DCT

2:17-cv-07680

Intellectual Ventures II LLC v. Honda Motor Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:17-cv-07680, C.D. Cal., 10/20/2017
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain a regular and established place of business and have committed infringing acts within the Central District of California.
  • Core Dispute: Plaintiff alleges that certain of Defendant’s automotive power steering motors and pumps infringe five patents related to the design, manufacturing, and thermal management of electric motors.
  • Technical Context: The technology concerns methods for improving the performance, reliability, and manufacturing efficiency of compact electric motors by using molded thermoplastic materials to encapsulate components, which enhances structural integrity and heat dissipation.
  • Key Procedural History: Subsequent to the filing of the complaint, Inter Partes Review (IPR) proceedings were initiated against the patents-in-suit. The provided IPR certificates indicate that all claims asserted in the complaint have since been disclaimed or cancelled. For example, the complaint asserts claims 3, 9, and 11 of the '944 patent, all of which were disclaimed per the IPR certificate issued September 26, 2019. This procedural development raises a significant question regarding the continued viability of the infringement claims as originally pleaded.

Case Timeline

Date Event
1999-07-29 ’200 Patent Priority Date
1999-12-17 ’944 Patent Priority Date
2001-03-02 ’952 Patent Priority Date
2006-06-27 ’944 and ’952 Patents Issued
2006-07-19 ’509 and ’348 Patents Application Date
2006-12-26 ’200 Patent Issued
2010-03-23 ’509 Patent Issued
2011-04-19 ’348 Patent Issued
2017-10-20 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,067,944 - "Motor with encapsulated stator and method of making same"

  • Patent Identification: U.S. Patent No. 7,067,944, "Motor with encapsulated stator and method of making same," issued June 27, 2006.

The Invention Explained

  • Problem Addressed: The patent describes conventional high-speed spindle motors, such as those used in computer hard drives, as suffering from performance limitations due to dimensional inconsistencies, heat dissipation challenges, vibration, and particulate contamination from components like varnish and glue (’944 Patent, col. 1:49-2:44).
  • The Patented Solution: The invention proposes encapsulating the stator windings with an injection-molded thermoplastic material. This process creates a single, monolithic structure that can lock the stator to the motor's baseplate, provide improved thermal conductivity, and dampen vibrations, thereby overcoming the drawbacks of multi-part assemblies (’944 Patent, Abstract; col. 4:7-11).
  • Technical Importance: This manufacturing approach sought to create more precise, reliable, and thermally efficient compact electric motors by integrating multiple structural and thermal functions into a single molded component (’944 Patent, col. 4:1-4).

Key Claims at a Glance

  • The complaint asserts independent claims 3, 9, and 11 (Compl. ¶26).
  • Claim 3, as an example, recites the following essential elements:
    • A core having poles and windings forming a pole assembly.
    • A shaft spaced from the pole assembly without direct contact.
    • A thermoplastic material that is secured to the shaft and encapsulates the pole assembly, joining the two components in the space between them to form a rigidly fixed unit.

U.S. Patent No. 7,067,952 - "Stator assembly made from a molded web of core segments and motor using same"

  • Patent Identification: U.S. Patent No. 7,067,952, "Stator assembly made from a molded web of core segments and motor using same," issued June 27, 2006.

The Invention Explained

  • Problem Addressed: The patent identifies drawbacks in manufacturing stators from single, circular stamped steel pieces, including non-uniform magnetic grain orientation, inefficient wire winding in cramped spaces, and significant material waste (’952 Patent, col. 1:56-2:45).
  • The Patented Solution: The invention discloses a method where individual stator arc segments are first linked by a flexible webbing of molded material into a continuous strip. The wire windings are applied to the segments while in this flat, linear arrangement, which allows for higher packing density. The wound strip is then formed into a final toroidal (circular) stator core (’952 Patent, Abstract; col. 5:46-6:5).
  • Technical Importance: This method was designed to produce smaller, more powerful, and more cost-effective electric motors by improving the uniformity of magnetic properties and the efficiency of the wire winding process (’952 Patent, col. 11:1-8).

Key Claims at a Glance

  • The complaint asserts independent claims 10 and 12 (Compl. ¶33).
  • Claim 10, as an example, recites the following essential elements:
    • A plurality of discrete stator segments, each at least partially encased with a phase change material.
    • The phase change material also comprises a bridge between adjacent segments to link them into a continuous strip, where the bridge is formed by interconnecting two mating sections.
    • The linked stator segments are arranged and secured together to form the stator assembly.

U.S. Patent No. 7,154,200 - "Motor"

  • Patent Identification: U.S. Patent No. 7,154,200, "Motor," issued December 26, 2006.
  • Technology Synopsis: This patent addresses the problem of mismatched thermal expansion rates between different motor components. The invention discloses a motor where the stator is encapsulated in a thermoplastic material having a coefficient of linear thermal expansion (CLTE) specifically chosen to approximate that of adjacent metal parts, thereby maintaining dimensional stability and integrity across operating temperatures (’200 Patent, Abstract).
  • Asserted Claims: Claims 1, 2, 4, 6, and 7 are asserted (Compl. ¶40).
  • Accused Features: The complaint alleges that various Honda power steering motors and pumps infringe this patent (Compl. ¶19).

U.S. Patent No. 7,683,509 - "Electromagnetic device with open, non-linear heat transfer system"

  • Patent Identification: U.S. Patent No. 7,683,509, "Electromagnetic device with open, non-linear heat transfer system," issued March 23, 2010.
  • Technology Synopsis: The patent describes an electromagnetic device with an integrated heat exchange system. The invention involves encapsulating a heat transfer mechanism, such as a heat pipe or a coolant channel, within the same monolithic body that encapsulates the device's electrical conductors, creating a direct and efficient path for thermal management (’509 Patent, Abstract).
  • Asserted Claims: Claims 1, 2, 14, and 15 are asserted (Compl. ¶47).
  • Accused Features: The complaint alleges that various Honda power steering motors and pumps infringe this patent (Compl. ¶19).

U.S. Patent No. 7,928,348 - "Electromagnetic device with integrated fluid flow path"

  • Patent Identification: U.S. Patent No. 7,928,348, "Electromagnetic device with integrated fluid flow path," issued April 19, 2011.
  • Technology Synopsis: This patent discloses an electromagnetic device wherein a fluid flow path is integrated directly into the molded body that encapsulates the electrical conductors. This design allows a fluid, such as a coolant or the fluid being pumped by the device itself, to flow through the body to actively remove heat from the operational components (’348 Patent, Abstract).
  • Asserted Claims: Claims 24, 25, 26, and 27 are asserted (Compl. ¶54).
  • Accused Features: The complaint alleges that various Honda power steering motors and pumps infringe this patent (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as the "Exemplary Honda Products," which include the Honda 53602-TV0-E01 Power Steering Motor, the Honda 53281-TG7-A20 Power Steering Motor, the Honda 53602-SZT-G01 Power Steering Motor, the Honda 53600-TY2-A61 Power Steering Gear, a coolant pump (part number 19200-5K0-A01), and a water pump (part number 061JO-5K1-A00) (Compl. ¶19).

Functionality and Market Context

  • The accused products are electric motors and pumps designed for automotive applications such as power steering and engine cooling (Compl. ¶19). The complaint does not provide specific technical details regarding the internal construction, materials, or manufacturing processes of these products. Instead, it alleges that they "practice, in whole or in material part, the technology claimed" and incorporates by reference a series of non-provided claim chart exhibits as evidence of this functionality (Compl. ¶21-22). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts (Exhibits 6-17) that allegedly compare the asserted claims to the accused products, but these exhibits were not publicly filed with the complaint (Compl. ¶21). The infringement theory must therefore be summarized from the complaint's narrative allegations.

For the ’944 Patent, the complaint alleges that Honda directly infringes claims 3, 9, and 11 by "designing, manufacturing, and selling the Exemplary Honda Products" (Compl. ¶27). The core of this allegation appears to be that the accused motors utilize a thermoplastic material to encapsulate and structurally unify components such as the stator core, windings, and shaft, consistent with the patent's teachings.

For the ’952 Patent, the complaint alleges that Honda directly infringes claims 10 and 12 by using a manufacturing method that falls within the scope of the claims (Compl. ¶34). This suggests an allegation that the stators in the accused products are made from a "continuous strip" of linked arc segments that are wound and then formed into a toroidal core, as described in the ’952 Patent.

  • Identified Points of Contention:
    • Factual Questions: The primary point of contention will be factual: do the accused Honda products actually embody the specific structures and are they made by the specific methods recited in the asserted claims? For instance, with respect to the ’944 patent, a key question is whether the accused motors use a thermoplastic material to rigidly join a spaced-apart shaft and pole assembly.
    • Methodology Questions: For the ’952 patent, the dispute would likely focus on Honda's actual manufacturing process. A central question would be whether Honda's process involves winding discrete stator segments while they are linked in a linear "web" before forming the final circular stator, as the claims require.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as it does not specify which claim limitations may be in dispute or offer a proposed construction for any terms.

VI. Other Allegations

  • Indirect Infringement: The complaint makes allegations of direct infringement only (e.g., Compl. ¶27, 34). It does not contain separate counts or factual allegations to support claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or a request for enhanced damages under 35 U.S.C. § 284. The prayer for relief includes a request that the case be declared "exceptional" for the purpose of awarding attorneys' fees under 35 U.S.C. § 285 (Compl., p. 9).

VII. Analyst’s Conclusion: Key Questions for the Case

This case, as framed by the provided documents, presents two fundamental questions for resolution.

  • A threshold issue will be one of procedural viability: can this action proceed as pleaded, given that Inter Partes Review proceedings initiated subsequent to the complaint's filing have resulted in the cancellation or disclaimer of every patent claim asserted by the Plaintiff?
  • Should the case proceed, a core evidentiary question will be one of factual correspondence: does the internal construction of Honda's accused motors and pumps, and the methods by which they are manufactured, actually align with the specific technical requirements of the patent claims, an issue for which the public complaint provides no direct evidence?