PTAB

IPR2015-01336

FCA US LLC v. Jacobs Vehicle Systems Inc

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1. Case Identification

2. Patent Overview

  • Title: Variable Lost Motion Valve Actuator and Method
  • Brief Description: The ’282 patent discloses a variable valve actuation system for an internal combustion engine. The system uses a hydraulic "lost motion" mechanism to vary the lift of an engine valve, where a trigger valve controls hydraulic fluid to adjust how much of a cam's motion is transferred to the valve. The challenged claims add specific control strategies for determining valve timing based on parameters like engine mode, load, speed, and temperature. Petitioner argued that these control strategies were added in a later-filed application, establishing a priority date of December 29, 2000, and rendering an earlier publication by the same inventor (Vorih) prior art.

3. Grounds for Unpatentability

Ground 1: Obviousness over Vorih and Wunning - Claim 1 is obvious over Vorih in view of Wunning.

  • Prior Art Relied Upon: Vorih (International Publication No. WO 99/30011) and Wunning (Patent 5,201,296).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Vorih disclosed all structural elements of the variable valve actuation system recited in claim 1, including the hydraulic lost motion mechanism and an electronic controller. However, Vorih was silent on the specific parameters used by the controller to determine valve timing, stating only that it optimizes engine operation. Wunning allegedly supplied this missing element by teaching a control strategy for variable valve systems that determines valve timing based on the exact parameters recited in claim 1: a selected engine mode, engine speed, and engine load.
    • Motivation to Combine: Petitioner argued that Vorih expressly stated its system was intended to optimize engine performance under various conditions but left the specific control parameters to a person of ordinary skill in the art (POSITA). Wunning disclosed a well-known control strategy in the same field to achieve this exact goal of optimization. A POSITA would combine Wunning’s known control logic with Vorih’s known mechanical system to achieve the predictable result of a fully functional and optimized variable valve actuation system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying a known control technique to a known, compatible system for its intended purpose.

Ground 2: Obviousness over Vorih, Wunning, and Takizawa - Claims 4 and 10 are obvious over Vorih in view of Wunning and Takizawa.

  • Prior Art Relied Upon: Vorih (WO 99/30011), Wunning (’296 patent), and Takizawa (Patent 4,258,671).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1. While Vorih and Wunning combined to teach the base system controlled by engine mode, speed, and load, dependent claims 4 and 10 added the limitation of further determining or modifying valve timing based on engine oil or fluid temperature. Petitioner contended that Takizawa disclosed this additional element. Takizawa taught a hydraulic valve system where an initial valve timing signal, based on speed and load, is explicitly "modified on the basis of the temperature of the oil under pressure."
    • Motivation to Combine: A POSITA would recognize that the hydraulic system of Vorih would be affected by changes in the viscosity of its hydraulic fluid (oil) due to temperature fluctuations, which could impair timing accuracy. Takizawa taught the precise solution: modifying the valve timing signal based on oil temperature to compensate for such viscosity changes. Therefore, a POSITA would be motivated to add Takizawa's temperature compensation method to the Vorih/Wunning system to improve its precision and reliability, a predictable improvement.
    • Expectation of Success: The combination represented the application of a known technique (temperature compensation) to improve a similar device (a hydraulic valve actuator), which would have yielded predictable results.

Ground 3: Anticipation by Takizawa - Claims 25 and 27-30 are anticipated by Takizawa.

  • Prior Art Relied Upon: Takizawa (’671 patent).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Takizawa disclosed every element of the method claimed in independent claim 25. This included the steps of determining a current temperature of an engine fluid, determining a timing modification based on that temperature, modifying the timing of a trigger valve, and transmitting the resulting actuation motion to an engine valve. For dependent claims 27-30, which specified that the timing modification "advances" or "delays" opening or closing times, Petitioner argued that this was inherent in Takizawa’s disclosure. Takizawa taught modifying an ON-OFF signal, and a POSITA would understand that modifying such a signal to compensate for temperature changes would necessarily involve advancing or delaying it.
    • Key Aspects: This ground asserted that a single reference taught the entire claimed method of temperature-based timing modification, without needing any combination of references.

  • Additional Grounds: Petitioner asserted that claims 13 and 15-18 are obvious over Vorih in view of Takizawa, arguing that a POSITA would apply Takizawa's temperature-based control strategy to Vorih's mechanical system. Petitioner also asserted, in the alternative, that claims 27-30 are obvious over Takizawa.

4. Key Claim Construction Positions

  • Petitioner argued that several terms in the challenged claims should be construed as means-plus-function limitations under 35 U.S.C. § 112, paragraph 6.
  • "means for hydraulically varying the amount of engine valve actuation" (Claim 1): Petitioner proposed this term requires the function of "hydraulically varying the amount of engine valve actuation" and identified the corresponding structure in the ’282 patent specification as the components of hydraulic system 300 (excluding the trigger valve) and the pivoting bridge 200.
  • "means for determining trigger valve actuation and deactuation times..." (Claim 1): Petitioner proposed this requires the function of determining timing based on engine mode, load, and speed, and identified the corresponding structure as an "electronic valve controller including a microprocessor and a non-volatile memory storing valve timing based on engine mode maps, engine speed and engine load," such as controller 500.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 4, 10, 13, 15-18, 25, and 27-30 of the ’282 patent as unpatentable.