PTAB

IPR2015-00787

Ford Motor Co v. Paice LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Hybrid vehicles
  • Brief Description: The ’634 patent describes methods for controlling a hybrid vehicle powertrain. The control strategy uses the vehicle's instantaneous torque demand ("road load") and compares it to a torque "setpoint" to switch between operating modes: electric motor only, internal combustion engine only, or both combined to optimize efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ibaraki - Claims 33, 34, 35, 38, and 215 are obvious over Ibaraki and the general 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 taught a control apparatus for a hybrid vehicle that selects operating modes to reduce fuel consumption. Ibaraki’s controller used a data map (Fig. 11) that plots "vehicle drive torque" against "vehicle speed" to select one of three modes: MOTOR DRIVE, ENGINE DRIVE, or ENGINE-MOTOR DRIVE. Petitioner contended this "vehicle drive torque" is the claimed "road load (RL)." The boundary lines on the map that trigger a switch between modes (e.g., boundary line B) function as the claimed "setpoint (SP)." Ibaraki disclosed operating the motor when torque is below the boundary (RL < SP), the engine when torque is between two boundaries, and both when torque is above the upper boundary, which corresponds to the engine's maximum torque output (MTO). Ibaraki also taught adjusting the setpoint boundary line based on driving patterns (e.g., on a mountain path) to prevent excessive battery charging, which meets the limitation of monitoring operation patterns and varying the SP accordingly.
    • Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference plus general knowledge. Petitioner argued that a POSA would have understood the concepts taught in Ibaraki as directly corresponding to the elements of the challenged claims.
    • Expectation of Success (for §103 grounds): A POSA would expect success in applying Ibaraki’s disclosed control strategy, as it was designed for the explicit purpose of efficiently managing a hybrid powertrain.

Ground 2: Obviousness over Ibaraki and Vittone - Claims 53, 241, and 252-256, 259, 261, 262 are obvious over Ibaraki in view of Vittone and the general knowledge of a POSA.

  • Prior Art Relied Upon: Ibaraki (Patent 5,789,882) and Vittone (a 1994 International Electric Vehicle Symposium paper).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Ibaraki taught the base hybrid control strategy as detailed in Ground 1. Vittone was introduced to teach the additional limitations of claim 241, specifically controlling the engine at a stoichiometric ratio to reduce emissions. Vittone disclosed a "driving torque management" strategy that explicitly limited the rate of change of engine torque during "transient phases" (e.g., rapid acceleration) to maintain stoichiometric operation. During these periods, Vittone taught using the electric motor to supply any supplemental torque required for driveability, thereby meeting the limitation of supplying additional torque from the motor when the engine is incapable of doing so.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Vittone’s stoichiometric control strategy with Ibaraki’s system to further Ibaraki’s stated goal of reducing exhaust gas emissions. Vittone taught that its control strategy could be implemented via a simple software modification to an existing electronic unit, making the combination straightforward and predictable.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as the combination involved applying a known emissions-control software strategy (Vittone) to a conventional hybrid vehicle architecture (Ibaraki) to achieve the predictable result of improved emissions.

Ground 3: Obviousness over Ibaraki and Yamaguchi - Claims 54, 238, 267, and 281, 282, 285, 287, 288 are obvious over Ibaraki in view of Yamaguchi and the general knowledge of a POSA.

  • Prior Art Relied Upon: Ibaraki (Patent 5,789,882) and Yamaguchi (Patent 5,865,263).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground again used Ibaraki for the base control method. Yamaguchi was introduced to teach the limitation of rotating the engine before starting it to heat its cylinders, as recited in claim 267. Yamaguchi disclosed a method for reducing cold-start emissions in a hybrid vehicle by rotating the engine up to a predetermined speed (e.g., 600 rpm) before ignition. Petitioner argued that a POSA would understand this pre-ignition rotation heats the cylinders through friction and air compression.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Yamaguchi’s preheating technique with Ibaraki’s system to address the well-known problem of cold-start emissions, which are frequent in hybrid vehicles due to repeated engine cycling. Adding this functionality would further Ibaraki's objective of reducing emissions and would predictably improve fuel economy on startup.
    • Expectation of Success (for §103 grounds): Success would be expected because the combination involved applying a known solution (Yamaguchi's preheating) for a known problem (cold starts) to a standard hybrid system (Ibaraki) using existing hardware (the generator/motor).

4. Key Claim Construction Positions

  • road load (RL): Petitioner proposed construing "road load" as "the amount of instantaneous torque required to propel the vehicle, be it positive or negative." This construction was argued to be critical for mapping the term to the "vehicle drive torque" disclosed in the Ibaraki reference.
  • setpoint (SP): Petitioner proposed construing "setpoint" as a "predetermined torque value." This was based on the patent's specification and prosecution history, where the setpoint is consistently compared to torque-based values. This construction was necessary to equate the claimed "setpoint" with the torque-based boundary lines in Ibaraki's control maps.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 33-35, 38, 53, 54, 215, 238, 241, 252-256, 259, 261, 262, 267, 281, 282, 285, 287, and 288 of the ’634 patent as unpatentable.