DCT

1:17-cv-00297

Intellectual Ventures II LLC v. Denso Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-00297, 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 in the district, have committed acts of infringement in the district, and derive substantial revenue from goods or services provided in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s power steering motors infringe a patent related to the manufacturing of electric motor stator assemblies.
  • Technical Context: The technology concerns methods for manufacturing stators—a core component of electric motors—by linking discrete magnetic segments to improve winding efficiency and motor performance, particularly for high-speed applications like computer hard drives.
  • Key Procedural History: The complaint asserts claims that were subsequently disclaimed. Post-filing, the patent-in-suit was the subject of multiple Inter Partes Review (IPR) proceedings. On June 11, 2018, the inventor filed a disclaimer for claims 1-6 and 8-14 of the patent, which includes all claims asserted in this complaint. An IPR Certificate issued on September 27, 2019, confirms that these claims are disclaimed. This post-filing disclaimer renders the infringement claims asserted in the original complaint untenable.

Case Timeline

Date Event
2001-03-02 ’952 Patent Priority Date
2006-06-27 ’952 Patent Issue Date
2017-03-20 Complaint Filing Date
2017-06-09 IPR2017-01497 Filed
2018-06-11 Inventor files disclaimer for claims 1-6 and 8-14 of the '952 Patent
2019-09-27 IPR Certificate issued, confirming claims 1-6 and 8-14 disclaimed

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

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’s background section identifies several problems with conventional methods of manufacturing electric motor stators from single, circular stamped steel pieces. These include difficulties in tightly winding wires in cramped spaces, inconsistent magnetic properties due to steel grain orientation, accumulation of manufacturing tolerances ("stack up"), and inefficient heat dissipation. (’952 Patent, col. 1:56-2:65).
  • The Patented Solution: The invention proposes constructing a stator from a plurality of individual arc segments (20) that are first linked together into a flexible, continuous strip by a "phase change material" (22), such as a thermoplastic webbing (23). (’952 Patent, Abstract; col. 5:46-54). This linear arrangement allows for easier and denser winding of wires (15) onto the segments. After winding, the strip is rolled into its final toroidal (donut-like) shape to form the stator core (17). (’952 Patent, col. 7:6-14).
  • Technical Importance: This method purports to enable the creation of smaller, more powerful, and more efficient motors by achieving a higher packing density of wire than was possible with traditional manufacturing techniques. (’952 Patent, col. 11:15-19, 11:34-39).

Key Claims at a Glance

  • The complaint asserts independent claim 10 and dependent claim 12. (’952 Patent, col. 14:10-20; Compl. ¶18).
  • Independent Claim 10:
    • a) a plurality of discrete stator segments each at least partially encased with a phase change material,
    • wherein the phase change material also comprises a bridge between adjacent segments to link adjacent segments into a continuous strip,
    • wherein the bridge is formed by interconnecting two mating sections formed from the phase change material; and
    • b) the linked stator segments being arranged and secured together to form the stator assembly.
  • The complaint does not explicitly reserve the right to assert other claims, focusing only on claims 10 and 12. (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Denso Power Steering Motor with Toyota part number 89650-33680" as the "Exemplary Denso Product." (Compl. ¶11).

Functionality and Market Context

  • The complaint does not provide specific details about the structure, manufacturing process, or operation of the accused motor. All technical allegations of infringement are incorporated by reference to an external "Exhibit 2," which is a claim chart that was not included with the complaint. (Compl. ¶12-14, ¶20). Therefore, the complaint itself does not contain sufficient information to describe the relevant functionality of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are presented in a claim chart exhibit that is not provided with the filed document. (Compl. ¶13, ¶20). The complaint’s narrative theory is limited to the conclusory statement that "the Exemplary Denso Product practices, in whole or in material part, the technology claimed by the Patent-in-Suit." (Compl. ¶14). No probative visual evidence provided in complaint. Due to the absence of the claim chart, a detailed tabular analysis is not possible.

  • Identified Points of Contention:
    • Evidentiary Question: The central issue at the pleading stage is whether the facts contained in the un-provided Exhibit 2 would be sufficient to plausibly allege that the accused motor meets every limitation of the asserted claims.
    • Technical Question: A key technical question would be whether the accused Denso motor is constructed from discrete segments linked by a "bridge... formed by interconnecting two mating sections" as required by claim 10. The specification links this element to a specific "successive molding operation," raising the question of whether the accused product is made using a comparable process. (’952 Patent, col. 6:38-44).
    • Scope Questions: The dispute would likely involve the proper construction of "phase change material" and whether the material used in the accused motor falls within the patent’s definition, which includes specific thermoplastics and thermal properties. (’952 Patent, col. 8:26-30, 8:51-57).

V. Key Claim Terms for Construction

  • The Term: "a bridge ... formed by interconnecting two mating sections formed from the phase change material"

  • Context and Importance: This limitation in independent claim 10 describes the specific method of linking the discrete stator segments. The infringement analysis hinges on whether the accused product's linking structure can be characterized as being formed by "interconnecting two mating sections." Practitioners may focus on this term because it appears to recite a very specific manufacturing step, potentially narrowing the claim's scope.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The plain language of the claim itself could be argued as the primary definition, covering any bridge formed by joining two sections of the phase change material.
    • Evidence for a Narrower Interpretation: The specification describes a specific method for creating this continuous strip: "by linking the webbing from successive molding operation. This is done by designing the tool to insert a section of the plastic webbing of the outermost segment molded in the prior cycle with the new laminations to be molded." (’952 Patent, col. 6:38-42). A defendant may argue this detailed description limits the claim to this specific overmolding process.

  • The Term: "phase change material"

  • Context and Importance: This term defines the encapsulating and linking substance. Its scope is critical, as it must read on the material used to encase and link the segments in the accused motor.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification provides a general definition as "a material that can be used in a liquid phase to envelope the stator, but which later changes to a solid phase," and notes it can be "temperature activated" or "chemically activated," giving epoxy as an example of the latter. (’952 Patent, col. 6:6-11, 6:24-28).
    • Evidence for a Narrower Interpretation: The specification heavily emphasizes preferred embodiments, such as thermoplastics like polyphenylene sulfide (PPS), and specifies preferred thermal conductivity (at least 0.4 watts/meter° K) and coefficient of linear thermal expansion (CLTE) values (less than 2x10⁻⁵ in/in/° F.). (’952 Patent, col. 8:51-57; col. 12:60-66). A defendant could argue these properties are defining characteristics of the claimed material.

VI. Other Allegations

  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. However, the prayer for relief requests a declaration that the case is "exceptional" under 35 U.S.C. § 285, which would permit an award of attorneys' fees. (Compl. p. 4, g(i)). The complaint alleges no specific facts to support a finding of willfulness or exceptionality, such as pre-suit knowledge of the patent.

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

  1. Viability of Asserted Claims: The foremost issue is the legal status of the asserted claims themselves. The complaint, as filed, asserts claims 10 and 12. However, these claims were disclaimed by the inventor during subsequent IPR proceedings. A foundational question for the court would be whether this action can proceed on claims that no longer exist, a question that is typically answered in the negative.

  2. Sufficiency of Factual Allegations: Assuming the claims were still valid, a key question is one of evidentiary sufficiency. The complaint’s infringement theory rests entirely on an external claim chart (Exhibit 2) that was not provided. Without it, the complaint itself offers no specific factual allegations connecting the accused product's features to the patent's claim limitations, raising questions about whether it meets federal pleading standards.

  3. Claim Scope and Manufacturing Process: A central technical issue would be one of definitional scope: can the term "bridge... formed by interconnecting two mating sections," which the patent specification links to a specific successive overmolding process, be construed to cover the manufacturing method used for the accused Denso motor? The outcome of this construction would likely determine the outcome of the infringement analysis.