Electric Machines and Drives Conference in San Antonio, Texas. Also, I am the
`
`recipient of the 2008 Industrial Electronics Society Electric Machines Committee Second Best
`
`Paper Award, as well as the recipient of the IEEE Power Engineering Society Prize Paper
`
`Awards in 1996 and 2006, and IEEE Industry Applications Society Transactions Third Prize
`
`Paper Award in 2006, and Second Prize Paper Award in 2016.
`
`12.
`
`My curriculum vitae (CV) is attached as Appendix D.
`
`III.
`
`Compensation
`
`13.
`
`I am being compensated at a rate of $500 per hour by the Complainant for my
`
`assistance in connection with the above-captioned Investigation, and all activities in connection
`
`with the preparation of my rebuttal expert report. I am being paid regardless of the conclusions
`
`or opinions I reach.
`
`I have no personal or financial stake or interest in the outcome of the present
`
`proceedings, and my compensation is not dependent in any way upon the outcome of these
`
`proceedings.
`
`I have no ownership or financial interest in Intellectual Ventures or in any of the
`
`Respondents.
`
`14.
`
`This report is based on my own personal knowledge and experience, as well as
`
`information currently available to me.
`
`I intend to continue my investigation and analysis, which
`
`may include a review of documents and information that may yet be produced, as well as
`
`deposition testimony from depositions for which transcripts are not yet available or that may yet
`
`be taken in this case. I expressly reserve the right to expand or modify my opinions as my
`
`investigation and analysis continue, and to supplement my opinions in response to any additional
`
`information that becomes available to me, any matters raised by Respondents and Staff, and/or
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`other opinions provided by Respondents’ experts, or in light of any relevant orders from the
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`Administrative Law Judge or other authoritative body. Moreover, I reserve the right to use
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`demonstratives and the right to provide rebuttal testimony regarding any analyses and opinions
`
`raised in opposition to my report.
`
`IV.
`
`Legal Principles
`
`15.
`
`Certain legal principles have been explained to me:
`
`16.
`
`I understand that an issued US. patent is entitled to a statutory presumption of
`
`validity, which is based on the assumption that the PTO properly follows and applies the tests for
`
`patentability.
`
`I understand this presumption can only be rebutted with clear and convincing
`
`evidence of invalidity.
`
`17. With respect to anticipation under 35 U.S.C. § 102, I have been informed that a
`
`single reference must describe the claimed invention with sufficient precision and detail to
`
`establish that the subject matter existed in the prior art.
`
`I understand that a vague or ambiguous
`
`teaching that neither discloses nor enables the claimed invention cannot anticipate the invention.
`
`I understand that a limitation may be deemed inherently disclosed in a prior-art reference, but
`
`only if it is necessarily present in the prior-art reference, as opposed to being merely probable or
`
`possible.
`
`18. With respect to obviousness under 35 U.S.C. § 103, I understand that a patent
`
`applicant is not entitled to a patent if the differences between the subject matter sought to be
`
`patented and the prior art are such that the subject matter as a whole would have been obvious at
`
`the time the invention was made to a person having ordinary skill in the art. I understand that, in
`
`determining whether an invention would have been obvious, the following facts should be
`
`considered: (1) the scope and content of the prior art; (2) the level of ordinary skill in the prior
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`art; (3) the differences between the claimed invention and the prior art; and (4) objective
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`evidence of non-obviousness.
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`I understand that the manner in which the invention was made is
`
`not relevant to the obviousness inquiry.
`
`19.
`
`I understand that "objective evidence of non-obviousness" can include such things
`
`as: (1) a long-felt but unmet need in the art for the claimed invention; (2) praise for the invention;
`
`(3) failure of others; (4) commercial success of the invention; and (5) copying by others.
`
`20.
`
`I also understand that a patent composed of several elements is not proved
`
`obvious merely by demonstrating that each of its elements was, independently, known in the
`
`prior art.
`
`I have been informed that this is so because inventions in most instances rely upon
`
`existing knowledge, and claimed discoveries almost of necessity will be combinations of what,
`
`in some sense, is already known.
`
`21.
`
`I understand that 35 U.S.C. § 112 imposes a "written description" and
`
`"enablemen " requirement on patentees. I understand the "written description" requirement is
`
`met if a person of ordinary skill in the art would have understood the inventor to have been in
`
`possession of the claimed invention at the time of filing, even if every nuance of the claims is not
`
`explicitly described in the specification. I understand the enablement requirement is satisfied if
`
`one skilled in the art, after reading the specification, could practice the claimed invention without
`
`undue experimentation.
`
`V.
`
`Materials Considered
`
`22.
`
`In forming the opinions set forth herein, I have considered and relied upon my
`
`education, knowledge in the relevant field, and my experience. I have also reviewed and
`
`considered the materials in Appendix E.
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`23.
`
`I understand that Intellectual Ventures has also engaged Robert M. Kimmel, Sc.D.
`
`I reviewed Dr. Kimmel’s Report in its entirety, and held discussions with him over the course of
`
`this Investigation. Accordingly, I reference Dr. Kimmel’s Report in my report.
`
`I have also
`
`communicated with Griffith Neal about the industry at the time of the patents and his experience
`
`with the same.
`
`VI.
`
`Person of Ordinary Skill in the Art
`
`26.
`
`The field of the Asserted Patents is electromagnetic motor design, manufacture
`
`and operation involving one or more component parts fabricated of a plastic nonmetal.
`
`Professionals in this field will generally be Electrical Engineers, Mechanical Engineers,
`
`Materials Engineers and/or Manufacturing Engineers.
`
`27.
`
`It is my opinion that a person of ordinary skill in the art of designing and
`
`manufacturing electromagnetic motors involving one or more component parts fabricated of a
`
`plastic nonmetal would have a degree in electrical engineering, mechanical engineering,
`
`materials engineering, manufacturing engineering and/or a related field. Such a person would
`
`also have at least three (3) years of experience in the field of designing and/or manufacturing
`
`electromagnetic motors involving one or more component parts fabricated of plastic nonmetal
`
`and/or in a related field, or have an equivalent combination of graduate education and/or work
`
`experience. I possess a higher level of skill than a person of ordinary skill in the relevant field of
`
`art pertaining to the Asserted Patents and would have been a person of ordinary skill in the
`
`relevant art at the time of the invention of each Asserted Patent.
`
`VII. Claim Construction
`
`24.
`
`I understand that the parties have completed the claim construction process for
`
`this Investigation and Administrative Law Judge Pender issued Order No. 32 construing the
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`terms of the asserted patents. I am familiar with Order No. 32 and the claim construction for the
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`terms therein.
`
`25.
`
`My validity analyses and opinions in this report considers Order No. 32 through
`
`the lens of a person of ordinary skill in the art at the time of the invention of each Asserted
`
`Patent. For those claim terms that have not been disputed by the parties, I have applied the plain
`
`and ordinary meaning of all such terms as those terms would have been understood by a person
`
`of ordinary skill in the art at the time of the invention of each Asserted Patent.
`
`VIII. No Motivation T0 Combine
`
`26.
`
`A POSITA would not have been motivated to combine the references identified
`
`by Dr. Trumper in order to arrive at the claimed invention. None of the references identified by
`
`Dr. Trumper discloses both of the critical limitations of “a monolithic body of injection molded
`
`thermoplastic material substantially encapsulating the at least one conductor” and “a non—linear
`
`head transfer fluid pathway in the monolithic body.” ’509 Patent, claim elements 1.2, 1.3, 14.2
`
`and 14.3; see also ’348 Patent, claim elements 24.2, 24.3 and 24.4. Dr. Trumper attempts to
`
`solve the shortcomings of the myriad of references identified as prior art by combining the prior
`art to fit together separate references in order to come up with the invention. The mere fact that
`
`Dr. Trumper cannot find a single reference that includes both of these limitations shows
`
`combining them is not something that a POSITA would do.
`
`27.
`
`Manufacturing a monolithic body from injection molded thermoplastic that
`
`includes a substantially encapsulated conductor and a fluid pathway is not a minor undertaking.
`
`As a POSITA, I’ve spent decades developing and researching electric motors. However, I am
`
`not a materials expert. When I need to have a plastic part made for one of my motors, I consult
`
`with a materials person. In my work on this case, I’ve consulted repeatedly with Dr. Kimmel.
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`Dr. Kimmel has been working on materials and molding of thermoplastic for decades and is very
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`knowledgeable on the subject. His opinion on the difficulty of creating the claimed monolithic
`
`body is the same as mine, it is quite difficult.
`
`28.
`
`One of the prior art references cited by Dr. Trurnper highlights this difficulty:
`
`US. Patent No. 7,3 62,554 to Griffith Neal (the Neal ’554 Patent). Mr. Neal is the inventor of the
`
`patents in suit, as well as the Neal ’554 Patent. The Neal ’554 Patent describes an apparatus that
`
`requires a monolithic body formed from injection molded thermoplastic that substantially
`
`encapsulates at least one conductor. See e. g., Neal ’554, 5:5 -49. The Neal ’554 Patent does not
`
`describe including a fluid pathway within the monolithic block. See generally, Neal ’554. The
`
`main difference between the Neal ’554 Patent and the ’348 and ”509 Patents is the inclusion of a
`
`fluid pathway in the injection molded thermoplastic of the monolithic body. Including a fluid
`
`pathway within the monolithic body of injection molded thermoplastic is not a straightforward
`
`problem to overcome.
`
`29.
`
`In my discussions with Mr. Neal and Dr. Kimmel, it’s become clear that solving
`
`the problems presented by including fluid pathways within the injection molded thermoplastic of
`
`the monolithic body was not straightforward. As Dr. Kimmel describes, using injection molded
`
`thermoplastic to form a part presents certain difficulties. Kimmel Rebuttal Report at 1] 152. The
`
`more complex a shape, the more pressure is needed to successfully mold and manufacture the
`
`monolithic body. As explicitly referenced, in the Konishi reference, other types of molding,
`
`including ordinary reactive injection molding, which is limited to thermoset materials, does not
`
`have this shortcoming. The material used within the mold can be given time to fill mold entirely
`
`before the reaction takes place to set the material. See Konishi at 11 [0037]. In order to fill the
`
`mold for a monolithic body that includes conductor(s) of a stator, which are somewhat fragile,
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`and fluid pathways requires significant pressure to ensure that the molten thermoplastic fills all
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`the cavities of the mold before the thermoplastic begins to harden.
`
`30.
`
`It took Mr. Neal’s company Encap Motor Corporation seven years to conduct the
`
`necessary research and development to be able to fully refine a monolithic body of injection
`
`molded thermoplastic that included both a substantially encapsulated conductor and at least a
`
`portion of a fluid channel. The Neal ’554 Patent was filed in 1999, and the ”348 Patent and the
`
`’509 Patents were filed in 2006. During that time, Mr. Neal engaged in years of research and
`
`development to establish the shapes and types of materials that were necessary to form this
`
`specific type of monolithic body that were not available in the marketplace or industry. In my
`
`conversations with Mr. Neal, he described some of the difficulties presented with this process.
`
`Being able to balance the pressure of the thermoplastic provided to the mold of the monolithic
`
`body and the specific thermoplastic to ensure that the complex mold was entirely filled was a
`
`delicate and difficult problem to overcome.
`
`31.
`
`Accordingly, the above analysis of Dr. Trumper’s deficiencies pertaining to a
`
`POSITA’s motivation to combine prior art references applies to Appendices A-C to my rebuttal
`
`report.
`
`IX.
`
`Overview of the ’200 Patent
`
`32.
`
`It is my opinion that all the Asserted Claims of the ’200 Patent are valid in light of
`
`the prior art references and combinations asserted by Dr. Trumper. Dr. Trumper’s prior art
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`references and combinations do not anticipate and/or render obvious claims 1, 2 and 4 of the
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`’200 Patent. The analysis rebutting Dr. Trumper’s prior art references and combinations is
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`located in Appendix A of my report.
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`33.
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`Among other things, the ’200 patent solves the foregoing problems by (1)
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`replacing the conventional metal stator assembly body with a molded thermoplastic stator
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`assembly body that substantially encapsulates the stator; and (2) choosing the thermoplastic
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`material so that is has a CLTE that results in it contracting and expanding at approximately the
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`same rate as one or more solid motor parts within or near the thermoplastic encapsulation body.
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`A.
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`The ’200 patent replaces a conventional metal stator assembly body with an
`encapsulating thermoplastic body to reduce stack up tolerances and
`manufacturing costs and increase motor efficiency and performance.
`
`34.
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`Like the conventional motor described above, the motor of the ’200 patent
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`features a stator 20 with steel laminations 11 forming a magnetically-inducible core 17 with
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`poles 21 thereon, and wire windings 15 serving as conductors. ‘200 Patent at 5:6-9, Fig. 2.
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`
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`35.
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`But instead of a metal stator assembly body as in a conventional electric motor,
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`the stator assembly of the ’200 patent has a thermoplastic material body 14 (annotated below in
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`magenta): “Together the stator 20 and body 14 make up stator assembly 13”:
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`36.
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`As shown in Figure 3 above and described in the ”200 patent, this thermoplastic
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`body 22 substantially encapsulates the stator 20 (shown above in yellow):
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`Together the stator 20 and body 14 make up stator assembly 13. The body 14
`is preferably a monolithic body 14. Monolithic is defined as being formed as a
`single piece. The body 14 substantially encapsulates the stator 20. Substantial
`encapsulation means that the body 14 either entirely surrounds the stator 20, or
`surrounds almost all of it except for minor areas of the stator that may be exposed.
`However, substantial encapsulation means that the body 14 and stator 20 are rigidly
`fixed together, and behave as a single component with respect to harmonic
`oscillation vibration.
`
`Id. at 5:14-27 (emphases added). The patent describes both types (“almost all” or “entirely”) of
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`“substantial encapsulation”: “The body 14 is molded around the stator 20 in a manner such that
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`the faces of the poles are exposed and surrounded by and aligned concentrically with respect to
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`the disc support member 12. Alternatively, the poles may be totally encapsulated in body 14 and
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`not be exposed.” Id. at 6:13-17.
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`37.
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`The ’200 patent describes in detail the materials and methods for making the
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`thermoplastic encapsulating body 14. E. g., id at 5:28-8:8. As detailed, a thermoplastic phase-
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`change material is used so that the stator assembly body may be molded around the stator using
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`molds and the disclosed encapsulation technique. Id. at 5:28-49, 7:46-60. “This encapsulation
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`technique involves the following steps and uses the mold shown in FIGS. 15 and 16. First, a
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`mold is constructed to produce a part with the desired geometry. The mold has two halves 72 and
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`74.” Id. at 7:49-54.
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`
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`38.
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`“Second, using solid state process controlled injection molding, plastic is injected
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`through gate 80 around the stator, so as to encapsulate the stator and from the body 14 shaped as
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`shown in Figs. 3 and 4. As plastic flows in, pins 76 are withdrawn so that the plastic completely
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`surrounds the stator.” Id. at 7:55-60. In this manner, a solid stator assembly body is molded
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`around the stator, obviating the need for a metal assembly body.
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`39.
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`The ”200 patent describes that using this encapsulation method to create the stator
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`assembly body 14 rather than manufacturing it from metal parts “reduces the number of parts
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`needed to manufacture the motor as compared with conventional motors
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`thereby reducing
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`stack up tolerances and manufacturing costs.” Id. at 4:67-5:5. This is because the thermoplastic
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`stator assembly body 14 molded around the stator provides the necessary structure, support,
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`alignment, and base, obviating the need to use metal parts and connections as the body:
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`The monolithic body 14 provides a single structure that aligns the stator,
`bearings, shaft and disc support members relative to one another. (Further
`this single piece provides a support for the bearings and a base 22 that allows
`connection to a hard disc drive). The use of multiple parts in previous devices
`results in stack up tolerances and increased manufacturing costs. Conversely, the
`single unitize body of the present
`invention provides alignment for the
`components of a spindle motor and couples these components to one another.
`By encapsulating the body 14 and thereby molding some components as part of the
`body 14 and using the body to align the remaining components, stack up
`tolerances are substantially reduced, along with manufacturing costs. This
`also leads to greater motor efficiency and performance.
`
`Id. at 8:11-27 (emphases added).
`
`B.
`
`The ’200 patent motor uses a thermoplastic material with a CLTE that
`causes the thermoplastic encapsulating stator assembly body and select
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`metal parts to expand and contract at approximately the same rate at the
`operating temperatures of the motor.
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`40.
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`Using a thermoplastic encapsulation as the stator assembly body allows for
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`further optimization of tolerances and performance, because the thermoplastic material can be
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`chosen with a coefficient of linear thermal expansion (“CLTE”) so that it and select metal parts
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`expand and contract at approximately the same rate at the operating temperatures of the motor.
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`E.g., id. at 8:28—65.
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`41.
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`For example, with regard to the stator assembly body and steel bearings, the ’200
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`patent describes that matching their expansion and contraction during operating temperatures
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`allows for tighter toleranc