UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________________
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________
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`MOTORTECH GMBH and MOTORTECH AMERICAS, LLC,
`
`Petitioners,
`
`- vs. -
`
`ALTRONIC,
`
`Patent Owner.
`_________________________
`
`Case IPR2025-00398
`
`U.S. Patent No. 7,401,603
`
`_________________________
`
`
`DECLARATION OF MARK EHSANI, Ph.D.
`IN SUPPORT OF PETITION FOR INTER PARTES
`REVIEW OF U.S. PATENT NO. 7,401,603
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`TABLE OF CONTENTS
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`
`INTRODUCTION AND QUALIFICATIONS ............................................... 1
`I.
`II. UNDERSTANDING OF THE GOVERNING LAW ..................................... 4
`A. Interpreting Claims Before the Patent Office ........................................... 4
`B. Invalidity Based on Obviousness .............................................................. 5
`III. MATERIALS RELIED ON IN FORMING MY OPINIONS ........................ 9
`IV. BACKGROUND DISCUSSION OF THE RELEVANT TECHNOLOGY . 10
`V. OVERVIEW OF THE ’603 PATENT .......................................................... 18
`A. Specification of the ’603 Patent .............................................................. 18
`B. The Claims of the ’603 Patent ................................................................. 25
`C. The Prosecution History of the ’603 Patent ............................................ 27
`D. The Priority Date of the ’603 Patent ....................................................... 27
`VI. STATE OF THE ART PRIOR TO THE ’603 PATENT .............................. 27
`A. The Person of Ordinary Skill in the Art .................................................. 27
`B. Capacitor Discharge Ignition System, Research Disclosure, Database
`No. 335026 (Mar. 1992) (“Research Disclosure,” EX1005). ................. 28
`C. U.S. Patent No. 4,181,112 to Grather (“Grather,” EX1006) .................. 31
`D. U.S. Patent No. 6,701,904 to Lepley (“Lepley-I,” EX1007) .................. 34
`VII. CLAIM CONSTRUCTION .......................................................................... 37
`VIII. GROUNDS OF INVALIDITY ..................................................................... 47
`A. Claims 1–7 of the ’603 Patent are obvious over admitted prior art
`including Research Disclosure in view of Grather. ................................ 47
`a. Claim 1 .............................................................................................. 48
`b. Claim 2 .............................................................................................. 64
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`i
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`c. Claim 3 .............................................................................................. 65
`d. Claim 4 .............................................................................................. 65
`e. Claim 5 .............................................................................................. 67
`f. Claim 6 .............................................................................................. 67
`g. Claim 7 .............................................................................................. 68
`B. Claims 8–16 of the ’603 Patent are obvious over Lepley-I in view of
`Research Disclosure. ............................................................................... 69
`a. Claim 8 .............................................................................................. 69
`b. Claim 9 .............................................................................................. 84
`c. Claim 10 ............................................................................................ 84
`d. Claim 11 ............................................................................................ 85
`e. Claim 12 ............................................................................................ 86
`f. Claim 13 ............................................................................................ 86
`g. Claim 14 ............................................................................................ 87
`h. Claim 15 ............................................................................................ 88
`i. Claim 16 ............................................................................................ 89
`IX. OBJECTIVE INDICIA OF NON-OBVIOUSNESS ..................................... 89
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`ii
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`
`I, Mark Ehsani, Ph.D., hereby declare as follows:
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`
`1.
`
`I have been retained on behalf of MOTORTECH GmbH and
`
`MOTORTECH Americas, LLC (collectively, “Petitioners”) to provide my technical
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`review, analysis, insights, and opinions concerning the validity of the claims of U.S.
`
`Patent No. 7,401,603 (EX1001; “the ’603 Patent”) entitled “High Tension
`
`Capacitive Discharge Ignition With Reinforcing Triggering Pulses.” The patent is
`
`assigned to Altronic, Inc. (“Patent Owner”).
`
`2.
`
`I earned a Bachelor of Science degree in electrical engineering from the
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`University of Texas at Austin in 1973. I obtained a Master of Science degree in
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`electrical engineering from the University of Texas at Austin in 1974. I earned a
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`Doctorate in electrical engineering from the University of Wisconsin-Madison in
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`1981. My doctorate work was focused on energy systems and control systems.
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`Between obtaining my undergraduate and doctoral degree, I was a Research
`
`Engineer with the Fusion Research Center and the University of Texas doing
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`research and spark gap power switching equipment development on high power
`
`supplies and power electronic and mechanical circuit breaker technology
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`development. While obtaining my Doctorate, I was with Argonne National
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`Laboratory, Argonne, Illinois, as a Resident Research Associate, developing similar
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`and related power switching equipment and systems.
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`1
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`Since obtaining my Doctorate, I have been at Texas A&M University
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`3.
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`at College Station, where I am now the Robert M. Kennedy endowed Professor of
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`Electrical Engineering and Director of the Power Electronics and Motor Drives
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`Laboratory and the Advanced Vehicle Systems Research Program.
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`4.
`
`I am the author of over 500 publications in the areas of power circuit
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`breakers, power electronics, energy systems, motor drives, and electric and hybrid
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`electric vehicles, and other areas of control, storage, and use of electric power and
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`energy systems. I was the recipient of the Prize Paper Awards in Static Power
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`Converters and motor drives at the IEEE-Industry Applications Society 1985, 1987,
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`and 1992 Annual Meetings, as well as over 140 other honors and recognitions. I am
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`the co-author of twenty-three books on power electronics and motor drives. In
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`addition to the above publications, I have over 30 granted or pending US and EP
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`patents in the general field of power electronics. I have also been a consultant to over
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`60 companies, US government agencies and internationals organizations. My
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`current research work is in power electronics, energy systems, motor drives, hybrid
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`vehicles and their control systems, and sustainable energy engineering. During my
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`over 40 years of employment at Texas A&M, I have originated and taught over eight
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`different undergraduate and graduate electrical engineering courses on a variety of
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`topics including power electronics, motor drives, dc power systems, electric and
`
`2
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`hybrid electric vehicles, sustainable energy and transportation systems, and
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`industrial practice of electrical and computer engineering.
`
`5.
`
`I have been a co-founder and member of IEEE Power Electronics
`
`Society (PELS) AdCom, past Chairman of PELS Educational Affairs Committee,
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`past Chairman of IEEE-IAS Industrial Power Converter Committee and past
`
`chairman of the IEEE Myron Zucker Student-Faculty Grant program. I was the
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`General Chair of IEEE Power Electronics Specialist Conference for 1990. I am the
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`founder of IEEE Power and Propulsion Conference, the founding chairman of the
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`IEEE Vehicular Technology Society (“VTS”) Vehicle Power and Propulsion and
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`chairman of Convergence Fellowship Committees. In 2002, I was elected to the
`
`Board of Governors of VTS. I have also served on the editorial board of several
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`technical journals and was the associate editor of IEEE Transactions on Industrial
`
`Electronics and IEEE Transactions on Vehicular Technology. I am a Life Fellow of
`
`IEEE, a past and present IEEE Industrial Electronics Society and Vehicular
`
`Technology Society Distinguished Speaker, IEEE Industry Applications Society and
`
`Power Engineering Society Distinguished Lecturer. I was also the first IEEE fellow
`
`that was also elected as the Fellow of Society of Automotive Engineers, SAE. I am
`
`also a registered professional engineer in the State of Texas.
`
`6.
`
`I attach my curriculum vitae, which includes a more detailed list of my
`
`qualifications, as Exhibit A. My curriculum vitae also contains a list of all other
`
`3
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`cases in which, during the previous 4 years, I testified as an expert at trial or by
`
`deposition. My work on this case is being billed at a rate of $500 per hour, with
`
`reimbursement for actual expenses. I have no direct financial interest in the dispute
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`between Patent Owner and Petitioners, and my compensation is not contingent upon
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`the outcome of this Inter Partes review.
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`II. UNDERSTANDING OF THE GOVERNING LAW
`I am not an attorney and offer no legal opinions. For the purposes of
`7.
`
`this Declaration, I understand certain aspects of the law that are relevant to my
`
`analysis, as summarized below.
`
`A.
`8.
`
`Interpreting Claims Before the Patent Office
`I understand that the first step in an obviousness analysis involves
`
`construing the claims, as necessary, to determine their scope. Second, the construed
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`claim language is then compared to the disclosures of the prior art. I am informed
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`that claims are generally given their ordinary and customary meaning as understood
`
`by a person of ordinary skill in the art (“POSA”) at the time of the alleged invention,
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`in light of a patent’s “specification.”
`
`9.
`
`I understand that Inter Partes Review is a proceeding before the United
`
`States Patent & Trademark Office (“USPTO”) for evaluating the validity of issued
`
`patent claims. I understand that, in an Inter Partes Review, a claim term is
`
`interpreted in a manner consistent with the standard used in patent litigation, as set
`
`4
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`forth in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). That
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`standard generally construes the claims according to their “ordinary and customary”
`
`meaning in view of the claim language, specification, and file history, and where
`
`applicable, relevant other evidence.
`
`10.
`
`I understand that a patent’s specification includes all the figures,
`
`discussion, and claims within the patent. I understand that the USPTO will look to
`
`the specification and prosecution history to see if there is a definition for a given
`
`claim term, and if not, will apply the ordinary and customary meaning from the
`
`perspective of a POSA at the time in which the alleged invention was made.
`
`11.
`
`I understand that claim construction is a matter of law and that the final
`
`constructions for this proceeding will be determined by the Patent Trial and Appeal
`
`Board.
`
`B.
`12.
`
`Invalidity Based on Obviousness
`I understand that obviousness under 35 U.S.C. § 103 is analyzed from
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`the perspective of a person of ordinary skill in the art (“POSA”) at the time of the
`
`alleged invention. I also understand that a POSA is presumed to have been aware of
`
`all pertinent prior art at the time of the alleged invention.
`
`13.
`
`I understand that an obviousness analysis involves comparing a claim
`
`to the prior art to determine whether the claimed invention as a whole would have
`
`been obvious to a POSA in view of the prior art, and in light of the general
`
`5
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`knowledge in the art at the time the invention was made. I also understand that the
`
`invention may be deemed obvious when a POSA would have reached the claimed
`
`invention through routine experimentation.
`
`14.
`
`I understand that obviousness can be established by combining or
`
`modifying the disclosures of the prior art to achieve the claimed invention. It is also
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`my understanding that where there is a reason to modify or combine the prior art to
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`achieve the claimed invention, there must also be a reasonable expectation of success
`
`in so doing to render the claimed invention obvious. I understand that the reason to
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`combine prior art references can come from a variety of sources, not just the prior
`
`art itself and need not be tied to the specific problem the patentee was trying to solve.
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`I also understand that the references themselves need not provide a specific hint or
`
`suggestion of the alteration needed to arrive at the claimed invention; the analysis
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`may include recourse to logic, judgment, and common sense available to a POSA.
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`15.
`
`I understand that when there is some recognized reason to solve a
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`problem, and there are a finite number of identified, predictable solutions, a POSA
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`has good reason to pursue the known options within his or her technical grasp. If
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`such an approach leads to the anticipated success, it is likely the product not of
`
`innovation but of ordinary skill and common sense. In such a circumstance, when a
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`patent simply arranges old elements with each performing the same function it had
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`6
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`been known to perform and yields no more than one would expect from such an
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`arrangement, the combination is obvious.
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`16.
`
`I understand that when considering the obviousness of an invention,
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`one should also consider whether there are any objective indicia that support the
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`non-obviousness of the invention. I further understand that objective indicia of non-
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`obviousness include failure of others, copying, unexpected results, information that
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`“teaches away” from the claimed subject matter, perception in the industry,
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`commercial success, and long-felt but unmet need. I also understand that in order for
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`objective indicia of non-obviousness to be applicable, the indicia must have some
`
`sort of nexus to the subject matter in the claim that was not known in the art. I
`
`understand that this nexus includes a factual connection between the patentable
`
`subject matter of the claim and the objective indicia alleged. I also understand that
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`an independently made invention that is made within a comparatively short period
`
`of time is evidence that the claimed invention was the product of ordinary skill.
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`17. Finally, I understand that patent examiners at the U.S. Patent and
`
`Trademark Office (“USPTO”) rely upon certain exemplary rationales in reviewing
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`patent applications to understand whether the subject matter of the claims is obvious.
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`I understand that the following is the list of exemplary rationales relied upon by
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`patent examiners at the USPTO:
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`7
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`(A) Combining prior art elements according to known methods to
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`yield predictable results;
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`(B) Simple substitution of one known element for another to obtain
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`predictable results;
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`(C) Use of a known technique to improve similar devices (methods,
`
`or products) in the same way;
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`(D) Applying a known technique to a known device (method, or
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`product) ready for improvement to yield predictable results;
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`(E) “Obvious to try” – Choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success;
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`(F) Known work in one field of endeavor may prompt variations of
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`it for use in either the same field or a different one based on
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`design incentives or other market forces if the variations are
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`predictable to one of ordinary skill in the art; and
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`(G) Some teaching, suggestion, or motivation in the prior art that
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`would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at
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`the claimed invention.
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`8
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`III. MATERIALS RELIED ON IN FORMING MY OPINIONS
`In forming the opinions expressed in this report, I have relied on my
`18.
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`own knowledge, experience, and expertise, as well as the knowledge of a POSA in
`
`the relevant timeframe. In addition, I have reviewed and relied upon all documents
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`referenced in this report and the following list of materials:
`
`• The ’603 Patent (EX1001);
`
`• The prosecution history for the ’603 Patent (EX1002);
`
`• Capacitor Discharge Ignition System, Research Disclosure, database number
`
`335026 (Mar. 1992) (“Research Disclosure”) (EX1005).
`
`• U.S. Patent No. 4,181,112 (“Grather”) (EX1006);
`
`• U.S. Patent No. 6,701,904 (“Lepley-I”) (EX1007);
`
`• U.S. Patent No. 9,429,132 (“’132 Patent”) (EX1008);
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`• Claim Construction Order from Inv. No. 337-TA-1390 (EX1010); and
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`• Testimony from Investigation No. 337-TA-1390 (EX1011–EX1016).
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`19.
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`I understand that on February 9, 2024, Petitioners received from the
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`U.S. International Trade Commission (“ITC”), a Notice of Institution of
`
`Investigation based on a complaint served by Patent Owner alleging violations of
`
`section 337 based upon the importation into the United States, the sale for
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`importation, and the sale within the United States after importation of certain
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`capacitive discharge ignition systems, components thereof, and products containing
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`9
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`the same of alleged infringement of certain claims of the ’603 Patent (the “ITC
`
`Proceeding”). EX1009, p. 1. I was present during the ITC Proceeding, including
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`testimony from Patent Owner’s technical witnesses, and I rely on portions of that
`
`testimony in support of my opinions set forth herein.
`
`IV. BACKGROUND DISCUSSION OF THE RELEVANT TECHNOLOGY
`20. To better understand my opinions on the invalidity of the claims of the
`
`’603 Patent, I provide below some background on combustion engines with a
`
`particular focus on capacitive discharge ignition systems for internal combustion
`
`engines. All of the concepts discussed in this section were well known and used prior
`
`to the February 2, 2007 priority date for the ’603 Patent.
`
`A. Capacitive Discharge Ignition Systems for Internal Combustion
`Engines Were Ubiquitous
`
`In this subsection I provide an introduction to conventional ignition
`
`21.
`
`systems for internal combustion engines, including an explanation of what
`
`capacitive discharge ignition systems are and how they work.
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`22.
`
`In general, ignition systems used in internal combustion engines
`
`provide a high-voltage spark into an engine’s cylinder (shown below), which causes
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`a fuel/air mixture within the cylinder to explode. The process begins by pumping a
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`fuel/air mixture into a cylinder. The cylinder contains a piston, which is forced
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`upward. The upward movement of the piston in the cylinder compresses the fuel/air
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`mixture. The ignition system next generates a spark across the spark plug. Ideally,
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`the spark is maintained by the ignition system for a period of time known as the
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`“spark duration.” The spark duration is long enough to ignite the fuel/air mixture.
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`Igniting the fuel/air mixture releases energy that forces the piston back down. The
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`downward movement of the piston, in turn, causes rotation of the crankshaft to
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`operate the engine. It is important to time the ignition and corresponding movement
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`of the piston to occur when the crankshaft is at a certain angle of its rotation in order
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`to make the most efficient use of the energy in the system, with the goal of igniting
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`all of the fuel/air mixture. This is sometimes referred to as operating “in
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`synchronism” with the engine.
`
`Operation of a Spark in an Engine
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`Ignition systems involve several basic electrical concepts. First, a spark
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`23.
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`plug includes a pair of electrodes that are spaced a certain distance apart. This space
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`between the electrodes is sometimes referred to as an “air gap.” If only a small
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`voltage were to be applied across the electrodes of the spark plug, the air gap
`
`between the electrodes would prevent any current from flowing. This state is
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`sometimes referred to as an “open circuit” state because the electrodes are spaced
`
`apart from each other, resulting in the electrodes being disconnected from one
`
`another. This is the same concept as a switch having an open position (e.g., off / non-
`
`conducting) and a closed position (e.g. on / conducting). As a result, current cannot
`
`flow between the electrodes unless a spark is generated.
`
`24. When the voltage across the spark plug electrodes reaches a sufficiently
`
`high level, a spark forms. The spark provides a conductive path that bridges the gap
`
`between the electrodes and allows current to flow. The minimum voltage required
`
`to generate the spark across the electrodes is called the “breakdown voltage.” When
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`the voltage generated by the ignition system exceeds the breakdown voltage, then
`
`the spark (or electric arc) forms across the electrodes. Current continues to flow
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`across the air gap and between the electrodes as long as the spark is present. When
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`the spark goes out or is “quenched,” the current abruptly stops flowing and the spark
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`plug returns to the open circuit state.
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`25. Capacitive discharge ignition (CDI) systems are a type of ignition
`
`system that were well known at the time of the ’603 Patent. A CDI system uses a
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`storage capacitor to temporarily store energy, and then quickly discharges that
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`energy to feed the spark (the arc). More particularly, a CDI system includes a power
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`source, a capacitor, a switch, and a transformer (also called an “ignition coil”). The
`
`transformer includes a primary winding and a secondary winding. The purpose of
`
`the transformer in the CDI system is to increase the voltage to the level needed to
`
`initiate the arc. As such, the transformer can be referred to as a step-up transformer,
`
`which converts a low voltage to a much higher voltage (greater than the breakdown
`
`voltage). The transformer is designed to do this by having a certain number of turns
`
`in the primary winding of the transformer, and many more turns in the secondary
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`winding of the transformer. The voltage increase is proportional to the ratio of the
`
`number of turns in the secondary winding to the number of turns in the primary
`
`winding.
`
`26. A basic CDI system is illustrated in FIG. 1 of the ’603 Patent (EX1001)
`
`and also in the Figure of Research Disclosure (EX1005), reproduced below.
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`
`EX1001, Figure 1 (Annotated)
`
`
`
`
`
`
`EX1005, Figure (Annotated)
`
`27. Briefly, a power supply (blue) supplies power to charge the capacitor
`
`(red). A switch (yellow) is initially opened to prevent current from flowing to the
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`transformer while the capacitor is being charged. At the appropriate time, a
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`controller (purple) closes the switch. Once closed, energy in the capacitor is then
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`discharged through the switch to the ignition coil’s primary winding (green). This
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`creates a high voltage in the secondary winding (pink), and if the voltage exceeds
`
`the breakdown voltage, it generates the spark at the spark plug (brown). Once the
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`spark is generated, the voltage drives a current to the spark plug, and the current
`
`maintains the spark for the desired duration of time.
`
`B. Circuit Synchronization and Pulse Arrangement Techniques
`Were Well-Known for Generating and Maintaining a Spark in
`Ignition Systems
`In a capacitive discharge ignition system, a controller commonly is used
`
`28.
`
`to synchronize the timing of the spark with the engine’s crankshaft rotation. It is
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`important that the spark be timed so that the piston has moved upward in the cylinder
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`14
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`and has compressed the fuel/air mixture, and also so that the crankshaft is at the
`
`proper angle of rotation to receive the air/fuel ignition energy applied to the piston.
`
`29.
`
`It was well-known
`
`that capacitive discharge
`
`ignition systems
`
`commonly use a controller as a pulse control. See e.g., EX1005, Figure at 3. Such
`
`pulse control mechanisms can control the switch to generate multiple sequentially
`
`generated pulse signals or “pulse trains.” See e.g., EX1005, 2:12–18; EX1006, 1:60–
`
`65.
`
`30.
`
`In a capacitive discharge ignition system, after the spark event,
`
`sequentially generated pulses can be applied to the spark gap to cause a build-up of
`
`charge accumulation that feeds energy to the spark (arc) to sustain it for the required
`
`duration. For example, a patent issued to Günter Gräther et al. (“Grather,” EX1006)
`
`in 1980 disclosed a “high-voltage ignition system” that “generate[s] a spark for an
`
`internal combustion engine, and method to generate the spark energy.” EX1006,
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`Title. In this prior art system, “[a]n electronic system so adjusts the length of the
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`signals [signal length, “l”] and the gaps between signals [signal pause, “p”] that a
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`charge accumulation will occur at the spark gap of the spark plug until breakdown
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`occurs.” EX1006, 1:62–65. The electronic system can generate “[c]harge
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`accumulation” by “adjusting the signals of graph E” [illustrated in FIG. 4 below]
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`“which control the opening and closing of the switch 18.” EX1006, 5:19–25, FIG.
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`15
`
`Exhibit 1004
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`4. This results in a rise in voltage at the spark gap, which is depicted as trace “U2”
`
`in FIG. 4 below. EX1006, 5:33–37.
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`EX1006, Figure 4 (Annotated)
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`
`
`31.
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`In a capacitive discharge ignition system, after the spark is established
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`(or struck), sequentially generated current pulses can be applied to the spark gap to
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`extend the magnitude or duration of the spark. For example, Lepley-I, a patent
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`published in 2002 and naming the same inventor as the ’603 Patent (“Lepley-I,”
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`EX1007), disclosed a “capacitive discharge ignition system with extended duration
`
`spark.” EX1007, Title. A stated purpose of the invention was to generate a spark
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`duration “three to six times longer than typical for the type of ignition coil in use.”
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`16
`
`Exhibit 1004
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`EX1007 at 1:12-16. This prior art system demonstrated that the spark duration can
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`be increased by controlling either the number or width of sequentially generated
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`pulses sent to the ignition transformer. EX1007, 1:53–56, 3:54–4:33. For example,
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`Figure 9 below shows “twelve equally spaced reenergizing pulses” (highlighted in
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`blue) that are “used to extend the spark duration” (highlighted in orange). EX1007,
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`4:25–26, FIG. 9.
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`EX1007, Figure 9 (Annotated)
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`
`
`
`
`32. When evaluating the performance of an ignition system, it is (and was
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`at the time of the invention) common to measure various signals using an
`
`17
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`Exhibit 1004
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`oscilloscope, as evidenced in the above figure from Lepley-I. An oscilloscope is an
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`electronic instrument that graphically displays electrical signals. An oscilloscope can
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`detect the voltage and current signals going into and resulting from the system, and
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`then display graphical representations of the waveforms (sometimes referred to as
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`“traces”) on the oscilloscope display. Patents and publications often include
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`graphical representations of oscilloscope displays, which are sometimes referred to
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`as “oscillograms.” Oscillograms can display various signals such as a control signal
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`delivered to a switch; a voltage waveform at the primary or secondary winding; and
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`current waveforms at the primary or secondary winding. For example, Figure 9 of
`
`Lepley-I, reproduced above, is an oscillogram that “shows extended capacitive
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`discharge circuit waveforms . . . with long duration extension pulses and with higher
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`arc current.” EX1007, 2:20–22.
`
`
`
`V. OVERVIEW OF THE ’603 PATENT
`Specification of the ’603 Patent
`A.
`33. The ’603 Patent relates to “capacitive discharge ignition systems” used
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`to “deliver energy to the primary of an ignition coil (transformer) in synchronism
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`with the rotation of the engine crank shaft” of an internal combustion engine.
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`EX1001, 1:8–11.
`
`18
`
`Exhibit 1004
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`34. The ’603 Patent discloses the same “basic capacitive discharge circuit”
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`as the prior art. EX1001, 3:32–33. Figure 1, reproduced below, shows a power
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`supply (shown in blue) connected in series with a storage capacitor C1 (shown in
`
`red). EX1001, 3:32–35, FIG. 1. A controllable switch S1 (shown in yellow) is
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`controlled by an electronic control circuit (EC1) (shown in purple). EX1001, 3:39–
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`40, FIG. 1. As shown in FIG. 1, the primary winding (shown in green) is in series
`
`with the capacitor C1 and the switch S1, such that the capacitor is charged when the
`
`switch S1 is open. EX1001, 3:36–38, FIG. 1. When the switch S1 is closed, the
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`capacitor C1 discharges to transfer energy (i.e., a voltage) across the primary
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`winding of the ignition transformer TR1. EX1001, 3:41–46, FIG. 1. A spark plug
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`(shown in brown) is connected in series with the secondary winding (shown in pink)
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`of the ignition transformer TR1. EX1001, 3:38–39. The secondary winding of the
`
`ignition transformer TR1 subsequently creates a secondary voltage that is applied
`
`across the spark plug 22. EX1001, 3:67–4:2, FIG. 1. Provided that the secondary
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`voltage exceeds the spark plug gap breakdown voltage threshold, a spark is then
`
`formed at the spark plug 22, at which time a secondary current flows through the
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`spark plug. EX1001, 2:59:63, FIG. 1.
`
`19
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`Exhibit 1004
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`Declaration of Mark Ehsani, Ph.D.
`U.S. Patent No. 7,401,603
`
`
`EX1001, Figure 1 (Annotated)
`
`
`
`35. The ’603 Patent explains that its “switch is controlled to create a train
`
`of pulses to the primary winding [of the ignition transformer that is] timed to
`
`reinforce the ringing action of the ignition transformer.” EX1001, Abstract.
`
`According to the ’603 Patent, “it is an object . . . to provide a capacitive discharge
`
`ignition system capable of generating a spark discharge between the spark plug
`
`electrodes with a higher breakdown voltage capability, greater secondary current,
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`and spark duration much longer than typical for the type of ignition [transformer] in
`
`use.” EX1001, 1:31–36.
`
`36. The timing of the control pulses is shown, for ex