PTAB

IPR2015-00800

Ford Motor Co v. Paice LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Hybrid Vehicles
  • Brief Description: The ’634 patent describes a control strategy and topology for a series-parallel hybrid electric vehicle. The system uses a microprocessor to control an internal combustion engine, a starting motor, and a traction motor based on instantaneous torque demands ("road load") and predefined torque setpoints to ensure the engine operates only under conditions of high efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over The Durham Project, Frank, and POSA Knowledge - Claims 80, 91-92, 95-96, 99-100, 102, 106, 114, and 125-135 are obvious over The Durham Project in view of Frank and the general knowledge of a POSA.

  • Prior Art Relied Upon: The Durham Project (a series of publications including Bumby I-V and the Masding Thesis, 1985-1990) and Frank (Patent 6,116,363).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that The Durham Project, a collection of related publications describing a hybrid vehicle research project, discloses the core limitations of independent claim 80. The Durham Project taught a control strategy for a parallel hybrid vehicle that selects an operating mode (motor-only, engine-only, or engine-motor hybrid) based on comparing the actual torque required for propulsion (“road load”) and vehicle speed against predefined torque and speed thresholds (“setpoints”). This strategy operates the motor alone when road load is below a lower torque bound (the setpoint), the engine alone when road load is between the lower and upper torque bounds, and both the engine and motor when road load exceeds the upper torque bound. Petitioner contended this maps directly to the claimed methods of operating the motor when road load is less than a setpoint (SP), operating the engine when road load is between the SP and the maximum torque output (MTO), and operating both when road load exceeds the MTO. To address the limitation requiring a time-delay hysteresis to prevent frequent engine cycling, Petitioner relied on Frank. Frank was cited for its teaching of using a time delay between "on" and "off" modes as a well-known hysteresis solution to prevent frequent engine cycling in a hybrid vehicle.
    • Motivation to Combine: Petitioner asserted that The Durham Project publications are a chronological series detailing a single research project, with later papers expressly citing earlier ones, providing an explicit reason to combine them. A POSA would combine these references to understand the full context of the project's control strategy. The motivation to combine The Durham Project with Frank stemmed from a shared problem: both recognized that frequent engine starts and stops cause excessive wear. Because The Durham Project identified this issue and Frank provided a known, simple time-based solution, a POSA would have been motivated to apply Frank’s time-delay hysteresis to the torque-based setpoints of The Durham Project as an obvious design choice.
    • Expectation of Success: A POSA would have had a reasonable expectation of success in applying Frank’s time-delay solution, as hysteresis techniques were known to be effective in preventing unnecessary engine cycling regardless of the specific nature of the setpoint (e.g., torque-based vs. speed-based).

Ground 2: Obviousness over The Durham Project and POSA Knowledge - Claims 161, 172, 215, 226, 230, 233, and 234 are obvious over The Durham Project in view of the general knowledge of a POSA.

  • Prior Art Relied Upon: The Durham Project (a series of publications including Bumby I-V and the Masding Thesis, 1985-1990).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenged a separate group of claims, including independent claims 161 and 215, which Petitioner argued were largely reformulations of the subject matter challenged in Ground 1. Petitioner contended that the limitations of these claims were taught by The Durham Project for the same reasons articulated in Ground 1. The arguments for how The Durham Project’s control strategy met limitations related to operating modes (low-load, cruising, acceleration), road load monitoring, and setpoint comparisons were incorporated by reference from the analysis of claim 80 and its dependents.
    • Motivation to Combine: The motivation to combine the various publications comprising The Durham Project was the same as asserted in Ground 1.
    • Expectation of Success: This argument was not explicitly separated for this ground but was inherent in the assertion that The Durham Project’s teachings rendered the claims obvious.

4. Key Claim Construction Positions

  • "road load (RL)": Petitioner proposed construing this term 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 central to mapping the prior art's concept of "tractive effort" or "torque requirements at the road wheels" to the claims.
  • "setpoint (SP)": Petitioner argued for the construction "predetermined torque value." This was based on the patent's file history, where the patentee distinguished prior art by defining the setpoint as being "substantially less than the maximum torque output," implying it is a torque value. This construction was critical for comparing the torque-based thresholds in The Durham Project directly to the claimed "setpoint."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 80, 91, 92, 95, 96, 99, 100, 102, 106, 114, 125, 126, 129, 132, 133, 135, 161, 172, 215, 226, 230, 233, and 234 of the ’634 patent as unpatentable.