DCT

1:17-cv-00299

Intellectual Ventures II LLC v. Nidec Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-00299, D. Del., 03/20/2017
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware based on Defendants maintaining a regular place of business, committing alleged acts of infringement, and deriving substantial revenue from the district.
  • Core Dispute: Plaintiff alleges that Defendant’s automotive steering gear assembly infringes a patent related to the manufacturing of stators for electric motors.
  • Technical Context: The technology concerns methods for manufacturing electric motor stators by linking discrete metal segments with a moldable material, designed to improve winding efficiency and thermal performance in high-speed motors.
  • Key Procedural History: The complaint was filed on March 20, 2017. Subsequent to the filing, the inventor filed a terminal disclaimer on June 11, 2018, disclaiming all asserted claims (10 and 12). Furthermore, an Inter Partes Review (IPR) Certificate issued on September 27, 2019, confirms that claims 1-6 and 8-14, which includes all asserted claims, are disclaimed. These post-filing events appear to be dispositive of the infringement claims as asserted in the original complaint.

Case Timeline

Date Event
2001-03-02 ’952 Patent Priority Date
2006-06-27 ’952 Patent Issue Date
2017-03-20 Complaint Filing Date
2018-06-11 Inventor files disclaimer for claims 1-6 and 8-14 of the ’952 Patent
2019-09-27 Inter Partes Review Certificate issues, confirming claims 1-6 and 8-14 of the ’952 Patent are 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," issued June 27, 2006

The Invention Explained

  • Problem Addressed: The patent describes several problems with conventional methods of manufacturing stators for electric motors, particularly high-speed spindle motors used in hard disk drives. These problems include inconsistent magnetic properties due to steel grain orientation, difficulty achieving high wire-packing density in small spaces, accumulation of manufacturing tolerances ('stack up'), and inefficient heat dissipation ('952 Patent, col. 1:7-18, col. 2:19-28, col. 2:46-64).
  • The Patented Solution: The invention proposes manufacturing a stator from a plurality of individual arc-shaped segments made of steel laminations. These discrete segments are linked together into a flexible, continuous strip by a "phase change material," such as an injection-molded thermoplastic, that also forms a "webbing" or "bridge" between them ('952 Patent, Abstract; col. 5:46-54). This linear strip of segments can be easily wound with wire and then bent into a final circular (toroidal) shape for the stator assembly, solving the winding access problem and allowing for more uniform construction ('952 Patent, col. 6:55-65; Fig. 6).
  • Technical Importance: This method was intended to enable the production of smaller, more powerful, and more reliable electric motors by improving manufacturing consistency, wire packing density, and thermal management ('952 Patent, col. 11:1-8, col. 11:31-38).

Key Claims at a Glance

  • The complaint asserts independent claim 10 and dependent claim 12 ('952 Patent, Compl. ¶18).
  • Independent Claim 10 requires:
    • 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
    • the bridge is formed by interconnecting two mating sections formed from the phase change material
    • the linked stator segments are arranged and secured together to form the stator assembly

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Nidec Assembly Steering Gear with Honda part number 53600-TY2-A61" as the "Exemplary Nidec Product" ('952 Patent, Compl. ¶11).

Functionality and Market Context

  • The complaint does not provide any description of the accused product's specific features, internal construction, or method of operation. It is identified only by name and part number ('952 Patent, Compl. ¶11). The complaint makes no allegations regarding the product's commercial importance beyond its inclusion in this infringement action.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused Nidec product infringes claims 10 and 12 of the ’952 Patent ('952 Patent, Compl. ¶18). It states that an "Exhibit 2" contains a chart comparing the claims to the product ('952 Patent, Compl. ¶13, ¶20). However, this exhibit was not filed with the complaint. The complaint’s narrative allegations are limited to the conclusory statement that "the Exemplary Nidec Product practices, in whole or in material part, the technology claimed by the Patent-in-Suit" ('952 Patent, Compl. ¶14). No specific components or functions of the accused steering gear are mapped to any claim elements in the body of the complaint.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: A primary question is whether the claims, which are described in the patent specification almost exclusively in the context of "spindle motor[s] such as used in a hard disc drive" ('952 Patent, col. 1:19-21), can be construed to read on the components of an "Assembly Steering Gear" for an automobile.
  • Technical Questions: The complaint provides no facts to support its infringement theory. A key question would be what evidence exists that the accused steering gear contains "discrete stator segments" linked by a "bridge" made of a "phase change material," as required by claim 10.

V. Key Claim Terms for Construction

"phase change material" (Claim 10)

Context and Importance

  • The definition of this term is central, as it forms the insulating encasement, the linking "bridge," and the "mating sections" that connect segments. The infringement analysis depends on whether the material used in the Nidec product meets the definition of a "phase change material" as contemplated by the patent.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification defines it broadly as "a material that can be used in a liquid phase to envelope the stator, but which later changes to a solid phase" ('952 Patent, col. 6:6-9). This could potentially encompass a wide range of thermoplastics, thermosetting materials, and epoxies.
  • Evidence for a Narrower Interpretation: The specification provides significant detail on "preferred" materials, describing specific temperature-activated thermoplastics that solidify in a range of "about 200° F. to about 700° F." ('952 Patent, col. 6:16-19), and materials with specific thermal conductivity (at least 0.4 watts/meter° K) and coefficients of linear thermal expansion (CLTE) ('952 Patent, col. 8:51-56, col. 8:61-64). A defendant could argue these properties are essential to the invention, not merely preferred.

"bridge between adjacent segments" (Claim 10)

Context and Importance

  • This structure is the claimed mechanism for linking the discrete segments into a "continuous strip." Infringement requires finding this specific linking structure in the accused product, rather than another method of assembly. Practitioners may focus on this term to distinguish the claimed method from prior art or alternative manufacturing techniques.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The term could be construed broadly to mean any material connection that links the segments. Claim 2, which depends from claim 1, describes the bridges as producing a "continuous linkage" that may be "used to orient and manipulate the segments during wire winding" ('952 Patent, col. 13:11-15).
  • Evidence for a Narrower Interpretation: The patent describes the bridge as part of the "webbing 23" formed during an injection molding process ('952 Patent, col. 5:4-5, col. 6:4-5). Claim 10 further requires the bridge to be "formed by interconnecting two mating sections." This suggests a specific, molded structure, potentially limiting the term to exclude simple adhesive links or other connection types.

VI. Other Allegations

Willful Infringement

  • The complaint does not contain an explicit allegation of willful infringement or plead any facts regarding pre- or post-suit knowledge by the Defendant. The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, but does not provide a factual basis for this request in the body of the complaint ('952 Patent, Compl. p. 4).

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

  1. Viability of Asserted Claims: The most critical issue is the legal status of the asserted claims. Given that an IPR certificate and an inventor disclaimer confirm that claims 10 and 12 were disclaimed post-filing, a central question is whether any viable cause of action remains from the original complaint.

  2. Claim Scope and Applicability: Should the case proceed, a core issue will be one of definitional scope: can the term "stator assembly," as defined and claimed in a patent focused on high-speed hard disk drive motors, be construed to cover the components within an automotive power steering system?

  3. Sufficiency of Factual Allegations: A key threshold question is one of evidentiary support: does the complaint, which lacks any specific factual allegations tying the accused product's features to the claim elements, meet the plausibility standard for pleading patent infringement, or is there a fundamental mismatch in the asserted technical operation?