`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`American Honda Motor Co., Inc.
`
`Petitioner,
`
`v.
`
`Intellectual Ventures II LLC,
`
`Patent Owner.
`
`__________________
`
`Case IPR2018-00442
`
`U.S. Patent No. 7,154,200
`
`__________________
`
`
`
`
`DECLARATION OF DR. GERALD JOHN MICKLOW IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF UNITED STATES PATENT
`NO. 7,154,200
`
`
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`Am. Honda v. IV II - IPR2018-00442
`PET_HONDA_1004-0001
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`TABLE OF CONTENTS
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`Introduction ...................................................................................................... 3
`I.
`Summary of Opinions ...................................................................................... 3
`II.
`III. Background and Qualifications ....................................................................... 4
`A.
`Background ........................................................................................... 4
`B.
`Compensation ...................................................................................... 10
`IV. Materials Reviewed ....................................................................................... 11
`V.
`Legal Standards ............................................................................................. 11
`A. Anticipation ......................................................................................... 11
`B. Obviousness ......................................................................................... 12
`VI. Overview of the ’200 Patent .......................................................................... 16
`A.
`Claims of ’200 Patent .......................................................................... 17
`B.
`Background of the Technology ........................................................... 18
`VII. Level of Ordinary Skill .................................................................................. 19
`VIII. Claim Construction ........................................................................................ 20
`IX. Analysis ......................................................................................................... 21
`A. Overview of Koizumi, Takagi, and Trago .......................................... 21
`1.
`Koizumi (Japanese Application Laid-Open No. H4-105538) .. 21
`2.
`Takagi (International Publication No. WO97/33359) .............. 23
`3.
`Trago (International Publication No. WO96/31936) ................ 25
`B. Obviousness of claims 1-2 and 4-7 over Koizumi .............................. 27
`C. Obviousness of claims 1-2 and 4-7 over Takagi ................................. 40
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`D. Obviousness of Claims 1, 2, and 4-5 over Trago [GROUND
`NOT ASSERTED IN PRESENT IPR PETITION}............................ 60
`Obviousness of claims 1, 2, and 4-7 over Trago in combination
`with Koizumi Claims 1, 2, 4, and 5 ..................................................... 78
`
`E.
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`I.
`
`I, Dr. Gerald John Micklow, declare as follows:
`
`Introduction
`1.
`
`I have been asked to submit this declaration on behalf of American
`
`Honda Motor Co., Inc. (“Petitioner”) in connection with a petition for inter partes
`
`review of U.S. Patent No. 7,154,200 (“the ’200 patent”),1 which I have been told is
`
`being submitted to the Patent Trial and Appeal Board of the United States Patent and
`
`Trademark Office by Petitioner.
`
`2.
`
`Specifically, I have been retained as a technical expert by Petitioner to
`
`study and provide my opinions on the technology claimed in, and the patentability or
`
`unpatentability of, claims 1-2 and 4-7 of the ’200 patent (“the Challenged Claims”).
`
`For purposes of this declaration, I was not asked to provide any opinions that are not
`
`expressed herein.
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`II.
`
`Summary of Opinions
`3.
`
`This declaration is directed to the Challenged Claims of the ’200 patent,
`
`and sets forth the opinions I have formed, the conclusions I have reached, and the
`
`bases for each.
`
`4.
`
`Based on my experience, knowledge of the art as of the effective filing
`
`date of the ’200 patent, analysis of prior art references, and the understanding a
`
`1 I understand that the ’200 patent is Exhibit 1001 to the petition for Inter Partes
`
`Review of the ’200 patent.
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`person of ordinary skill in the art would have had of the claim terms in light of the
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`specification as of the effective filing date, it is my opinion that the Challenged
`
`Claims of the ’200 patent are unpatentable as being obvious over the prior-art
`
`references discussed below. In forming my opinions, counsel for Petitioner told me
`
`to assume the effective filing date of the ’200 patent is July 29, 1999.
`
`III. Background and Qualifications
`A. Background
`5.
`I am currently employed as a full Professor of Mechanical and
`
`Aerospace Engineering at Florida Institute of Technology (“FIT”) in Melbourne,
`
`FL. I have been a Licensed Professional Engineer in the State of North Carolina
`
`since December of 2004 and active in the mechanical engineering field for decades,
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`including through my membership in the American Society of Mechanical
`
`Engineers (ASME) since 1988. My mechanical engineering experience was
`
`developed through a variety of academic and industrial projects directed to
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`automotive components, including electric motors. I have been involved in the
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`design and evaluation of advanced power producing systems, such as electric
`
`motors, for over 40 years. I have worked within the areas of automotive engineering,
`
`mechanics of materials, electric motor design, fluid dynamics, and manufacturing
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`methods, and have authored, co-authored, or edited several books and numerous
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`peer-reviewed technical papers in these areas.
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`6. My work on power production systems has resulted in a number of
`
`engineering awards. For example, I was awarded the American Society of
`
`Mechanical Engineers (ASME) Professor of the Year award for the 2015-2016 term.
`
`I am also included in AcademicKeys Who’s Who in Engineering in Higher
`
`Education. Additionally, I provide review and editing services for a wide variety of
`
`mechanical engineering publications, including the American Society of
`
`Engineering Education (ASEE) Southeast Conference (2005-present), the Journal of
`
`Mechanical, Aerospace and Industrial Engineering (2007-present), and the
`
`Proceedings of the Institution of Mechanical Engineers (2007-present), among
`
`others.
`
`7.
`
`I received my Bachelors of Science in Aerospace Engineering from the
`
`Pennsylvania State University (Penn State) in 1975. I obtained my Masters of
`
`Science in Aerospace Engineering from Penn State in 1981. I obtained my Ph.D. in
`
`Mechanical Engineering at the Virginia Polytechnic Institute and State University
`
`(Virginia Tech) in 1989. I attach my current curriculum vitae (CV) as Appendix A to
`
`this Declaration.
`
`8.
`
`I joined Pratt & Whitney in 1976 as a Senior Analytical Design
`
`Engineer. I worked on a wide variety of engineering projects directed to various
`
`aspects of power producing systems and components. For example, I worked on
`
`advanced fan and compressor design, including analysis of flow dynamics related to
`
`
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`rotor and stator blades. Following my time at Pratt & Whitney, I continued working
`
`on advanced design and evaluation of power producing components at Tracor
`
`Aerospace and then Allison Gas Turbines until 1982. While at Allison Gas Turbines,
`
`I received funding to research aspects of power production systems related to rotors
`
`and stators.
`
`9.
`
`I joined the Mechanical Engineering Department at Virginia Tech in
`
`1982 as a full-time faculty member and instructor in the thermal and fluid sciences
`
`area. I worked at Virginia Tech for six years before becoming an Assistant Professor
`
`in the Mechanical Engineering Department at the University of Florida, Gainesville.
`
`At the University of Florida, I taught classes in power production systems for
`
`automotive applications, including computational fluid dynamics, fluid dynamics,
`
`combustion, jet and rocket propulsion, gas turbine engines, advanced fan and
`
`compressor design, compressible gas dynamics, turbomachinery, hydraulic systems,
`
`and internal combustion engines.
`
`10.
`
`In 1996, I also joined the mechanical engineering department at the
`
`University of Alabama where I focused my research on power production systems
`
`for automotive applications. I was one of the key collaborating researchers to start
`
`the Center for Advanced Vehicle Technology (CAVT), which is directed to the
`
`research of electric vehicle components, such as electric motors.
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`11.
`
`I joined the Mechanical Engineering and Engineering Science
`
`Department at the University of North Carolina, Charlotte in 2001 as an Associate
`
`Professor. While at the University of North Carolina, I became a licensed
`
`Professional Engineer in the State of North Carolina in 2004. I worked in this
`
`position until 2005, when I joined the Department of Engineering at East Carolina
`
`University as a Professor and Program Director with a Mechanical Engineering
`
`Concentration. During my time at these positions, I taught classes in the design and
`
`evaluation of automotive engineering components, including various components
`
`and aspects of power production systems, such as gas turbine engines, electric
`
`motors, advanced fan and compressor design, combustion, hydraulic systems,
`
`turbomachinery, internal combustion engines, external aerodynamics, dynamics,
`
`mechanics of materials, and non-destructive testing. I also developed numerous
`
`graduate level courses, including one course titled, “Automotive Powertrains,”
`
`which included sections on electric components in hybrid electric vehicles. At the
`
`undergraduate level, I developed a course in Materials and Processes, which
`
`included a significant section on polymers, thermoplastics, and injection molding
`
`manufacturing techniques.
`
`12. My current position is at FIT, which I joined in 2012 as a Professor.
`
`During my tenure at FIT, I have acted as the Head of Automotive Engineering and
`
`the Director of the Florida Center for Automotive Research. At FIT I have taught
`
`
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`classes in automotive engineering, thermodynamics, computational fluid dynamics,
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`fluid dynamics, gas turbine engines, advanced fan and compressor design,
`
`compressible gas dynamics, jet and rocket propulsion, acoustic emissions,
`
`combustion, hydraulic systems, turbomachinery, internal combustion engines,
`
`external aerodynamics, dynamics, mechanics of materials, non-destructive testing,
`
`and alternative fuels.
`
`13.
`
`I have been the Director of several laboratories related to the design of
`
`power production systems while at these universities. For example, I am the Director
`
`of the Florida Center for Automotive Research at FIT through which I supervise the
`
`development and design of power generation systems for automotive applications. I
`
`was also the Director of the Materials and Welding Lab at East Carolina University,
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`the Computational Fluid Dynamics Lab at several universities, and the Internal
`
`Combustion Engine Lab at several universities. Through this work, over the last 40
`
`years, I personally have disassembled, rebuilt, and reassembled hundreds of electric
`
`starter motors, generators, and other electric automotive motor components.
`
`14. Throughout my career, I have served on numerous engineering
`
`committees. For example, at FIT, I was the chair of the Faculty Search Committee
`
`for mechanical engineering. While at East Carolina University, I chaired the
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`Mechanical Engineering Concentration Development Committee and the Promotion
`
`and Tenure Committee for engineering.
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`15. Early in my career, I received several NASA/ASEE Summer Faculty
`
`Fellowships and was inducted into the U.S. Space Foundation Technology Hall of
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`Fame in 2000. I was also listed in the Who’s Who for the International Gas Turbine
`
`Institute, The American Society of Mechanical Engineers from 1993-2006. In
`
`addition to several other awards and recognitions, most recently, I was named the
`
`2015-2016 ASME Outstanding Professor of the Year. I have used my education and
`
`experience working in the mechanical engineering field, and my understanding of
`
`the knowledge, creativity, and experience of a person having ordinary skill in the art
`
`in forming the opinions expressed in this report, as well as any other materials
`
`discussed herein. I am the associate editor for the Society of Automotive Engineers
`
`(SAE) International Journal of Fuels and Lubricants. Further, in the last eight years I
`
`have organized 38 technical sessions for SAE international conferences in the areas
`
`of direct injection SI engine technology, diesel fuel injection and sprays, HCCI
`
`combustion, powertrain development for hybrid electric vehicles, fuel and additive
`
`effects on SI engine performance, Advanced OBD systems, multi-dimensional
`
`engine modeling, high efficiency engines, modeling of diesel and SI engines, fuel
`
`and fuel additive effects on CI performance, colds starts and transient operation,
`
`engine boosting systems, dual fuel combustion and SI fuel injection and sprays.
`
`16. For over 40 years I have been involved in the design, analysis,
`
`fabrication, construction and testing of advanced and complex mechanical
`
`
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`engineering systems associated with both engineering firms and race teams. This has
`
`included work with hundreds of electric starter motors, generators, and other electric
`
`automotive motor components. Over my engineering career, in the assembly of
`
`complex precise engineering systems, from high performance engine building and
`
`drivetrain components to simply engineering systems that have parts that must fit
`
`together precisely over a range of operating temperatures, one of the first parameters
`
`ascertained and taken into account is the coefficient of linear thermal expansion
`
`(CLTE) of the various parts. This engineering parameter is crucial, and I have taken
`
`it into account countless times over my engineering career when selecting materials
`
`to build engineering systems.
`
`B. Compensation
`17.
`I am being compensated for services provided in this matter at my usual
`
`and customary rate of $550.00 per hour plus travel expenses. My compensation is
`
`not conditioned on the conclusions I reach as a result of my analysis or on the
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`outcome of this matter, and in no way affects the substance of my statements in this
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`declaration.
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`18.
`
`I have no financial interest in Petitioner, or any of the real
`
`parties-in-interest to this proceeding. I also have no financial interest in Patent
`
`Owner, Intellectual Ventures II LLC. I do not have any financial interest in the ’200
`
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`patent and have not had any contact with the named inventor of the ’200 patent,
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`Griffith D. Neal.
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`IV. Materials Reviewed
`19.
`In forming my opinions, I read and considered the ’200 patent and its
`
`prosecution history, the exhibits listed in the Exhibit List filed with the petition for
`
`inter partes review of the ’200 patent, as well as any other material referenced
`
`herein.
`
`20.
`
`I have been asked to assume that each of Exhibits identified in the
`
`analysis section of my declaration qualifies as prior art to the Challenged Claims of
`
`the ’200 patent.
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`V. Legal Standards
`21.
`I have been told the following legal principles apply to analysis of
`
`patentability based on 35 U.S.C. §§ 102 and 103. I also have been told that, in an
`
`inter partes review proceeding, a patent claim may be deemed unpatentable if it is
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`shown by a preponderance of the evidence that the claim was anticipated by a prior
`
`art patent or publication under § 102 and/or rendered obvious by one or more prior
`
`art patents or publications under § 103.
`
`A. Anticipation
`22.
`I have been told that for a claim to be anticipated under 35 U.S.C. §
`
`102, every limitation of the claimed invention must be found in a single prior art
`
`reference.
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`23.
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`I have also been told that an anticipatory reference does not have to
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`recite word for word what is in the anticipated claims. Rather, anticipation can occur
`
`when a claimed limitation is “inherent” in the relevant reference. I have been told
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`that if the prior art necessarily functions in accordance with, or includes, the claims
`
`limitations, it can anticipate even though the limitation is not expressly recited.
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`B. Obviousness
`24.
`I have been told that under 35 U.S.C. § 103(a), “[a] patent may not be
`
`obtained through the invention is not identically disclosed or described as set forth in
`
`section 102, if the differences between the subject matter sought to be patented and
`
`the prior art are such that the subject matter as a whole would have been obvious at
`
`the time the invention was made to a person having ordinary skill in the art to which
`
`said subject matter pertains.”
`
`25. When considering the issues of obviousness, I have been told that I am
`
`to do the following:
`
`a.
`
`b.
`
`c.
`
`d.
`
`Determine the scope and content of the prior art;
`
`Ascertain the differences between the prior art and the claims at
`
`issue;
`
`Resolve the level of ordinary skill in the pertinent art; and
`
`Consider evidence of secondary indicia of non-obviousness (if
`
`available).
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`26.
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`I have been told that the relevant time for considering whether a claim
`
`would have been obvious to a person of ordinary skill in the art is the time of alleged
`
`invention. Counsel for Petitioner instructed me to assume that the alleged invention
`
`date for the Challenged Claims is July 29, 1999.
`
`27.
`
`I have been told that a reference may be modified or combined with
`
`other references or with the person of ordinary skill’s own knowledge if the person
`
`would have found the modification or combination obvious. I have also been told
`
`that a person of ordinary skill in the art is presumed to know all the relevant prior art,
`
`and the obviousness analysis may take into account the inferences and creative steps
`
`that a person of ordinary skill in the art would employ.
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`28.
`
`In determining whether a prior-art reference could have been combined
`
`with another prior-art reference or other information known to a person having
`
`ordinary skill in the art, I have been told that the following principles may be
`
`considered:
`
`a.
`
`A combination of familiar elements according to known methods
`
`is likely to be obvious if it yields predictable results;
`
`b.
`
`The substitution of one known element for another is likely to be
`
`obvious if it yields predictable results;
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`c.
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`The use of a known technique to improve similar items or
`
`methods in the same way is likely to be obvious if it yields
`
`predictable results;
`
`d.
`
`The application of a known technique to a prior art reference that
`
`is ready for improvement is likely obvious if it yields predictable
`
`results;
`
`e.
`
`Any need or problem known in the field and addressed by the
`
`reference can provide a reason for combining the elements in the
`
`manner claimed;
`
`f.
`
`A person of ordinary skill often will be able to fit the teachings of
`
`multiple references together like a puzzle; and
`
`g.
`
`The proper analysis of obviousness requires a determination of
`
`whether a person of ordinary skill in the art would have a
`
`“reasonable expectation of success”—not “absolute
`
`predictability” of success—in achieving the claimed invention
`
`by combining prior art references.
`
`29.
`
`I have been told that whether a prior art reference renders a patent claim
`
`unpatentable as obvious is determined from the perspective of a person of ordinary
`
`skill in the art. I have also been told that, while there is no requirement that the prior
`
`art contain an express suggestion to combine known elements to achieve the claimed
`
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`invention, a suggestion to combine known elements to achieve the claimed
`
`invention may come from the prior art as a whole or individually, as filtered through
`
`the knowledge of one skilled in the art. In addition, I have been told that the
`
`inferences and creative steps a person of ordinary skill in the art would employ are
`
`also relevant to the determination of obviousness.
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`30.
`
`I have been told that, when a work is available in one field, design
`
`alternatives and other market forces can prompt variations of it, either in the same
`
`field or in another. I have also been told that if a person of ordinary skill in the art can
`
`implement a predictable variation and would see the benefit of doing so, that
`
`variation is likely to be obvious. I have been told that in many fields, there may be
`
`little discussion of obvious combinations, and in these fields market demand—not
`
`scientific literature—may drive design trends. I have been told that, when there is a
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`design need or market pressure and there are a finite number of predictable
`
`solutions, a person of ordinary skill in the art has good reason to pursue those known
`
`options.
`
`31.
`
`I have been told that there is no rigid rule that a reference or
`
`combination of references must contain a “teaching, suggestion, or motivation” to
`
`combine references. But I also have been told that the “teaching, suggestion, or
`
`motivation” test can be a useful guide in establishing a rationale for combining
`
`elements of the prior art. I have been told that this test poses the question as to
`
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`whether there is an express or implied teaching, suggestion, or motivation to
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`combine prior art elements in a way that realizes the claimed invention, and that it
`
`seeks to counter impermissible hindsight analysis.
`
`VI. Overview of the ’200 Patent
`32. The ’200 patent relates to a thermoplastic encapsulated motor having a
`
`stator substantially encapsulated within a body of thermoplastic material and to one
`
`or more solid parts that are used within the motor or near the body of the motor. (Ex.
`
`1001, Abstract.) The solid parts include components like bearings and inserts, which
`
`are most often made from a metal, such as steel, copper, or aluminum. (Ex. 1001,
`
`16:26-29; 16:49-55.)
`
`33. The ’200 patent explains that the thermoplastic material is chosen
`
`based on its coefficient of linear thermal expansion (CLTE), and is chosen to
`
`contract and expand at approximately the same rate as one or more of the solid parts.
`
`(Ex. 1001, 3:38-41.) In my opinion, the ’200 patent appears to tout as its purported
`
`invention the selection of a phase-change material having a CLTE that is
`
`approximately the same as that of the metal used for the solid parts. (Ex. 1001,
`
`16:52-55.) And, in cases where the motor is designed with multiple different solids,
`
`the ’200 patent explains that the thermoplastic material is chosen based on a CLTE
`
`that is in between the maximum and minimum CLTE’s of the different solids. (Ex.
`
`1001, 17:14-19.)
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`34. Below in annotated Fig. 4, the ’200 patent discloses that a body 14 is
`
`formed of a thermoplastic material (green). An interior portion of the body 14
`
`includes upper and lower support portions 42, 44 that support bearings 18 (yellow)
`
`that surround a shaft 16 (orange). (Ex. 1001, 6:21-9.) Further, the body 14
`
`substantially encapsulates a stator 20 including a core 17 (gray) formed of steel
`
`laminations 11 and wire windings 15 (blue). (Ex. 1001, 5:14-27.)
`
`(Ex. 1001, ’200 patent, Fig. 4 (annotated).)
`
`
`
`A. Claims of ’200 Patent
`35.
`I understand that the ’200 patent contains 16 claims. Of those claims,
`
`claims 1, 9, and 11 are independent. For the purposes of this Declaration, I was
`
`asked to analyze independent claim 1 and its dependent claims 2 and 4-7.
`
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`36. For simplicity, I will refer to elements of the claims using separate
`
`reference numbers for each claim element. For example, I will refer to the elements
`
`of claim 1 as follows:
`
`1. [Preamble] A motor comprising:
`
`[1a] a) a stator substantially encapsulated within a
`
`body of thermoplastic material; and
`
`[1b] b) one or more solid parts used in the motor
`
`either within or near the body;
`
`[1c] c) the thermoplastic material having a
`
`coefficient of linear thermal expansion such that the
`
`thermoplastic material contracts and expands at
`
`approximately the same rate as the one or more solid parts.
`
`Background of the Technology
`
`In my opinion, engineers and designers have known for decades that
`
`B.
`37.
`
`electric motor design and fabrication requires careful consideration of the motor’s
`
`component material properties. One of the most important considerations is the
`
`motor materials’ thermal properties, including its CLTE. A POSITA would
`
`recognize this to be the case because almost all motors generate waste heat, which
`
`causes the components to expand or contract as they heat up or cool down. And, in
`
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`motors, material contraction or expansion during motor operation can lead to poor
`
`motor performance and even failure.
`
`38. Because of this, motor designers were cognizant of the fact that CLTEs
`
`of thermoplastics could be controlled and substantially reduced to suit their design
`
`needs. (Ex. 1012, pp. 8, 10-15; Ex. 1014, pp. 6-14.) For example, it was well-known
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`that by mixing fiberglass, mica, or carbon with molten thermoplastics, one could
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`create thermoplastics with very low CLTE values that approximated those of metals.
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`(Ex. 1012, pp. 8, 10-15; Ex. 1014, pp. 6-14.) And using thermoplastics to
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`encapsulate motors and their components was commonplace by the 1990’s. And by
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`then, in my opinion, a POSITA would recognize and appreciate common-sense
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`engineering as including selecting from a known set of options a thermoplastic that
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`had relatively low or similar CLTE values that approximated those of metals
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`traditionally used in electric motors.
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`VII. Level of Ordinary Skill
`39.
`I understand a person of ordinary skill in the art is determined by
`
`looking at (A) type of problems encountered in the art; (B) prior art solutions to
`
`those problems; (C) rapidity with which innovations are made; (D) sophistication of
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`the technology; and (E) educational level of active workers in the field. Based on my
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`experience in this art in the 1990s and accounting for these factors, I believe a person
`
`of ordinary skill in the art would have had as of July 29, 1999 (what I have been told
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`to assume is the earliest potential effective filing date of the ’200 patent), would
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`have a bachelor’s degree in mechanical or electrical engineering, or an equivalent
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`degree, and at least two years of experience in the design of electric motors. In
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`particular, a POSITA would be familiar with the fundamentals of electric motor
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`design and operation, the concept of encapsulating various components in an electric
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`motor, the types of materials that could be used for encapsulation and their thermal
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`and dimensional properties (e.g., CLTE), and thermofluid concepts. A POSITA
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`would further be aware of various techniques for manufacturing encapsulated
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`motors, including by the use of injection molding.
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`40.
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`I was at least a person of ordinary skill in the art as of July 29, 1999.
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`VIII. Claim Construction
`41.
`I have been told by counsel that the claims in the ’200 patent should be
`
`understood based on their broadest reasonable construction in light of the patent
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`specification for purposes of this inter partes review proceeding. Unless otherwise
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`noted, my opinions in this declaration are consistent with the broadest reasonable
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`construction of the claims to a person of ordinary skill in the art at the effective filing
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`date.
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`42. Claim 4 of the ’200 patent recites the term “insert.” In my opinion, a
`
`person of ordinary skill in the art would understand that, in the context of the ’200
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`patent, this term means “any component other than the elements of the stator that [is]
`
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`substantially encapsulated in the phase-change material with the stator.” (Ex. 1001,
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`10:26-28.)
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`IX. Analysis
`43. Based on my personal experience at the relevant time and my review of
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`the prior art, it is my opinion that claims 1-2 and 4-7 of the ’200 patent would have
`
`been obvious to a person of ordinary skill in the art as of the effective filing date of
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`the ’200 patent based on the teachings of (1) International Publication No.
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`WO97/33359 to Takagi et al. (“Takagi”) and (2) Japanese Application Laid-Open
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`No. H4-105538 to Shigeki Koizumi (“Koizumi”). It is also my opinion that claims
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`6-7 of the ’200 patent would have been obvious to a person of ordinary skill based on
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`the teachings of (4) (3) International Publication No. WO96/31936 to Trago et al.
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`(“Trago”) in view of Koizumi.
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`A. Overview of Koizumi, Takagi, and Trago
`1. Koizumi (Japanese Application Laid-Open No. H4-105538)
`In my opinion, Koizumi discloses the claim limitations of the
`
`44.
`
`Challenged Claims.
`
`45. Koizumi discloses a spindle motor having a “salient pole core coil,” or
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`stator. (Ex. 1005, pp. 2-3.) Koizumi’s stator is “made by winding a coil onto the arm
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`portion of a salient pole core, wherein the coil wound on the salient pole core is
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`flattened,” and then encapsulating the coil and core with “a molding material such as
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`plastic with a thermal expansion coefficient approximately midway between that of
`
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`the core 6 material [] and the coil 10 material copper.” (Ex. 1005, pp. 4, 10.) The
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`core 6 may be formed by laminating a silicon-steel plate, a type of electrical steel
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`which is commonly used as a core material because of its magnetic properties, such
`
`as high permeability. (Ex. 1005, p. 5) Koizumi explains that, by using a molding
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`material having a CLTE between that of the core and the coil the thermal
`
`deformation will be minimal and the motor will have increased durability. (Ex.
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`1005, pp. 6, 10.)
`
`46. Fig. 6 of Koizumi shows one embodiment of Koizumi where the
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`molding material 23 (green) encapsulates the core 6 (gray) and the coil 10 (blue).
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`(Ex. 1005, p. 9.) Additionally, Koizumi includes multiple solid parts, such as
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`bearings 4, 5 (yellow) and screws 12 (purple). (Ex. 1005, p. 5.)
`
`Figure 6
`
`(Ex. 1005, Koizumi, Fig. 6 (annotated).)
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`Takagi (International Publication No. WO97/33359)
`
`2.
`In my opinion, Takagi also discloses the claim limitations of the
`
`61.
`
`Challenged Claims.
`
`62. Takagi discloses a thermoplastic encapsulated motor for use in a
`
`scooter. (Ex. 1002, p. 3.) Takagi’s motor includes a stator core within a cylinder and
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`encapsulated by a thermoplastic resin. (Ex. 1002, p. 16-17.) In my opinion, based on
`
`Takagi’s disclosures and teachings, a POSITA would understand and appreciate that
`
`Takagi was well aware of the issues that can arise from differences in CLTE values
`
`between motor components and the encapsulating thermoplastic and expressly
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`provides preferable relationships between CLTE values of the different solid parts
`
`within the thermoplastic, and the encapsulating thermoplastic resin itself:
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`These resins preferably have a linear coefficient of
`expansion lower than that of the metal configuring the
`cylinder 3, or as close as possible to that of the metal
`constituting a core 11, and should have excellent
`absorption of vibr