PTAB

IPR2015-00791

Ford Motor Co v. Paice LLC

Key Events

Petition

petition

Case #: IPR2015-00791
Patent #: 7,237,634
Filed: February 22, 2015
Petitioner(s): Ford Motor Company
Patent Owner(s): Paice LLC & Abell Foundation, Inc.
Challenged Claims: 33, 37, 39-41, 80, 93, 94, 96, 99, 106, 107, 108, 113, 114, 127, 128, 132, 139, 140, 141, 146, 215, 229, and 231

Title: Method for Controlling a Hybrid Vehicle
Brief Description: The ’634 patent describes a method for controlling a hybrid electric vehicle powertrain having an engine and at least one electric motor. The control strategy involves monitoring the instantaneous road load (RL) and comparing it to a predetermined torque setpoint (SP) to transition between operating modes—such as electric-only, engine-only, or combined power—to optimize fuel efficiency.

Prior Art Relied Upon: Ibaraki (Patent 5,789,882).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Ibaraki taught the core control strategy of the challenged claims. Ibaraki’s controller selects from three operating modes (motor-only, engine-only, engine-motor combined) based on a data map (Fig. 11) that plots "vehicle drive torque" against vehicle speed. Petitioner contended that Ibaraki’s "vehicle drive torque" is the same as the claimed "road load (RL)." The boundary line "B" on Ibaraki’s map, which dictates the transition from motor-only to engine-drive mode, was argued to be the claimed "setpoint (SP)." Ibaraki’s system also enters a combined engine-motor mode for high torque demands, which Petitioner mapped to the claimed limitation of operating both power sources when RL exceeds the engine's maximum torque output (MTO).
- Key Aspects: The central argument rests on equating Ibaraki's graphical control parameters with the claimed terms, asserting that Ibaraki’s well-known hybrid control map rendered the claimed method obvious.

Prior Art Relied Upon: Ibaraki (Patent 5,789,882), Frank (Patent 6,116,363).
Core Argument for this Ground:
- Prior Art Mapping: This ground adds Frank to address claim limitations requiring a time delay in mode switching. While Ibaraki disclosed the fundamental mode-switching strategy, its system lacked logic to prevent rapid and inefficient cycling between modes if the road load hovered near the setpoint. Frank explicitly recognized this "frequent cycling" as a known problem in hybrid vehicles and taught that it was correctable "with a time delay."
- Motivation to Combine: A POSITA would combine Frank’s time-delay solution with Ibaraki’s control system to address the predictable problem of powertrain harshness, increased emissions, and potential component damage caused by erratic mode switching. This modification would predictably improve drivability and durability.
- Expectation of Success: A POSITA would have a high expectation of success because implementing a time delay is a simple software modification to existing control logic and a well-established solution for preventing system instability.

Prior Art Relied Upon: Ibaraki (Patent 5,789,882), Frank (Patent 6,116,363), Suga (Patent 5,623,104).
Core Argument for this Ground:
- Prior Art Mapping: This combination addresses claims requiring the electric motor to be powerful enough to handle acceleration during a specific urban driving test cycle without engine assistance. Suga disclosed a test apparatus and procedure for determining an electric motor's performance capabilities across the known LA4 drive cycle (a precursor to the Federal Urban Driving Schedule, or FUDS).
- Motivation to Combine: A POSITA developing the Ibaraki/Frank hybrid system would be motivated to consult a reference like Suga to select an appropriately sized electric motor. Suga provided a direct, known methodology for ensuring a motor could meet specific performance demands, making its teachings an obvious tool for optimizing the vehicle for city driving efficiency.
- Expectation of Success: Success was highly predictable, as this combination merely involves applying standard engineering component selection and testing principles (from Suga) to a known system (Ibaraki/Frank) to achieve a desired performance goal.

Prior Art Relied Upon: Ibaraki (Patent 5,789,882), Jurgen ("Automotive Electronics Handbook"), Lateur (Patent 5,823,280).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted the obviousness of adding cruise control functionality to Ibaraki's vehicle. Ibaraki already described a controller that receives operator inputs to manage the powertrain. Jurgen and Lateur both taught conventional closed-loop cruise control systems where a controller receives a desired speed setpoint and modulates power to maintain it.
- Motivation to Combine: A POSITA would be motivated to add this standard feature to Ibaraki's vehicle for the well-known benefits of improved fuel efficiency and driver convenience. Integrating Jurgen's or Lateur’s teachings would simply involve modifying Ibaraki’s controller to accept a speed setpoint input instead of relying solely on the accelerator pedal position.
- Expectation of Success: A POSITA would have expected success, as integrating a standard cruise control function into a vehicle's existing electronic controller was a routine and well-understood task in the automotive arts.

"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 was argued to be consistent with prior PTAB decisions and was critical to mapping the term onto Ibaraki’s disclosed "vehicle drive torque."
"setpoint (SP)": Petitioner proposed construing "setpoint" as a "predetermined torque value." This was presented as a narrower and more accurate construction than the Patent Owner’s proposed definition, based on the patent’s specification and the prosecution history of a parent patent (’347 patent). This construction was essential for identifying the boundary line on Ibaraki's control map as the claimed setpoint.

Petitioner requested the institution of an inter partes review and the cancellation of claims 33, 37, 39-41, 80, 93, 94, 96, 99, 106-108, 113, 114, 127, 128, 132, 139-141, 146, 215, 229, and 231 of Patent 7,237,634 as unpatentable under 35 U.S.C. §103.