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`I, Richard A. Flasck, declare as follows:
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`1.
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`I have been retained by Sony Corporation in connection with its petition for
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`inter partes review of U.S. Patent No. 6,934,148 (“’148 patent”).
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`2.
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`I received a Bachelor of Science degree in Physics from the University of
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`Michigan (Ann Arbor, MI) in 1970. I received a Master of Science degree in
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`Physics from Oakland University (Rochester, MI) in 1976.
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`3.
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`During the course of my professional career, my projects have involved
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`power components and assemblies in enclosures that required cooling, either
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`natural convective cooling or forced air convective cooling. Often heat sinks were
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`also necessary.
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`4.
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`I am an inventor on a number of issued patents, and I have worked on
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`numerous projects involving the cooling of electronics, including through forced
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`air cooling. On one end of the spectrum is my micro thermal print head (US
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`4,170,728), which required microscopic thermal management at the tiny print head
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`and cooling of the electronics driving the print head. On the other end of the
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`spectrum were two programs, one to develop a small footprint 2000 watt thermal
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`printer and the other was a high power LED theatrical spotlight (US 9,328,898),
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`both of which required forced air cooling.
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`5.
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`Other projects that involved natural convection or forced air convection
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`(using tubeaxial fans or centrifugal blowers) include:
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`1
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`. 1002
`SON -
`Sony Corporation - Petitioner
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`1
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`SONY - Ex.-1002
`Sony Corporation - Petitioner
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`a.) High fidelity class A single ended audio power amplifier using power
`mosfets;
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`b.) Large format HDTV units;
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`c.) A therapeutic medical device for Seasonal Affective Disorder (SAD);
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`d.) Small pocket projectors using high power LEDs;
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`e.) A variety of LCD flat panel backlight units (BLUs) using either CCFLs
`or high power LEDs;
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`f.) Various power supplies, voltage regulators and current regulators for
`numerous projects such as signal generators, frequency counters, stepper
`motor drivers, and railroad warning signals.
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`6.
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`The thermal management of power dissipating devices and assemblies in
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`enclosures has been part and parcel of most of my projects throughout my career.
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`7.
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`Additional details about my employment history, fields of expertise, and
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`publications are included in my curriculum vitae, attached as Ex. A.
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`8.
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`I have reviewed the ’148 patent as well as its prosecution history. I have also
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`reviewed U.S. Patent No. 6,317,319 (“Lewis”) and a certified translation of
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`Japanese Published Patent Application No. 11-53061 (“Hanaguchi”). I have further
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`reviewed U.S. Patent No. 6,914,779 (“Askeland”) and U.S. Patent No. 4,860,163
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`(“Sarath”).
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`The ’148 Patent
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`9.
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`The ’148 patent describes a “chassis and housing having an integrated forced
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`air cooling system that preserves the front panel and display appearance generally
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`associated with a rack-mounted electronics chassis system.” ’148 patent, 1:6-11.
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`2
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`2
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`10. Figure 1 of the ’148 patent is a front perspective view of a chassis 10 with a
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`front panel and display module in place. ’148 patent, 1:54-56.
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`11. The chassis 10 includes a base 12 and a top 22, as well as rear 14, left 16,
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`and right 18 side walls. Ex. 1001, 2:37-40. A front panel 20 is also shown.
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`12. Figure 5 of the ’148 patent shows “a top perspective view of the chassis
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`without the front and top panels, but with the display module, showing the internal
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`components and centrifugal blower.” Ex. 1001, 1:65-67, 2:32-34. Figure 5 of the
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`’148 patent is reproduced below with colored annotations.
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`3
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`3
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`13. The chassis includes an inlet vent 30 (green), a centrifugal blower 74 (red),
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`and “baffles” 78 and 79 (blue). See Ex. 1001, 2:41, 3:26-27, 3:37-40. Centrifugal
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`blower 74 includes an inlet port 80 on the top-facing side. Ex. 1001, 3:48-49.
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`14. Figure 6 of the ’148 patent is a “top plain view of the chassis illustrating the
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`internal air flow through the chassis.” Ex. 1001, 2:1-2. Figure 6 of the ’148 patent
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`is reproduced below with colored annotations.
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`4
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`4
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`Intake air flows into the air inlet vent 30 (green), and the path of air entering
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`15.
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`the chamber 60 is influenced by the blower 74. Ex. 1001, 3:17-19, 26-27. The
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`blower 74 “pulls the intake air into its intake port 80” (red), and “move[s] hotter air
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`outwardly through the blower exhaust ports 82, 83 and into the RF PWA chamber
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`62.” Ex. 1001, 3:48-51. The “final air egress from the RF PWA chamber 62 is
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`through one or more exhaust vents 88, 89.” Ex. 1001, 3:60-61. The ’148 patent
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`illustrates internal air flow with a dashed-line arrow path.
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`Background Information
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`16. The use of forced air cooling in an electronic components chassis, including
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`the use of baffles to provide horizontally non-linear air flow paths from a housing
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`inlet to a fan inlet, was well known before April 15, 2003.
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`5
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`5
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`17. For example, U.S. Patent No. 4,860,163 (“Sarath”) discloses “an
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`arrangement for cooling an electronic assembly of heat generating components
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`mounted in an equipment cabinet.” Sarath, 1:7-9. According to Sarath, “a flow
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`control baffle” is provided to “direct cooling gas entering the front of the cabinet to
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`the rear of the circuit packs and thence around the backplane to a plenum formed
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`by the backplane and a rear surface of the cabinet where the gas is exhausted by
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`convection.” Sarath, 1:51-63. Figures 2 (a perspective view) and 3 (a top view) of
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`Sarath, annotated and reproduced below, illustrates the flow control baffles 30, 31
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`(green) that provide a horizontally non-linear air flow path (blue) from the housing
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`inlet 11 to an inlet of the fan 19.
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`6
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`6
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`18. U.S. Patent No. 6,914,779 (“Askeland”) discloses a computing device
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`having “a housing with various electrical and/or mechanical components included
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`7
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`7
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`
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`therein.” Askeland, Abstract. According to Askeland, a carriage 24 accommodates
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`a baffle 120, which is “adapted to control the movement of air as the air passes into
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`the interior of housing 20 and exits from housing 20.” Askeland, 10:19-22. Figure
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`5 of Askeland, annotated and reproduced below, illustrates the baffle 120 (green)
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`and the horizontally non-linear air flow path (blue) between housing inlet vent 36
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`and the inlet port of fan 80.
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`19. Hanaguchi discloses an electronic device casing 3 that includes baffles 12
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`that direct air flow from an inlet vent 3b to an inlet port of a blower 1. Figure 3(a)
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`of Hanaguchi, annotated and reproduced below, illustrates the baffles 12 (green)
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`directing air flow through a horizontally non-linear flow path, indicated by arrows,
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`from the inlet vent 3b and the inlet port of the blower 1.
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`8
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`8
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`Combination of Lewis and Hanaguchi -
`Claims 1, 2, and 4
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`
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`20.
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`It would have been obvious to utilize baffles, such as those described by
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`Hanaguchi, to provide horizontally non-linear flow paths for cooling air in
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`electronic devices, such as those disclosed by Lewis.
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`A.
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`Lewis
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`21. Lewis notes that the “components of a computer, telecommunications switch
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`or other microprocessor-based device are usually contained within an enclosure or
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`housing” and that “[w]hen the device is powered up, these components become
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`heated.” Lewis, 1:10-14. According to Lewis, “such devices invariably include
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`some means for circulating air through the enclosure to conduct heat away from
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`these components,” Lewis, 1:17-19.
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`9
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`9
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`
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`22. Lewis describes three classes of computers and devices: (1) those “having a
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`relatively high profile enclosure;” (2) “thin computers and devices;” and (3) “low
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`profile computers.” For computers and devices “having a relatively high profile
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`enclosure,” Lewis states that “it may suffice to provide fans at the perimeter of the
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`enclosure to circulate air through the enclosure;” for “thin computers and devices,”
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`Lewis states that “it is usually necessary to supplement the perimeter fans with a
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`fan or blower which conducts the cooling air directly to and from the CPU chip in
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`the enclosure.” Lewis, 1:21-28. For “low profile computers,” Lewis observes that
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`“such cooling means … do not suffice to cool higher rated chips in the low profile
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`computers.” Lewis, 1:28-33. Thus, according to Lewis, its objectives include
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`providing “a cooling assembly for efficiently cooling a high power-rated CPU chip
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`in a low profile computer.” Lewis, 1:38-41.
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`23. Lewis’s cooling assembly includes “flexible air baffles which direct the
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`outlet air from the heat sink smoothly around the corners to a tube-axial exhaust
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`fan on the opposite wall of the enclosure from the inlet fans,” Lewis, 2:8-14, and
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`“is easily installed in an enclosure less than two inches thick and, when installed, it
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`can efficiently cool a CPU chip having a power rating of 80 watts or more,” Lewis,
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`2:15-18. Figure 1, reproduced below, is a plan view of a low profile computer
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`incorporating Lewis’s cooling assembly. Lewis, 2:26-28.
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`10
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`10
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`
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`
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`24. As illustrated in Figure 1, a horizontally non-linear air flow path is provided
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`between the inlet vent (e.g., at fans 24) and the inlet port of the blower 44, as
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`indicated by the arrows “AIN.”
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`B. Hanaguchi
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`25. Hanaguchi describes “a thin, portable electronic device” and “an electronic
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`device having a heat-generating component requiring cooling, at the interior.”
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`Hanaguchi, ¶ [0001].
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`11
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`11
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`
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`26. Hanaguchi notes that thin, portable electronic devices, such as laptops,
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`generate increasingly more heat as performance improves over the years.
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`Hanaguchi, ¶ [0002]. According to Hanaguchi, the increase of heat generated by
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`CPUs has resulted in the increase in the size of cooling fan and heat dissipation
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`components, e.g., heatsinks, heatpipes, etc., thereby “making it difficult to reduce
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`the weight and reduce the thickness of the electronic device.” Hanaguchi, ¶ [0005].
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`27. Thus, Hanaguchi states that one of its objectives “is to provide an electronic
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`device having an air-cooling structure, which can increase the air-cooling effect in
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`a simple manner, without changing the size of the cooling fan or the heatsink.”
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`Hanaguchi, ¶ [0006]. Hanaguchi achieves this improved cooling structure by using,
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`for example, ribs and structural members in a casing to partition the space and
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`control the flow of air. Hanaguchi, ¶ [0007]. In this manner, heat generating
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`components can be arranged in the flow path to be air cooled and to minimize air
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`resistance. Hanaguchi, ¶ [0008]. Figure 3(a), reproduced below, is a perspective
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`view of the interior of the electronic device.
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`12
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`12
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`28. As indicated by the arrows in Figure 3(a), baffle walls 12 provide for a
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`horizontally non-linear air flow path from the inlet port 3b, to the fan 1, and then to
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`the exhaust port 3c. Hanaguchi, ¶ [0020].
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`i.
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`Claim 1
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`29.
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`It would have been obvious to utilize Hanaguchi’s baffle walls 12 in Lewis’s
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`cooling assembly to direct the flow of air in a horizontally non-linear path to
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`effectively and efficiently cool the heat-generating components located within
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`Lewis’s enclosure 10.
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`30. Claim 1 describes “electronic chassis and housing having an integrated force
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`air cooling system.” Lewis discloses an electronic chassis and housing having an
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`integrated forced air cooling system. Lewis discloses, for example, “an enclosure
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`13
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`13
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`
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`housing at least one CPU chip mounted to a motherboard within the enclosure,”
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`Lewis, 1:55-57, i.e., an electronic chassis and housing.
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`31. Lewis further discloses a cooling assembly (force air cooling system)
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`incorporated into the enclosure. Lewis, 2:38-40. The cooling assembly utilizes
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`“force air cooling” via multiple tube-axial fans mounted on the perimeter of the
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`enclosure, Lewis, 2:57-62, as well as a centrifugal blower, Lewis, 3:25-45. For
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`example, according to Lewis, the blower assembly “draws air into the housing
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`through opening 48” and “expels the air through the exit opening 52.” Lewis, 3:33-
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`37.
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`32. Hanaguchi describes an electronic device that includes a casing (electronic
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`chassis and housing) having an air-cooling structure (force air cooling system).
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`Hanaguchi, ¶ [0014]. For example, Hanaguchi discloses a cooling fan that
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`“generates a flow of air, and this increases the cooling effect, by suctioning and
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`discharging air.” Hanaguchi, ¶ [0014].
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`33. Claim 1 describes that the electronic chassis and housing includes “a
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`housing having a top, a base and front, back, left and right side walls which define
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`an interior space having a predetermined height, as measured between the top and
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`the base.” Lewis discloses a housing having a top, a base and front, back, left and
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`right side walls which define an interior space having a predetermined height, as
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`measured between the top and the base. Lewis discloses, for example, an enclosure
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`14
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`14
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`
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`(housing) that includes “a front wall 10a, a rear wall 10b, a pair of opposite side
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`walls 10c, 10c, as well as a top wall 10d and a bottom wall 10e.” Lewis, 2:38-45.
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`The “front wall 10a” and “rear wall 10b” of Lewis correspond to the front and back
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`“side walls” as described in claim 1. The “top wall 10d” and “bottom wall 10e” of
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`Lewis correspond to the “top” and “base” as described in claim 1. Lewis’s
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`enclosure 10 is illustrated in Figures 1 and 2, reproduced below, highlighting the
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`front wall 10a, rear wall 10b, opposite side walls 10c, top wall 10d, and bottom
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`wall 10e.
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`
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`15
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`15
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`
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`34. Lewis further discloses that the enclosure 10 is “a so-called low profile
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`enclosure having a height or thickness in the order of only two inches or less, e.g.
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`1U.” Lewis, 2:43-45. The enclosure of Lewis has a predetermined height, e.g., of
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`two inches or less, between the top wall 10d and the bottom wall 10e. Lewis, 1:33.
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`35. Hanaguchi discloses an electronic device having a casing 3, corresponding
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`to the housing as described in claim 1. The casing 3 includes peripheral sidewalls
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`(e.g., Hanaguchi, ¶ [0009]), corresponding to the front, back, left, and right side
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`walls, which define an interior space, as described in claim 1. The casing also
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`includes a “ceiling 3e” and a “bottom surface 3f” (e.g., Hanaguchi, ¶ [0019]),
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`which correspond to the top and base as described in claim 1. As illustrated in
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`Figure 3b, reproduced below, the interior space of Hanaguchi’s casing has a
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`16
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`16
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`
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`predetermined height, as measured between the ceiling 3e and the bottom surface
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`3f.
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`
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`36. Claim 1 describes that the electronic chassis and housing includes “an inlet
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`vent in at least one side wall and an exhaust vent in an opposed side wall.” Lewis
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`discloses an inlet vent in at least one side wall and an exhaust vent in an opposed
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`side wall. Lewis discloses, for example:
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`One or more tube-axial fans 24 are mounted to the enclosure front
`wall 10a for conducting cooling air into the enclosure 10 as shown by
`the arrows AIN and one or more exhaust or purging fans 26 are
`mounted to the enclosure rear wall 10b to conduct heated air out of
`enclosure 10 as shown by arrow AOUT. (Lewis, 2:57-62).
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`37. Lewis’s Figure 1, reproduced below, illustrates front wall 10a and rear wall
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`10b (both highlighted) being opposed and also illustrates airflow through front wall
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`10a and through rear wall 10b. The inlet vent is at tube-axial fans 24, and the
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`exhaust vent is at purging fans 26.
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`17
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`17
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`
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`38. Hanaguchi’s electronic device includes “suction holes provided in the
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`electronic device casing for taking in outside air” and “discharge holes,” through
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`which “warmed air is discharged to the exterior of the electronic device casing.”
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`Hanaguchi, ¶¶ [0014]-[0015]. Hanaguchi’s suction holes 3b correspond to an inlet
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`vent, and the discharge holes 3c correspond to an exhaust vent.
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`39. Claim 1 describes that the electronic chassis and housing includes “a
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`centrifugal blower assembly having defined top and bottom planes and perimeter
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`walls.” Lewis discloses a centrifugal blower assembly having defined top and
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`bottom planes and perimeter walls. As illustrated in Lewis’s Figure 2, reproduced
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`18
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`18
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`
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`and annotated below, the centrifugal blower assembly 44, has a top plane (yellow),
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`a bottom plane (blue), and perimeter walls (green).
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`
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`40. The centrifugal blower 44 of Lewis’s cooling assembly 32 corresponds to
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`the “centrifugal blower assembly” described in claim 1. Centrifugal blower
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`assembly 44 includes “a housing 46 having a large area inlet opening 48 in the
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`bottom wall of the housing and an exit opening 52 at the side of the housing.”
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`Lewis, 3:29-32. As shown in the annotated figure 2 of Lewis above, the centrifugal
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`19
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`19
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`blower assembly 44’s housing 46 has a defined top plane (yellow), bottom plane
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`(blue), and perimeter walls (green).
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`41. Hanaguchi’s electronic device has an air-cooling structure, which includes
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`“a cooling fan, which generates a flow of air … by suctioning and discharging air.”
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`Hanaguchi, ¶ [0014].
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`42. Claim 1 describes that the electronic chassis and housing includes “a second
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`predetermined height measured between the top and bottom planes that is less than
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`the predetermined height of the interior space.” Lewis discloses a second
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`predetermined height measured between the top and bottom planes that is less than
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`the predetermined height of the interior space. As illustrated in Figure 2, Lewis’s
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`centrifugal blower 44 (centrifugal blower assembly) has a rectangular exit opening
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`52, which “has the same dimensions as the end openings into the heat sink channel
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`34.” Lewis, 3:29-34. Thus, the centrifugal blower assembly 44 has a predetermined
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`height measured between the top and bottom planes.
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`43. The centrifugal blower assembly 44 has a predetermined height that is less
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`than the predetermined height of the interior space because it is positioned inside
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`the interior space: i.) with a baffle on top; and ii.) with space between the bottom
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`The centrifugal blower assembly 44 has a predetermined height that is less than the
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`plane and the bottom of the enclosure 10. The cooling assembly 32, which includes
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`the centrifugal blower assembly, is positioned inside enclosure 10 (Lewis, 2:63-
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`20
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`20
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`
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`3:45), with baffle element 74 between the centrifugal blower assembly 44 and the
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`enclosure 10 (see Lewis, Fig. 2). Additionally, the cooling assembly 32, which
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`includes centrifugal blower assembly 44, does not extend to the bottom plane of
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`the interior space of enclosure 10:
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`When the cooling assembly 32 is secured thusly to chip 18, it is
`important to note that blower 44 extends out beyond the edge of
`motherboard 16 so that the blower inlet opening 48 is completely
`unobstructed. (Lewis, 3:63-66 (emphasis added)).
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`44. This can be further seen in Figure 3 of Lewis, in which cooling air AIN can
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`be seen to flow under then into the centrifugal blower 44. The predetermined
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`height measured between the top and bottom planes of centrifugal blower assembly
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`44 is thus less than the predetermined height of the interior space of the enclosure
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`10.
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`45. Hanaguchi’s electronic device includes “a cooling fan provided within a
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`casing.” Thus, the height of the cooling fan is less than the height of the interior of
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`the casing.
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`46. Claim 1 describes a centrifugal blower assembly having “inlet and outlet
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`ports.” Lewis discloses a centrifugal blower assembly having inlet and outlet ports.
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`Lewis discloses, for example, that the centrifugal blower housing 46 (of the
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`centrifugal blower assembly 44) has “a large area inlet opening 48 in the bottom
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`wall of the housing.” Lewis, 3:25-34. The inlet opening 48 corresponds to the inlet
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`21
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`21
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`
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`port as described in claim 1. According to Lewis, “cooling air is sucked into the
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`blower [44] and discharged through heat sink 33.” Lewis, 4:58-60. The “exit
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`opening 52” of the blower 44 corresponds to the outlet port as described in claim 1.
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`47. Hanaguchi discloses an electronic device that includes “a cooling fan, which
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`generates a flow of air … by suctioning and discharging air.” Hanaguchi, ¶ [0014].
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`48. Claim 1 describes that “the blower assembly is mounted within the interior
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`space such that its inlet port is in fluid communication with the inlet vent and its
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`exhaust port is in fluid communication with the exhaust vent.” Lewis discloses that
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`the blower assembly is mounted within the interior space such that its inlet port is
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`in fluid communication with the inlet vent and its exhaust port is in fluid
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`communication with the exhaust vent. As noted above: an inlet vent is disclosed in
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`Lewis at the location of fans 24; an exhaust vent is disclosed at fan 26; an inlet port
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`to the blower is indicated at 48; and an outlet port Lewis is indicated at the exit
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`opening 52 of the blower assembly 44. According to Lewis:
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`When fans 24 and 26 and cooling assembly 32 are in operation, air is
`drawn into enclosure 10 as shown by the arrows AIN in FIG. 1, with
`the flow of that incoming air being directed to the inlet opening 48 of
`blower 44. That cooling air is sucked into the blower and discharged
`through the heat sink 33…. As the heated air AOUT nears exhaust fan
`26, it is again redirected 90° by skirt 88 directly into fan 26 so that the
`flow rate of the heated air exiting enclosure 10 is maximized. (Lewis,
`4:55-5:2.)
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`22
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`22
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`
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`49. The air flow path is illustrated in Figure 1 of Lewis, reproduced below,
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`between AIN and AOUT.
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`
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`
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`50. Thus, the inlet port 48 of the centrifugal blower assembly 44 is in fluid
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`communication with the inlet vent 24, and the exhaust port 52 of the centrifugal
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`blower assembly 44 is in fluid communication with the exhaust vent 26.
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`51.
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`In Hanaguchi’s electronic device, “air taken in from the exterior of the
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`electronic device casing 3 through the suction holes 3b is suctioned by the cooling
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`fan 1, … after air-cooling the heatsink, the warmed air is discharged to the exterior
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`of the electronic device casing 3, from the discharge holes 3c.” Hanaguchi, ¶
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`[0015]. Thus, the inlet port of the cooling fan 1 is in fluid communication with the
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`23
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`23
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`
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`
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`inlet vent 3b, and the exhaust port of the cooling fan 1 is in fluid communication
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`with the exhaust vent 3c.
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`52. Claim 1 describes that the electronic chassis and housing includes “a baffle,
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`positioned within the interior space so that it directs the flow of air from the inlet
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`vent through a horizontally non-linear path to the blower inlet port.” Lewis
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`discloses a baffle positioned within the interior space, and cooling air flows from
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`the inlet vent through a horizontally non-linear path to the blower inlet port.
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`53. For example, Lewis discloses a baffle member 74, which includes a front
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`wall 78a, having a rectangular extension 84, a top wall 76, having an end extension
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`86, and a skirt 88. Lewis, 4:25-35. According to Lewis, “[w]hen fans 24 and 26
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`and cooling assembly 32 are in operation, air is drawn into the enclosure 10 as
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`shown by the arrows AIN in FIG. 1, with the flow of that incoming air being
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`directed to the inlet opening 48 of blower 44.” Lewis, 4:55-58. In addition to
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`“prevent[ing] recirculation of … heated air from the heat sink 33 back to the
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`blower inlet 48,” as mentioned by Lewis at 5:2-4, the baffle member 74 directs air
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`from the inlet vents 24 to the inlet 48 of the centrifugal blower assembly 44.
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`54. Baffle member 74 is illustrated and highlighted in yellow in Figure 2 of
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`Lewis, reproduced below.
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`24
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`24
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`
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`
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`In the absence of the baffle member 74, exhaust gas from the heat sink 33
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`55.
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`could be recirculated to the inlet 48 of the centrifugal blower 44, and cooling air
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`drawn into the enclosure 10 by the fans 24 and discharged by fan 26 could bypass
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`the cooling assembly. Thus, baffle member 74 directs the flow of air from the inlet
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`vent 24 to the blower inlet port 48.
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`56. The flow of air from the inlet vent 24 to the blower inlet port 48 follows a
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`“horizontally non-linear path.” For example, the annotated Figure 1 of Lewis,
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`25
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`25
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`
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`reproduced below, shows the horizontally non-linear air-flow path (yellow) from
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`the inlet vents 24 (blue) to the blower inlet port 48 (green).
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`
`
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`57. Hanaguchi discloses a baffle positioned within the interior space so that it
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`directs the flow of air from the inlet vent through a horizontally non-linear path to
`
`the blower inlet port. For example, Hanaguchi discloses an inlet vent 3b and an
`
`exhaust vent 3c, as illustrated below in an annotated Figure 3a. Hanaguchi, ¶¶
`
`[0014], [0019]-[0020].
`
`26
`
`26
`
`
`
`
`
`
`58. Hanaguchi further discloses elastic plates 12 (blue), which are baffles.
`
`Hanaguchi, ¶¶ [0019]-[0021]. According to Hanaguchi, “[t]he air is taken in
`
`through the suction hole 3b passes through the flow-path that is bounded by the
`
`elastic plates 12 and flows to the cooling fan 1 as indicated by arrows [highlighted
`
`in yellow].” Hanaguchi, ¶ [0020]. As seen above, baffles 12 (highlighted in blue)
`
`direct air from the inlet vent 3b to the inlet port of the blower 1 though a
`
`“horizontally non-linear path.”
`
`59. Claim 1 describes that “the baffle is comprised of at least one blower
`
`assembly side wall that extends upwardly beyond the top plane and contacts the
`
`top of the housing.” Lewis discloses a baffle comprised of at least one blower
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`assembly side wall that extends upwardly beyond the top plane and contacts the
`
`top of the housing. For example, as explained above, Lewis discloses a baffle
`
`member 74, including extension 84 and skirt 88. In the annotated Figure 2 of
`
`27
`
`27
`
`
`
`Lewis, reproduced below, extension 84 of baffle member 74 is highlighted in
`
`yellow, and skirt 88 of baffle member 74 is highlighted in green.
`
`
`
`
`
`60. The top plane of Lewis’s centrifugal blower assembly is, as explained above,
`
`the portion of centrifugal blower 44 highlighted in red above. According to Lewis,
`
`“extension 84 [yellow] and skirt 88 [green] extend the full height of the enclosure
`
`10 interior.” Lewis, 4:51-52. The extension 84 (yellow) and skirt 88 (green), which
`
`are portions of baffle 74, thus extend upwardly beyond the top plane (red) and
`
`contact the top of the enclosure (housing) 10.
`
`28
`
`28
`
`
`
`61. Baffle member 74 of Lewis includes at least one blower assembly side wall,
`
`in a configuration comparable to the baffle illustrated in Figure 5 of the ’148
`
`patent.
`
`
`
`62. Lewis discloses, for example, skirt 88 of baffle member 74, which abuts
`
`centrifugal blower assembly 44, as show in Lewis’s Figure 3, annotated below:
`
`
`
`
`
`29
`
`29
`
`
`
`63.
`
`Thus, Lewis’s “depending skirt 88,” for example, of baffle member 74
`
`corresponds to “at least one blower assembly side wall that extends upwardly
`
`beyond the top plane and contacts the top of the housing.”
`
`64.
`
`The front wall 78a of the baffle member 74, which includes extension 84
`
`that “extend[s] the full eight of enclosure 10 interior,” Lewis, 4:25-27, 4:51-52,
`
`also constitutes a “side wall that extends upwardly beyond the top plane and
`
`contacts the top of the housing.”
`
`65. Additionally, referring to Figure 3(b), reproduced below, Hanaguchi
`
`discloses that “elastic plates 12 are mounted in pressing contact between the circuit
`
`board 2 and the ceiling 3e of the electronic device casing 3, and between the
`
`bottom surface 3f and the ceiling 3e of the electronic device casing 3.” Hanaguchi,
`
`¶ [0019].
`
`66.
`
`It would have been obvious to include Hanaguchi’s elastic plates 12 in
`
`Lewis’s cooling assembly, to provide for effective cooling of the CPU and to
`
`provide for effective cooling of components, such as components 22a, 22b, 22c, …
`
`30
`
`30
`
`
`
`
`
`22n (described by Lewis) and heat generating components 10 (described by
`
`Hanaguchi), located upstream of the CPU.
`
`67.
`
`In such a combination, the “baffle” includes Lewis’s baffle member 74 and
`
`Hanaguchi’s elastic plates 12, which direct the flow of air from the inlet vent (at
`
`axial fan 24 of Lewis; suction hole 3b of Hanaguchi) through a horizontally non-
`
`linear flow path to the blower inlet port (Lewis’s opening 48 of blower 44; inlet
`
`port of Hanaguchi’s cooling fan 1). In this combination, the “baffle,” which
`
`includes Lewis’s baffle member 74 and Hanaguchi’s elastic plates 12, includes at
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`least one blower assembly side wall that extends upwardly beyond the top plane
`
`and contacts the top of the housing. The baffle extends upwardly for example in
`
`the form of Lewis’s depending skirt 88, which, as mentioned above “extend[s] the
`
`full height of enclosure 10 interior,” Lewis, 4:50-51. The front wall 78a of the
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`baffle member 74, which includes extension 84 that “extend[s] the full eight of
`
`enclosure 10 interior,” Lewis, 4:25-27, 4:51-52, also constitutes a “side wall that
`
`extends upwardly beyond the top plane and contacts the top of the housing.”
`
`ii.
`
`Claim 2
`
`68. Claim 2 describes that “the baffle is positioned between the housing inlet
`
`vent and said blower inlet port.” Lewis discloses that a baffle is positioned between
`
`the housing inlet vent and the blower inlet port. As illustrated in Figure 1,
`
`31
`
`31
`
`
`
`reproduced below, the baffle member 74 is located between the inlet vents 24 and
`
`the inlet 48 of the centrifugal blower assembly 44.
`
`
`
`69. Additionally, as illustrated in Figure 3a of Hanaguchi, reproduced below, the
`
`baffles 12 are positioned between the housing inlet vent 3b and the inlet port of the
`
`
`
`blower 1.
`
`32
`
`32
`
`
`
`
`
`
`
`iii. Claim 4
`
`70. Claim 4 describes that “the blower is centrally located within the interior
`
`space.” Lewis discloses that the blower is centrally located within the interior
`
`space. For example, as illustrated in Figure 1, reproduced below, the centrifugal
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`blower assembly 44 is centrally located.
`
`33
`
`33
`
`
`
`
`
`
`71. Lewis also describes that “[w]hen the cooling assembly 32 is secured thusly
`
`to chip 18, it is important to note that blower 44 extends out beyond the edge of
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`motherboard 16 so that the blower inlet opening 48 is completely unobstructed.”
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`Lewis, 3:63-66.
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`72. Additionally, it was conventional and well-known before April 2003 to
`
`position a blower within a housing to achieve the desired air flow path. For
`
`example, Askeland acknowledges that “the particular position of the hard disk
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`assembly, the processor assembly [which includes a fan 80], the motherboard
`
`assembly, the power assembly, and the baffle are variable to accommodate or
`
`result in differing flow paths of the air circulate [sic] through the interior of the
`
`computing device.” Askeland, 2:59-63.
`
`34
`
`34
`
`
`
`
`
`73. Moreover, the ’148 patent does not ascribe any criticality to the location of
`
`the blower, such that locating providing the blower “centrally located within the
`
`interior space” would have been obvious, particularly in view of Askeland’s
`
`recognition that the location of, for example, the blower, can accommodate or
`
`result in the desired flow path.
`
`74. Claim 4 describes that “the blower … includes a fan having a diameter
`
`greater than the predetermined height.” Lewis discloses that centrifugal blower
`
`assembly 44 is a low profile centrifugal blower. Lewis, 3:26-29. The blower 44
`
`includes a blower housing 46 that “contains a motor driven rotor 54 which, when
`
`operating draw air into the housing through opening 48 and expels the air through
`
`the exit opening 52.” Lewis, 3:33-36. Lewis explains that using its cooling
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`assembly 32, which includes centrifugal blower assembly 44, “heat can be drawn
`
`efficiently and effectively away from CPU chip 18,” Lewis, 4:1-3, and that
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`“cooling air is sucked into the blower and discharged through the heat sink 33 at a
`
`relatively high flow rate thereby efficiently and effectively conducting heat away
`
`from the heat sink and CPU chip 18,” Lewis, 4:58-62.
`
`75. Additionally, it was conventional and well-known before April 2003 to
`
`provide a fan having a larger diameter than the height of the housing. For example,
`
`Askeland describes that the fan “has a diameter greater than a height dimension of
`
`the housing of the computing device” and that “[b]y configuring the fan with a
`
`35
`
`35
`
`
`
`
`
`large diameter, a relatively large flow of air is drawn into and forced from the
`
`housing of the computing device to fool the components of the computing device
`
`using a fan having a relatively low number of revolutions per minute.” Askeland,
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`3:30-35. According to Askeland, the “relatively low rotation
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