PTAB

IPR2015-00784

Ford Motor Co v. Paice LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Hybrid Vehicle Control System
  • Brief Description: The ’634 patent discloses a control system for a hybrid electric vehicle (HEV). The system uses a controller that compares the required torque (road load) to a predetermined torque value (setpoint) to manage power flow and switch between different operating modes, such as electric-only, engine-only, or combined power, to improve fuel efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ibaraki - Claims 1-3, 5, 12, 16, 17, 19, 27, 30, and 66 are obvious over Ibaraki in view of the knowledge of a POSA.

  • Prior Art Relied Upon: Ibaraki (Patent 5,789,882).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ibaraki discloses all elements of independent claim 1. Ibaraki teaches a hybrid vehicle with an internal combustion engine, an electric motor, and a controller that manages different drive modes. Specifically, Ibaraki’s controller uses an engine efficiency map (Fig. 5) with a threshold boundary line to determine whether to operate in motor-only mode or engine-drive mode. Petitioner asserted this threshold, which varies with engine speed, is the claimed "setpoint (SP)." When the required engine torque is above this setpoint, the vehicle enters engine-drive mode because it is more fuel-efficient. Petitioner further argued that the setpoint disclosed in Ibaraki is "substantially less than the maximum torque output (MTO)" of the engine, as required by the claim, by showing that Ibaraki's 70% efficiency threshold corresponds to a torque value significantly below 50% of the engine's MTO. Ibaraki also expressly discloses using a separate generator, which Petitioner argued would function as the claimed "first electric motor coupled to the engine."
    • Motivation to Combine (for §103 grounds): This ground relies primarily on a single reference. The motivation was for a person of ordinary skill in the art (POSA) to implement the teachings of Ibaraki using known engineering principles. For instance, a POSA would have found it an obvious design choice to configure Ibaraki's explicitly disclosed separate "generator" to be coupled to the engine to perform its function of generating electricity.
    • Expectation of Success: A POSA would have had a high expectation of success in implementing Ibaraki's control strategy, as it uses conventional components and control logic common in the art at the time.

Ground 2: Obviousness over Ibaraki and Frank - Claims 6-11 are obvious over Ibaraki in view of Frank.

  • Prior Art Relied Upon: Ibaraki (Patent 5,789,882), Frank (Patent 6,116,363).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ibaraki for the base hybrid system and adds Frank to teach the limitations of claims 6-11, which address preventing rapid cycling between operating modes. Petitioner argued that when the road load hovers near the setpoint in Ibaraki's system, the controller would rapidly toggle between motor-drive and engine-drive modes. This "hunting" is a known issue in hybrid vehicles that causes component wear, increases emissions, and reduces drivability. Frank directly addresses this exact problem of "frequent cycling" and teaches the obvious solution of adding a time delay before switching modes. Frank discloses that a transition from one mode to another should only occur after the condition (e.g., road load > setpoint) persists for a predetermined length of time.
    • Motivation to Combine: A POSA would combine Frank's time-delay solution with Ibaraki's control system to solve the known and predictable problem of mode cycling at the setpoint threshold. Implementing this solution would improve the durability and performance of Ibaraki's vehicle, directly aligning with Ibaraki's stated goal of improving fuel consumption and reducing emissions, which are negatively impacted by frequent engine starts and stops.
    • Expectation of Success: Implementing a time-delay in a software control loop is a simple, well-understood, and predictable technique. A POSA would have had a very high expectation of successfully integrating this feature into Ibaraki's controller.

Ground 3: Obviousness over Ibaraki, Jurgen, and Lateur - Claim 23 is obvious over Ibaraki in view of Jurgen and Lateur.

  • Prior Art Relied Upon: Ibaraki (Patent 5,789,882), Jurgen ("Automotive Electronics Handbook"), and Lateur (Patent 5,823,280).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds cruise control functionality, as recited in claim 23, to the Ibaraki system. Claim 23 requires a controller that can receive a desired cruising speed from the operator and then control the torque output of the engine and/or motors to maintain that speed as road load varies. While Ibaraki discloses the underlying mode-switching logic, Jurgen and Lateur both teach conventional cruise control systems. They describe how a controller receives a driver's speed setpoint and modulates the throttle (and thus torque) to maintain that speed, for example, while ascending a hill.
    • Motivation to Combine: A POSA would combine the known cruise control functionality taught by Jurgen and Lateur with Ibaraki's hybrid vehicle to enhance its functionality and further improve fuel efficiency, a primary goal of hybrid vehicles. Integrating cruise control was a known and desirable feature for production vehicles to improve driver comfort and economy. Adding this feature would be a logical and predictable improvement to Ibaraki's system.
    • Expectation of Success: Integrating a standard cruise control input signal into an existing electronic vehicle controller, like that in Ibaraki, was a routine task for automotive engineers. The controller would simply use the cruise control system's torque demand as an input for its existing mode-selection logic, making the modification straightforward with a high expectation of success.

4. Key Claim Construction Positions

  • road load (RL): Petitioner proposed this term be construed as "the amount of instantaneous torque required to propel the vehicle, be it positive or negative." This construction is central to mapping Ibaraki's "vehicle drive torque" to the claimed RL.
  • setpoint (SP): Petitioner proposed this term be construed as "a predetermined torque value." This construction allows Ibaraki's torque-based thresholds on its efficiency maps (Figs. 5 and 11) to be interpreted as the claimed SP.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-3, 5-12, 16, 17, 19, 23, 27, 30, and 66 of the ’634 patent as unpatentable.