DCT

1:17-cv-00295

Intellectual Ventures II LLC v. Aisin Seiki Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-00295, D. Del., 03/20/2017
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendants maintain a regular place of business, have committed alleged acts of infringement, and regularly conduct business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s automotive electric water pumps infringe four patents related to the design, encapsulation, and thermal management of electric motors.
  • Technical Context: The technology concerns methods of constructing electric motors, particularly by encapsulating stator components in thermoplastic materials to improve structural integrity, thermal performance, and manufacturing efficiency.
  • Key Procedural History: The complaint was filed on March 20, 2017. Subsequent Inter Partes Review (IPR) proceedings, concluded between 2019 and 2021, are highly relevant to the case as pled. The IPR certificates provided with the patents indicate that all claims asserted in this complaint have since been cancelled or disclaimed. Specifically, claims 3, 9, and 11 of the '944 patent were disclaimed; claims 1, 2, 4, 6, and 7 of the '200 patent were cancelled; claims 1, 2, and 14 of the '509 patent were cancelled; and all asserted claims of the '348 patent were cancelled.

Case Timeline

Date Event
1999-07-29 U.S. Patent No. 7,154,200 Earliest Priority Date
1999-12-17 U.S. Patent No. 7,067,944 Earliest Priority Date
2006-06-27 U.S. Patent No. 7,067,944 Issued
2006-07-19 U.S. Patents No. 7,683,509 & 7,928,348 Application Date
2006-12-26 U.S. Patent No. 7,154,200 Issued
2010-03-23 U.S. Patent No. 7,683,509 Issued
2011-04-19 U.S. Patent No. 7,928,348 Issued
2017-03-20 Complaint Filed

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

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's background section describes challenges in conventional high-speed motors, including manufacturing costs associated with high-precision components, performance degradation from "stack up tolerances," acoustic noise, and poor heat dissipation (ʼ944 Patent, col. 2:12-44, col. 3:1-4).
  • The Patented Solution: The invention proposes encapsulating the stator windings with an injection-molded thermoplastic material. This material not only protects the windings but can also lock the stator assembly to the motor's baseplate, creating a rigid, unitized structure that improves dimensional stability and provides a direct path for heat to dissipate (ʼ944 Patent, Abstract; col. 4:21-34). Figure 2 illustrates this concept, showing the thermoplastic material (36) encapsulating the wire windings (31) and core (24).
  • Technical Importance: This encapsulation method was intended to simplify motor manufacturing while improving performance and reliability, particularly in applications like computer hard drives where precision, quiet operation, and thermal management are critical (ʼ944 Patent, col. 1:59-65).

Key Claims at a Glance

  • The complaint asserts claims 3, 9, and 11 (Compl. ¶23). Claim 3 is dependent on independent claim 1.
  • Independent Claim 1: A motor comprising:
    • A pole assembly with a core, poles, and windings.
    • A shaft spaced from the pole assembly.
    • A thermoplastic material that both secures the shaft and encapsulates the pole assembly, joining the two parts in the space between them.
  • Independent Claim 9: A motor comprising:
    • A core.
    • At least one magnet spaced from the core.
    • A thermoplastic material that substantially encapsulates the magnet and fills the space between the magnet and the core, rigidly fixing them together.
  • Independent Claim 11: A motor comprising:
    • At least one conductor.
    • At least one magnet forming at least one pole.
    • A thermoplastic material that substantially encapsulates the magnet and positions it with respect to the conductor during motor operation.

U.S. Patent No. 7,154,200 - "Motor," issued December 26, 2006

The Invention Explained

  • Problem Addressed: The patent identifies performance issues in high-speed motors caused by the differing coefficients of linear thermal expansion (CLTE) between various components, such as metal bearings and housings. These differences can cause parts to expand and contract at different rates, leading to dimensional instability, stress, and reduced bearing life (ʼ200 Patent, col. 2:15-21).
  • The Patented Solution: The invention claims a motor where the stator is encapsulated within a body of thermoplastic material that is specifically chosen to have a CLTE that is "approximately the same" as one or more other solid parts of the motor (e.g., the bearings or shaft) (ʼ200 Patent, Abstract). By matching the thermal expansion characteristics, the motor can maintain precise tolerances and alignment across its operating temperature range.
  • Technical Importance: This approach of matching the CLTE of a plastic encapsulant to critical metal components provided a method to enhance the thermal stability and precision of high-speed motors, which is crucial for applications requiring high reliability and performance (ʼ200 Patent, col. 8:30-41).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2, 4, 6, and 7 (Compl. ¶30).
  • Independent Claim 1: A motor comprising:
    • A stator substantially encapsulated within a body of thermoplastic material.
    • One or more solid parts used in the motor either within or near the body.
    • 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.
  • The complaint explicitly asserts dependent claims, which further specify the solid parts as metal, ceramic, a metal insert, or a metal bearing.

U.S. Patent No. 7,683,509 - "Electromagnetic device with open, non-linear heat transfer system," issued March 23, 2010

Technology Synopsis

This patent addresses heat dissipation in electromagnetic devices by encapsulating the electrical conductors in a monolithic thermoplastic body. The invention's key feature is the integration of a "non-linear heat transfer fluid pathway," such as a heat pipe or a sealed coolant channel, directly within the encapsulating body to actively and efficiently remove heat from the device's core components (ʼ509 Patent, Abstract; col. 2:36-44).

Asserted Claims

Claims 1, 2, 14, and 15 are asserted (Compl. ¶37). Independent claim 1 is the lead asserted claim.

Accused Features

The complaint alleges that the Aisin water pumps infringe by using an integrated, non-linear heat transfer system within an encapsulated motor body to manage thermal loads (Compl. ¶¶16, 39).

U.S. Patent No. 7,928,348 - "Electromagnetic device with integrated fluid flow path," issued April 19, 2011

Technology Synopsis

This patent describes an electromagnetic device, such as a pump motor, that is cooled by the same fluid it is designed to move. The invention involves encapsulating the motor's conductors in a monolithic thermoplastic body that includes an "integrated fluid flow path." This path allows the working fluid (e.g., water in a water pump) to flow through the motor body, actively cooling it during operation (ʼ348 Patent, Abstract; col. 2:40-50).

Asserted Claims

Claims 24, 25, 26, and 27 are asserted (Compl. ¶44). Independent claim 24 is the lead asserted claim.

Accused Features

The Aisin water pumps are accused of infringing by allegedly routing the water they pump through an integrated flow path within the encapsulated motor body for cooling purposes (Compl. ¶¶16, 46).

III. The Accused Instrumentality

Product Identification

The accused products are identified as the "Exemplary Aisin Products," which include a range of electric water pumps such as the Aisin WPT-190, WPT-191, and other models supplied for Toyota and Honda vehicles (Compl. ¶16).

Functionality and Market Context

The complaint identifies the accused products as electric motors used in automotive water pumps (Compl. ¶16). It does not provide specific technical details of their internal construction or operation beyond alleging that they practice the patented technologies (Compl. ¶19). The products' association with major automotive brands suggests their use in mass-market vehicle cooling systems.
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement theories in its body, instead incorporating by reference "Exhibits 5-36" which were not attached to the publicly filed complaint (Compl. ¶18). The infringement theories must therefore be inferred from the narrative allegations.

  • '944 Patent Infringement Theory: The complaint alleges that the Aisin water pumps infringe by embodying the patented motor construction (Compl. ¶¶23-25). The implied theory is that the electric motors within the accused pumps contain a stator assembly that is encapsulated and structurally secured by a thermoplastic material, consistent with the limitations of the asserted claims.

  • '200 Patent Infringement Theory: The complaint alleges that the Aisin pumps infringe by using materials with matched thermal properties (Compl. ¶¶30-32). The narrative suggests the pumps' encapsulated motors are constructed with a thermoplastic material whose coefficient of linear thermal expansion (CLTE) is "approximately the same" as other solid components (e.g., metal bearings), thereby meeting the core limitation of asserted claim 1.

V. Key Claim Terms for Construction

'944 Patent

  • The Term: "thermoplastic material" (Claim 9)
  • Context and Importance: The definition and functional requirements of this term are central to the patent's scope. A dispute may arise over whether the term is limited to materials with specific advantageous properties mentioned in the specification or covers a broader class of plastics.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a long, non-limiting list of "suitable thermoplastic resins," including common polymers like polyamides, polyesters, and polyolefins, suggesting the term is not restricted to a particular chemical formulation (ʼ944 Patent, col. 7:3-20).
    • Evidence for a Narrower Interpretation: The preferred embodiments describe the material as being "thermally conductive but non-electrically conductive" and preferably including "ceramic filler particles" ('944 Patent, col. 6:63-66). A party could argue that the term should be construed to require these specific, functionally important properties.

'200 Patent

  • The Term: "contracts and expands at approximately the same rate" (Claim 1)
  • Context and Importance: This term of degree is the central limitation of the patent's main independent claim. The infringement analysis for the '200 patent hinges on the scope of "approximately the same," which will require judicial construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The word "approximately" inherently suggests that a perfect match of the CLTE is not required. The background's focus on solving the general problem of "differing coefficients of thermal expansion" could support a reading that covers any material chosen to meaningfully reduce the thermal mismatch ('200 Patent, col. 2:15-16).
    • Evidence for a Narrower Interpretation: The specification provides a table with specific numerical CLTE values for steel, aluminum, and a preferred "Konduit" thermoplastic ('200 Patent, col. 17:1-12). A party may argue that these examples provide context that limits the scope of "approximately the same" to a specific numerical range or degree of similarity.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims for either induced or contributory infringement, focusing instead on allegations of direct infringement (Compl. ¶¶24, 31, 38, 45).
  • Willful Infringement: The complaint does not allege willful infringement or plead any specific facts related to pre- or post-suit knowledge of the patents by Aisin. The prayer for relief includes a request for a finding of an "exceptional" case for attorneys' fees under 35 U.S.C. § 285 but does not explicitly request enhanced damages for willfulness (Compl. p. 8).

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

The analysis of this complaint reveals several fundamental questions, the most significant of which arises from post-filing procedural events.

  • A dispositive threshold question will be the viability of the lawsuit: Given that post-filing Inter Partes Reviews resulted in the cancellation or disclaimer of every patent claim asserted in the complaint, the case as currently pled appears to lack a legal basis for relief.
  • A central claim construction issue for the '200 patent would have been one of quantitative scope: How much similarity is required for two materials to have CLTEs that are "approximately the same?" Resolution would depend on whether the term is defined by its functional purpose of mitigating thermal stress or by the specific numerical examples provided in the patent.
  • A key technical question for the '348 patent would be one of structural integration: Do the accused water pumps feature a fluid flow path that is monolithically formed as part of the encapsulating motor body itself, or do they utilize a more conventional design where a separate cooling jacket is merely attached or adjacent to the encapsulated motor?