PTAB

IPR2015-01229

FCA US LLC v. Jacobs Vehicle Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Controlling the Amount of Lost Motion Between an Engine Valve and a Valve Actuation Means
  • Brief Description: The ’397 patent describes systems for controlling internal combustion engine valve timing and lift. The technology uses a "lost motion" system, which incorporates a variable-length hydraulic linkage (tappet) between the cam and the engine valve, allowing for dynamic adjustment of valve actuation.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 32-33 under 35 U.S.C. § 102

  • Prior Art Relied Upon: Nohira (Patent 4,696,265).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Nohira, which was not considered during the original prosecution, discloses every limitation of claims 32 and 33. Nohira describes a lost motion system for varying engine valve timing and lift using a variable length tappet comprised of two valve lifters defining an "oil pressure chamber." The system functions by supplying hydraulic fluid to this chamber and then selectively bleeding it using a high-speed response control valve to create lost motion between the cam and the engine valve.

    • Petitioner contended that Nohira explicitly meets the key limitation added during prosecution to secure allowance of claim 32: "wherein the step of selectively bleeding is controlled such that the amount of hydraulic fluid in the chamber may be varied one or more times per cycle of the engine and independently of the position of the means for opening an engine cylinder valve." Petitioner asserted that Nohira’s high-speed electronic control valve allows for "continuous and stepless" control of fluid bleeding based on engine operating conditions, not merely cam position. Nohira’s Figure 6 was presented as evidence, showing the actuator being energized four separate times during a single cam revolution, demonstrating that fluid can be varied multiple times per cycle. Petitioner argued this electronic control, modulated by an ECU based on sensor inputs, is necessarily independent of the mechanical cam's position.

    • For dependent claim 33, which requires the tappet be "capable of assuming one of three or more different lengths," Petitioner argued that Nohira's disclosure of actuating the control valve four times per cycle inherently results in the tappet achieving at least four different lengths, thus meeting the claim limitation.

4. Key Claim Construction Positions

  • "Means for Opening an Engine Cylinder Valve": Petitioner proposed this means-plus-function term be construed as "any engine or vehicle component from which a force may be derived to open an engine cylinder valve, including a cam." Petitioner argued the claim term recites only a function without sufficient structure, thus invoking analysis under 35 U.S.C. § 112, para. 6, with the corresponding structure found in the ’397 patent’s specification.

  • "Internal Expansible Chamber of a Variable Length Tappet": Petitioner proposed this term be construed as "a variable volume of space defined between two pistons slidable within one another." This construction was argued to be essential to the claimed invention, as the slidable piston arrangement is what enables the tappet to have a variable length and the chamber to be expansible. Petitioner supported this construction by citing the ’397 patent’s specification and figures, as well as another patent assigned to the Patent Owner that described the term identically.

5. Key Technical Contentions (Beyond Claim Construction)

  • The central technical contention was that a person of ordinary skill in the art (POSITA) would understand Nohira’s disclosure of "continuous and steplessly" controlling hydraulic fluid flow via a high-speed, electronically actuated valve to be control that is "independent" of the cam's physical position. Petitioner argued that because Nohira’s control valve operation is dictated by an ECU based on engine performance parameters, it can be actuated at any time during the engine cycle, irrespective of the cam lobe's position. To support this interpretation, Petitioner cited Babitzka (Patent 4,696,265), another prior art reference that describes a similar system and explicitly uses the term "independently of the position of the cam follower" to describe its control scheme.

7. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 32 and 33 of the ’397 patent as unpatentable under 35 U.S.C. § 102.