`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`MITSUBA CORPORATION AND AMERICAN MITSUBA CORPORATION
`Petitioners
`v.
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`______________
`Case No.: IPR2017-_____
`Patent No. 7,067,952
`Title: Stator Assembly Made from a Molded
`Web of Core Segments and Motor Using Same
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,067,952
`
`
`
`

`

`
`
`I.
`
`C.
`
`TABLE OF CONTENTS
`MANDATORY NOTICES (37 C.F.R. § 42.8) ............................................... 1
`A.
`37 C.F.R. § 42.8(b)(1): Real Party-In-Interest ...................................... 1
`B.
`37 C.F.R. § 42.8(b)(2): Related Matters ............................................... 1
`1.
`Procedural History Regarding Related Matters .......................... 2
`2.
`IPR Should Be Instituted Over IPR2017-01497 Because
`Mitsuba’s Petition Does Not Present The Same Or
`Substantially The Same Prior Art Or Arguments ....................... 3
`37 C.F.R § 42.8(b)(3)-(4): Lead And Back-Up Counsel And
`Service Information ............................................................................... 6
`PAYMENT OF FEES (37 C.F.R. § 42.103) ................................................... 6
`II.
`III. GROUNDS FOR STANDING (37 C.F.R. § 42.104(A)) ................................ 7
`IV.
`IDENTIFICATION OF CHALLENGE (37 C.F.R. § 42.104(B)) .................. 7
`V.
`BACKGROUND ON THE ’952 PATENT ..................................................... 9
`A.
`Level Of Ordinary Skill ......................................................................... 9
`B.
`Description Of The Alleged Invention Of The ’952 Patent .................. 9
`C.
`Priority Date ........................................................................................ 12
`D.
`Claim Construction ............................................................................. 14
`VI. REASONABLE LIKELIHOOD THAT CLAIMS 10-12 ARE
`UNPATENTABLE ........................................................................................ 14
`A. Ground 1: Claims 10 And 12 Are Anticipated By Suzuki, And
`Claim 11 Is Rendered Obvious By Suzuki In View Of
`Nakatsuka. ........................................................................................... 14
`1.
`Claim 10: Anticipated By Suzuki ............................................. 14
`2.
`Claim 12: Anticipated By Suzuki ............................................. 23
`3.
`Claim 11: Obvious Over Suzuki In View Of Nakatsuka. ......... 26
`i
`
`
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`

`

`
`
`B.
`
`C.
`
`Ground 2: Claims 10 And 12 Are Anticipated By Ishihara, And
`Claim 11 Is Rendered Obvious By Ishihara In View Of
`Nakatsuka. ........................................................................................... 29
`1.
`Claim 10: Anticipated By Ishihara ........................................... 30
`2.
`Claim 12: Anticipated By Ishihara ........................................... 37
`3.
`Claim 11: Obvious Over Ishihara In View Of Nakatsuka. ....... 39
`Ground 3: Claims 10 And 12 Are Rendered Obvious By Iikuma
`And/Or Iikuma In View Of Scherzinger, And Claim 11 Is
`Rendered Obvious By Iikuma In View Of Nakatsuka And/Or
`Iikuma In View Of Nakatsuka And Scherzinger. ............................... 42
`1.
`Claim 10: Obvious Over Iikuma And/Or Iikuma In View
`Of Scherzinger. ......................................................................... 42
`Claim 12: Obvious Over Iikuma And/Or Iikuma In View
`Of Scherzinger. ......................................................................... 52
`Claim 11: Obvious Over Iikuma In View Of Nakatsuka
`And/Or Iikuma In View Of Nakatsuka And Scherzinger. ........ 54
`VII. CONCLUSION .............................................................................................. 58
`
`
`
`
`2.
`
`3.
`
`
`
`ii
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`
`
`Petitioners Mitsuba Corporation and American Mitsuba Corporation
`
`(collectively, “Mitsuba”) request inter partes review (“IPR”) of claims 10-12
`
`(collectively, the “Challenged Claims”) of U.S. Patent No. 7,067,952 (the “’952
`
`patent”) (Ex. 1001).
`
`I. MANDATORY NOTICES (37 C.F.R. § 42.8)
`A.
`37 C.F.R. § 42.8(b)(1): Real Party-In-Interest
`Mitsuba is the real party-in-interest for Petitioner.
`
`B.
`37 C.F.R. § 42.8(b)(2): Related Matters
`Mitsuba identifies the following judicial or administrative matters that could
`
`affect or could be affected by a decision in this proceeding:
`
`Name
`Intellectual Ventures II LLC v. Honda
`Motor Co., Ltd. et al.
`Intellectual Ventures II LLC v. Denso
`Corp. et al.
`Intellectual Ventures II LLC v.
`Mitsuba Corp., et al.
`Intellectual Ventures II LLC v. Nidec
`Corp., et al.
`Intellectual Ventures II LLC v. Toyota
`Motor Corp. et al.
`Certain Thermoplastic-Encapsulated
`Electric Motors, Components
`Thereof, and Products and Vehicles
`Containing Same
`Toyota Motor Corp. and Denso Corp.
`v. Intellectual Ventures II LLC
`Denso Corp. et al v. Intellectual
`Ventures II LLC
`
`
`
`Case No.
`
`Court /
`Agency
`
`Filed
`
`1:17-cv-00294 D. Del. March 20, 2017
`
`1:17-cv-00297 D. Del. March 20, 2017
`
`1:17-cv-00298 D. Del. March 20, 2017
`
`1:17-cv-00299 D. Del. March 20, 2017
`
`1:17-cv-00300 D. Del. March 20, 2017
`
`337-TA-1052
`IPR2017-
`01497
`IPR2017-
`01631
`
`1
`
`ITC
`
`March 21, 2017
`
`PTAB
`
`June 9, 2017
`
`PTAB
`
`June 16, 2017
`
`

`

`
`
`Certain Thermoplastic-Encapsulated
`Electric Motors, Components
`Thereof, and Products and Vehicles
`Containing Same
`Certain Thermoplastic-Encapsulated
`Electric Motors, Components
`Thereof, and Products and Vehicles
`Containing Same II
`
`
`Dkt. No. 3243
`
`ITC
`
`337-TA-1073
`
`ITC
`
`August 10,
`2017
`
`September 5,
`2017
`
`1.
`Procedural History Regarding Related Matters
`On March 20 and 21, 2017 Intellectual Ventures II LLC (“IV”) sued Mitsuba
`
`and numerous other defendants/respondents in district court and the International
`
`Trade Commission (“ITC”) for alleged infringement of the ’952 patent. Dkt. Nos.
`
`17-cv-00294; -00297; -00298; -00299; -00300; 337-TA-1052 (the “1052
`
`Investigation”). On June 9 and 16, 2017 various Toyota, DENSO, and/or ASMO
`
`entities filed IPR Nos. 2017-01497 and 2017-01631 against the ’952 patent.
`
`On June 20, 2017 the respondents in the 1052 Investigation moved to
`
`terminate the 1052 Investigation after discovering that IV did not own the asserted
`
`patents, including the ’952 patent. On August 3, 2017 the Administrative Law Judge
`
`entered an initial determination finding that IV was not the owner of the asserted
`
`patents, including the ’952 patent, and that the 1052 Investigation should be
`
`terminated. On September 19, 2017, the Commission terminated the 1052
`
`Investigation.
`
`
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`2
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`

`
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`On August 11, 2017 IV filed a second complaint in the ITC against Mitsuba
`
`and other respondents for alleged infringement of the ’952 patent. Dkt. No. 3243.
`
`On September 5, 2017 IV withdrew its August 11, 2017 complaint.
`
`On September 5, 2017, IV filed a third complaint in the ITC against Mitsuba
`
`and other respondents for alleged infringement of the ’952 patent. Dkt. No. 3248.
`
`On October 4, 2017, the ITC instituted an Investigation, No. 337-TA-1073, on this
`
`complaint.
`
`2. IPR Should Be Instituted Over IPR2017-01497 Because
`Mitsuba’s Petition Does Not Present The Same Or Substantially
`The Same Prior Art Or Arguments
`On June 9, 2017 Toyota Motor Corporation and DENSO Corporation filed
`
`IPR2017-01497 (the “’1497 IPR”) challenging claims 10-12 of the ’952 patent. Two
`
`of the six references asserted in the ’1497 IPR, Ishihara and Iikuma, are also asserted
`
`in this IPR. However, Mitsuba asserts Ishihara and Iikuma as part of substantially
`
`different grounds and makes substantially different arguments than the arguments
`
`set forth in the ’1497 IPR. Therefore, the ’1497 IPR should have no impact on the
`
`institution of this petition.
`
`Ishihara. Ground 1 of the ’1497 IPR states that claims 10 and 12 are “obvious
`
`over Nakahara in view of Ishihara.” IPR2017-01497, Paper 1 at 23. The present
`
`IPR asserts that Ishihara anticipates claims 10 and 12. More specifically, for these
`
`claims, the ’1497 IPR combines Ishihara with its primary reference, Nakahara, as
`
`
`
`3
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`

`

`
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`part of an obviousness challenge under § 103. In contrast, the instant IPR asserts
`
`that Ishihara anticipates claims 10-12 under § 102. Similarly, with respect to claim
`
`11, the ’1497 IPR combines Ishihara with Nakahara, the primary reference, and Lieu,
`
`another secondary reference. In contrast, the instant IPR asserts that Ishihara, as a
`
`primary reference, in combination with Nakatsuka renders obvious claim 11.
`
`Iikuma. With respect to Iikuma, the ’1497 IPR states that Iikuma in view of
`
`Nakahara renders obvious claim 10, and that Iikuma in view of Nakahara and
`
`Stridsberg renders obvious claim 12. In contrast, the instant IPR asserts that Iikuma
`
`alone renders obvious claims 10 and 12. Additionally, this IPR asserts that claims
`
`10 and 12 are rendered obvious by Iikuma in view of Scherzinger. As to claim 11,
`
`the ’1497 IPR states that Iikuma in view of Nakahara and Lieu renders claim 11
`
`obvious, while this IPR asserts Iikuma in combination with just one other reference,
`
`Nakatsuka, renders obvious claim 11.
`
`Mitsuba also relies on a different expert declarant than the declarant relied on
`
`in the ’1497 IPR. The declarations from those different expert declarants assert
`
`different opinions as to the invalidity of claims 10-12 of the ’952 patent, rely on
`
`different prior art references, and set forth different analysis. Each declarant’s
`
`deposition will differ as well. These evidentiary differences will affect the course
`
`of this trial relative to the course of the trial in the ’1497 IPR. Wockhardt Bio AG v.
`
`Janssen Oncology, Inc., IPR2016-01582, Paper 29 at 18 (PTAB Jan. 19, 2017).
`
`
`
`4
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`

`
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`Further, Mitsuba is not a real party in interest to the ’1497 IPR, nor is any
`
`Toyota or DENSO entity a real party in interest to this IPR, which also favors
`
`institution. Toyota Motor Co. v. Adaptive Headlamp Techs., Inc., IPR2016-01740,
`
`Paper No. 7 at 11 (PTAB Mar. 10, 2017) (“Where the petitioner is not a real party
`
`in interest to a previously filed petition, this factor weighs in favor of institution.”);
`
`Square, Inc. v. Protegrity Corp., CBM2014-00182, Paper No. 16 at 8 (PTAB Mar.
`
`5, 2015). Mitsuba would be prejudiced if institution of its IPR was denied based on
`
`the ’1497 IPR, and Petitioners Toyota and DENSO subsequently withdrew the ’1497
`
`IPR due to settlement or other reasons, leaving no pending challenge to the validity
`
`of the ’952 patent.
`
`The early stage of the ’1497 IPR also weighs in favor of institution. Toyota
`
`Motor Co. v. Adaptive Headlamp Techs., Inc., IPR2016-01740, Paper No. 7 at 10
`
`(PTAB Mar. 10, 2017). Here, the ’1497 IPR is at its earliest possible stage, and the
`
`grounds therein have not yet been “considered” in any written submission by either
`
`IV or the Board. IV has not yet filed its patent owner preliminary response, and the
`
`Board has not issued an institution decision. Because no opposition or decision has
`
`been filed, Mitsuba’s IPR is not an attempt to “take a second bite at the apple” to
`
`cure any alleged deficiencies in the ’1497 IPR. Further, the timing of Mitsuba’s IPR
`
`was directly affected by the Respondents’ June 20, 2017 motion to terminate the
`
`1052 Investigation. After Mitsuba discovered that IV did not own the ’952 patent,
`
`
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`5
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`
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`there was no reason to burden the Board with a further challenge to it in IPR.
`
`However, after IV acquired ownership of the ’952 patent and accused Mitsuba of
`
`infringement in its second and third complaints filed on August 11, 2017 and
`
`September 5, 2017, respectively, Mitsuba revisited an IPR challenge to the validity
`
`of the ’952 patent. After an investigation was instituted IV’s third ITC complaint on
`
`October 4, 2017, Mitsuba promptly filed this IPR.
`
`C.
`
`37 C.F.R § 42.8(b)(3)-(4): Lead And Back-Up Counsel And Service
`Information
`
`Lead Counsel
`Eric Hayes (Reg. No. 53,004)
`eric.hayes@kirkland.com
`Postal and Hand-Delivery Address:
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`Telephone: (312) 862-2000
`Fax: (312) 862-2200
`
`Back-up Counsel
`Adam Kaufmann (Reg. No. 66,276)
`adam.kaufmann@kirkland.com
`Postal and Hand-Delivery Address:
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`Telephone: (312) 862-2000
`Fax: (312) 862-2200
`
`
`Mitsuba submits a Power of Attorney, 37 C.F.R. § 42.10(b), and consents to service
`
`by e-mail at Mitsuba_IPR@kirkland.com.
`
`II.
`
`PAYMENT OF FEES (37 C.F.R. § 42.103)
`The undersigned authorizes the Office to charge the fee set forth in 37 C.F.R.
`
`§ 42.15(a) to Deposit Account No. 506092. Review of three (3) claims is requested,
`
`thus no excess claim fees are required. The undersigned further authorizes payment
`
`for any additional fees that may be due in connection with this Petition to be charged
`
`to the above-referenced Deposit Account.
`6
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`

`

`
`
`III. GROUNDS FOR STANDING (37 C.F.R. § 42.104(A))
`Mitsuba certifies that it has standing to request, and is not barred or estopped
`
`from requesting, IPR of the ’952 patent. Mitsuba certifies: (1) Mitsuba is not the
`
`owner of the ’952 patent; (2) Mitsuba (or any real party-in-interest) has not filed a
`
`civil action challenging the validity of any claim of the ’952 patent; (3) Mitsuba files
`
`this Petition within one year of the date it was served with a complaint alleging
`
`infringement of the ’952 patent; (4) the estoppel provisions of 35 U.S.C. § 315(e)(1)
`
`do not prohibit this IPR; and (5) this Petition is filed after the ’952 patent was
`
`granted.
`
`IV.
`
`IDENTIFICATION OF CHALLENGE (37 C.F.R. § 42.104(B))
`Mitsuba requests IPR of Claims 10-12 based on the following:
`
`Suzuki. US 6,177,751 to Suzuki. (Ex. 1002). Suzuki is a United States patent
`
`filed on August 20, 1999, issued on January 23, 2001, and is prior art under 35 U.S.C.
`
`§§ 102(a), (b), and (e).1
`
`Ishihara. JP 11-89128 to Ishihara. (Ex. 1003). Ishihara is a Japanese patent
`
`disclosure published on March 30, 1999 and is prior art under 35 U.S.C. §§ 102(a)
`
`and (b).
`
`
`1 Cites to 35 U.S.C. §§ 102 and/or 103 are to the pre-AIA versions applicable here.
`
`
`
`7
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`

`
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`Iikuma. JP H9-308163 to Iikuma. (Ex. 1004). Iikuma is a Japanese patent
`
`disclosure published on November 28, 1997 and is prior art under 35 U.S.C. §§
`
`102(a) and (b).
`
`Scherzinger. US 5,698,923 to Scherzinger. (Ex. 1005). Sherzinger is a
`
`United States patent filed on May 24, 1996, issued on December 16, 1997 and is
`
`prior art under 35 U.S.C. §§ 102(a), (b), and (e).
`
`Nakatsuka. US 6,075,304 to Nakatsuka. (Ex. 1006). Nakatsuka is a United
`
`States patent filed on April 30, 1997, issued on June 13, 2000, and is prior art under
`
`35 U.S.C. §§ 102(a), (b), and (e).
`
`Mitsuba challenges the ’952 patent on the following grounds:
`
`Ground 1: Claims 10 and 12 are anticipated by Suzuki under 35 U.S.C. §
`
`102. Claim 11 is rendered obvious by Suzuki in combination with Nakatsuka under
`
`35 U.S.C. § 103(a).
`
`Ground 2:
`
` Claims 10 and 12 are anticipated by Ishihara under
`
`35 U.S.C. § 102. Claim 11 is rendered obvious by Ishihara in combination with
`
`Nakatsuka under 35 U.S.C. § 103(a).
`
`Ground 3: Claims 10 and 12 are rendered obvious by Iikuma under
`
`35 U.S.C. § 103(a) and/or by Iikuma in combination with Scherzinger under
`
`35 U.S.C. § 103(a). Claim 11 is rendered obvious by Iikuma in combination with
`
`
`
`8
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`

`
`
`Nakatsuka under 35 U.S.C. § 103(a) and/or by Iikuma in combination with
`
`Nakatsuka and Scherzinger under 35 U.S.C. § 103(a).
`
`Petitioner sets forth the relevant background on the ’952 patent (Section V),
`
`how the contested claims are to be construed (Section V), and how the construed
`
`claims are unpatentable under the statutory grounds (Section VI). Attached is an
`
`Appendix of Exhibits. The relevance of the evidence, including identifying the
`
`specific portions of the evidence that support the challenge, is set forth in Section
`
`VI. Petitioner submits a declaration by Dr. Itzhak Green in support of this Petition.
`
`37 C.F.R. § 1.68. (Ex. 1007).
`
`V. BACKGROUND ON THE ’952 PATENT
`A. Level Of Ordinary Skill
`Persons having ordinary skill in the art for the ’952 patent would have a
`
`bachelor’s degree in mechanical or electrical engineering, or an equivalent degree,
`
`and at least two years of work experience relating to the design of electric motors.
`
`Ex. 1007 ¶¶ 44-47.
`
`B. Description Of The Alleged Invention Of The ’952 Patent
`The ’952 patent is titled “Stator Assembly Made from a Molded Web of Core
`
`Segments and Motor Using Same” and relates to “a stator assembly used in a
`
`dynamoelectric machine such as a motor.” Ex. 1001 at 1:1-4; 1:16-21. The ’952
`
`patent depicts an example of a prior art motor, including its stator (labelled “4”) at
`
`Figure 1:
`
`
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`9
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`

`
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`
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`Id. at Fig. 1.
`
`The ’952 patent states that “[i]n conventional spindle motors, stators have
`
`been made by laminating together stamped pieces of steel,” which “are generally
`
`circular in nature, but also have ‘poles’ extending either inwardly or outwardly.” Id.
`
`at 1:30-33. Once laminated together, “[w]ire is then wound around the poles to form
`
`stator windings.” Id. at 1:35-36. After the stator is assembled and incorporated into
`
`a motor, “[t]he stator windings are selectively energized and interact with the
`
`permanent magnet to cause a defined rotation of the hub.” Id. at 1:54-56.
`
`The ’952 patent alleges that prior art stators had “a number of drawbacks,”
`
`caused by designs using “circular steel pieces,” but concedes that “[s]ome of these
`
`problems have been addressed by motor manufacturing methods in which individual
`
`stator arc segments are made and wound with wire to form poles.” Id. at 2:6-7; 2:19;
`
`3:34-36. The ’952 patent also alleges that stators made from individual stator arc
`
`segments have a host of drawbacks, including complex assembly, difficulty winding
`
`
`
`10
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`

`

`
`
`and connecting wires, reduced magnetic flux, large amounts of scrap, and cost. Id.
`
`at 3:39-4:8.
`
`The ’952 patent purports to solve these problem with “a stator assembly
`
`comprising a plurality of discrete stator segments each at least partially encased with
`
`a phase change material, wherein the phase change material also comprises a bridge
`
`between adjacent segments to link adjacent segments into a continuous strip; and the
`
`linked stator segments being arranged and secured together to form the stator
`
`assembly.” Id. at 4:13-22.
`
`The ’952 patent states that a “preferred embodiment” is “shown in F[igures]
`
`2-7 and 9.” Id. at 5:43-45. In this preferred embodiment, Figures 2 and 3 depict a
`
`single stator arc segment pole where “the pole 21 is shown extending inwardly. The
`
`stamped pieces are then coated with encapsulating material 22 which provides
`
`electrical insulation and laminates the pieces together to form a stator arc segment
`
`20, and links other arc segments into a continuous strip via webbing 23”:
`
`
`
`
`
`11
`
`
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`

`

`
`
`Id. at 5:67-6:5; Figs. 2, 3. Figure 5 of the “preferred embodiment” depicts how
`
`“encapsulating material 22 . . . links other arc segments into a continuous strip via
`
`webbing 23”:
`
`
`
`Id. at 6:2-5.
`
`While in the preferred embodiment the stator segments are encased by
`
`encapsulating them with injection-molded phase change material, the specification
`
`makes clear that “the segments 20 could be encased in other ways with a bridging
`
`material.” Id. at 12:53-54. Similarly, while the preferred embodiment in Figure 5
`
`depicts bridging the stator segments using a “re-melt[ed]” strip of webbing to form
`
`“a continuous strip,” the ’952 patent states that the bridge can also be formed by
`
`material that “can mechanically lock” to make “a continuous strip.” Id. at 6:41-45.
`
`C.
`Priority Date
`On its face, the ’952 patent claims priority to May 2, 2001. Claims 10-12,
`
`however, are not entitled to that date because they contain subject matter that was
`
`
`
`12
`
`

`

`
`
`not added until a continuation-in-part application (“CIP”) was filed on March 5,
`
`2003. Ex. 1007 ¶¶ 41-43. Because “[n]ew subject matter [in a CIP] does not receive
`
`the benefit of the earlier priority date,” claims 10-12 are entitled to priority no earlier
`
`than March 5, 2003. Go Med. Indus. Pty., Ltd. v. Inmed Corp., 471 F.3d 1264, 1270
`
`(Fed. Cir. 2006).
`
`Each of claims 10-12 recites “a bridge between adjacent [stator] segments to
`
`link adjacent segments into a continuous strip, wherein the bridge is formed by
`
`interconnecting two mating sections.” Ex. 1001 at claims 10-12. As support for the
`
`claimed “bridge,” the ’952 patent describes linking segments into a continuous strip
`
`using “webbing,” including “plastic webbing” that “can mechanically lock with or,
`
`depending upon design, re-melt, the webbing from the prior cycle, thus making a
`
`continuous strip.” Id. at 6:1-5; 6:35-47.
`
`The ’952 patent’s parent application, which was filed on March 2, 2001 and
`
`to which priority is claimed, contains no such description. Ex. 1008. This parent
`
`application omits any mention of a strip of stator segments linked together, whether
`
`by “webbing,” a “bridge,” or any other mechanism. Ex. 1008 at 3-27. Nor does the
`
`parent application include any of the figures that the ’952 patent uses to depict those
`
`features. Ex. 1008 at 27-32. Those features were described and illustrated, for the
`
`first time, in the March 5, 2003, continuation-in-part application. Ex. 1009 at 381,
`
`398-404.
`
`
`
`13
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`

`
`
`D. Claim Construction
`Claim terms in an IPR are given the broadest reasonable interpretation in light
`
`of the specification. 37 C.F.R. § 42.100(b). For purposes of this Petition, the claims
`
`of the ’952 patent do not require construction and should be given their plain and
`
`ordinary meaning to one having ordinary skill in the art.
`
`VI. REASONABLE LIKELIHOOD THAT CLAIMS 10-12 ARE
`UNPATENTABLE
`A. Ground 1: Claims 10 And 12 Are Anticipated By Suzuki, And
`Claim 11 Is Rendered Obvious By Suzuki In View Of Nakatsuka.
`As set forth in detail below, Suzuki teaches all elements of independent claim
`
`10. Suzuki teaches a stator assembly made of salient poles that are partially encased
`
`in phase change material using bobbins made of resin. The bobbins include
`
`projections that mate with the depressions of adjacent coil bobbins to link the salient
`
`poles into a continuous strip. The salient poles are also secured together to form the
`
`stator assembly using the bobbins and stator case. With respect to claim 12, Suzuki
`
`teaches holding the magnetic pole teeth in a ring shape using a stator core. With
`
`respect to claim 11, Nakatsuka teaches overmolding the stator with thermoplastic
`
`resin.
`
`1.
`
`Claim 10: Anticipated By Suzuki
`a. “A stator assembly”
`Suzuki teaches “a stator assembly.” Suzuki teaches that “the stator 6
`
`comprises six stator yokes 32 and is secured radially inside the case 4.” Ex. 1002 at
`
`
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`14
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`3:19-20. Suzuki further teaches that “each stator yoke 32 comprises a salient pole
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`34, a bobbin 36 for supporting the salient pole 34, and a magnet wire 38 wound
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`around the bobbin 36.” Id. at 3:21-25. Suzuki depicts its assembled stator at Figures
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`2 and 3:
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`
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`Ex. 1002 at Figs. 2, 3. Suzuki’s stator is a stator assembly. Ex. 1007 ¶¶ 57-58.
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`b. “a plurality of discrete stator segments each at least
`partially encased with a phase change material”
`Suzuki teaches “a plurality of discrete segments each at least partially encased
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`with a phase change material.” Suzuki teaches a stator that includes “salient poles”
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`encased with “bobbins” made of “resin.” Suzuki depicts one such salient pole and
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`resin bobbin at Figure 5:
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`15
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`Ex. 1002 at Fig. 5 (annotated and highlighted). Suzuki teaches that “the salient pole
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`34 comprises nine pieces of electromagnetic steel plates, each having a thickness of
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`0.35 mm, punched into a shape of a letter T and laminated in parallel to the shaft.”
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`Id. at 3:26-29. Suzuki’s salient poles are discrete stator segments because they are
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`individual, physically separate pole segments that make up Suzuki’s stator assembly.
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`Ex. 1007 ¶¶ 59-61.
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`Suzuki further teaches a “bobbin 36 which is made of resin.” Ex. 1002 at
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`3:36. Suzuki teaches partially encasing the salient poles with these resin bobbins by
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`inserting the salient pole into the resin bobbin: “[t]he narrowly formed portion of
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`the salient pole 34 of T shape is inserted into a rectangular hole 37 of the bobbin 36,
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`while the elongated portion is so arranged as to project slightly from the bobbin 36
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`toward the rotary shaft 8.” Id. at 3:29-33. Inserting the salient poles into the resin
`16
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`bobbins partially encases them in the resin bobbins. Ex. 1007 ¶¶ 62-65. Resin is a
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`phase change material because it is a viscous liquid that cures into a solid upon
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`activation. Id. ¶¶ 64-65.
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`Suzuki depicts an assembled stator with resin bobbins partially encasing the
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`salient poles in Figure 3:
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`Ex. 1002 at Fig. 3 (annotated and highlighted).
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`
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`c. “wherein the phase change material also comprises a
`bridge between adjacent segments to link adjacent segments
`into a continuous strip, wherein the bridge is formed by
`interconnecting two mating sections formed from the phase
`change material”
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`17
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`Suzuki teaches “wherein the phase change material also comprises a bridge
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`between adjacent segments to link adjacent segments into a continuous strip,
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`wherein the bridge is formed by interconnecting two mating sections formed from
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`the phase change material.” Suzuki’s bobbins comprise a bridge between adjacent
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`salient poles to link the salient poles into a continuous strip. Suzuki further teaches
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`that the bobbin bridge is formed by interconnecting two mating sections of the
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`bobbins.
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`As depicted in Figures 6-9, Suzuki’s bobbins comprise a bridge between
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`adjacent salient poles to link adjacent salient poles into a continuous strip. Id. at
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`Figs. 6-9; Ex. 1007 ¶¶ 66-71. In the embodiments depicted in Figures 6 and 7,
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`Suzuki’s bobbins comprise a bridge formed by interconnecting a projection of one
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`bobbin with a depression of the adjacent bobbin to link the salient poles into a
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`continuous strip: “[i]n the embodiment shown in FIGS. 6 and 7, the bobbin 36 has a
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`projection and a depression on both edge portions of the collar 39 thereof along a
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`longitudinal direction thereof in a mirror image relationship.” Id. at 4:30-34; Ex.
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`1007 ¶ 67, 69. Suzuki further teaches that the projection and depression engage with
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`each other: “[a]s shown in FIG. 6, when two bobbins 36 are brought into engagement
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`with each other, the projection and depression of one bobbin 36 engages those of the
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`other bobbin 36 to be secured with each other.” Id. at 4:33-36. Suzuki depicts this
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`engagement in Figure 6:
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`18
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`Id. at Fig. 6 (annotated and highlighted). Suzuki similarly illustrates how a bridge
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`is formed by interconnecting a projection of one bobbin with a depression of the
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`adjacent bobbin to link the salient poles into a continuous strip in Figure 7:
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`19
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`Id. at Fig 7 (annotated and highlighted); Ex. 1007 ¶ 67.
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`In the embodiments of Figures 8 and 9, Suzuki’s bobbins comprise a bridge
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`formed by interconnecting a pin and hole, or by interconnecting a coupling slot to
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`the adjacent bobbin to link the salient poles into a continuous strip: “[a]s shown in
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`FIG. 8, the collar 39b of a first bobbin 36 may be provided with a pin 41, and the
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`collar 39b of another bobbin 36 to be coupled to the first bobbin may be provided
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`with a hole 43 which can fit the pin 41, so that these two bobbins are coupled.
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`Furthermore, as shown in FIG. 9, a slot 45 may be adopted for coupling.” Id. at
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`4:47-52; Ex. 1007 ¶ 68-69. Suzuki depicts these bridges in Figures 8 and 9:
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`20
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`Id. at Figs. 8, 9 (annotated and highlighted). In the embodiments of Figures 6-9, the
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`bridge is formed by interconnecting two mating sections of the coil bobbin, which
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`Suzuki describes as “mating portions”. Ex. 1002 at 2:20-31; Figs. 6-9; Ex. 1007 ¶¶
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`66-71. In the embodiments of Figures 6-9, the two mating sections, which Suzuki
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`describes as “mating portions” are the “projections and depression,” “pin and hole”
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`or “slot for coupling” that are interconnected to form the bridge that links adjacent
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`magnetic pole teeth into a continuous strip. Id.
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`d. “the linked stator segments being arranged and secured
`together to form the stator assembly.”
`Suzuki teaches “the linked stator segments being arranged and secured
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`together to form the stator assembly.” Suzuki teaches the linked stator segments
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`being arranged and secured together to form the stator assembly using the bobbins,
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`a case, and a resin injection. Ex. 1007 ¶¶ 72-75.
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`Suzuki teaches using the mating portions of the bobbins to arrange and secure
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`the linked salient poles together to form the stator assembly:
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`Furthermore, the stator yoke may be provided, on the edge
`thereof, with a projection and depression so that other
`bobbins are mated with each other. This allows the
`stator yoke to be more secure when stator yokes are
`combined, and allows the securing force to be
`increased as well. The mating portion may have at least,
`but is not necessarily limited to, a projection and a
`depression that allows for no displacement between
`21
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`bobbins; the mating portion may be of a slidable type for
`assembly, may be provided with a pin and a hole for
`insertion, or may be mated with another one by bonding or
`adhesion.
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`Ex. 1002 at 2:20-31 (emphasis added). These bobbins arrange and secure the linked
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`salient poles together to form the stator assembly. Ex. 1007 ¶¶ 73.
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`Suzuki further teaches that the stator is secured inside a case using a resin
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`injection. Ex. 1007 ¶¶ 74-75. Suzuki teaches that “[a]s shown in FIGS. 2 and 3, the
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`stator 6 comprises six stator yokes 32 and is secured radially inside the case 4.” Ex.
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`1002 at 3:19-20. Suzuki depicts the case at Figure 2:
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`Id. at Fig. 2 (annotated and highlighted). Suzuki further teaches that “[m]old resin
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`is injected inside the case 4 of the motor 2 after the stator 6 has been arranged at the
`22
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`predetermined position. As shown in FIG. 2, the resin 58 is filled in between the
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`stator 6 and the case 4, leaving a space at the center for inserting the rotor 10.” Id.
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`at 3:58-62. Figure 1 similarly depicts how the stator is secured to the case using
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`resin:
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`Id. at Fig. 1 (annotated and highlighted). Attaching the stator to the case by injecting
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`resin into the case arranges and secures the salient poles together to form the stator
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`
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`assembly. Ex. 1007 ¶¶ 74-75.
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`2.
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`Claim 12: Anticipated By Suzuki
`a. “the stator assembly of claim 10”
`Suzuki teaches the stator assembly of claim 10, infra § VI.A.1.
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`b. “wherein the stator segments are held in a toroidal shape
`by a retaining member”
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`23
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`Suzuki teaches “wherein the stator segments are held in a toroidal shape by a
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`retaining member.” Suzuki teaches that the stator is held in a ring shape by securing
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`it to a cylindrical case using a resin injection. Ex. 1007 ¶¶ 77-78. Suzuki teaches
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`that “[a]s shown in FIGS. 2 and 3, the stator 6 comprises six stator yokes 32 and is
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`secured radially inside the case 4.” Ex. 1002 at 3:19-20. Suzuki depicts this case at
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`Figure 2:
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`Id. at Fig. 2 (annotated and highlighted). Suzuki further teaches that “[m]old resin
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`is injected inside the case 4 of the motor 2 after the stator 6 has been arranged at the
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`predetermined position. As shown in FIG. 2, the resin 58 is filled in between the
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`stator 6 and the case 4, leaving a space at the center for inserting the rotor 10.” Id.
`24
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`at 3:58-62. Figure 1 similarly depicts how the stator is secured to the case in a
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`toroidal shape using resin:
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`
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`Id. at Fig. 1 (annotated and highlighted). Attaching the stator to the case by injecting
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`resin into the cylindrical case holds the salient poles in a toroidal shape. Ex. 1007 ¶
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`77-78. In addition, a person having ordinary skill in the art would recognize that
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`toroidal shapes would include ring shapes, including Suzuki’s arrangement of salient
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`poles in a ring shape. Id. Indeed, the ’952 patent Figures 8a and 8b disclose “a
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`cross-sectional view of a toroidal core,” depicting “toroidal co