PTAB

IPR2015-01338

FCA US LLC v. Jacobs Vehicle Systems Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Variable Lost Motion Valve Actuator and Method
  • Brief Description: The ’276 patent describes a variable valve actuation system for an internal combustion engine. The system uses a hydraulic "lost motion" mechanism to alter engine valve lift, which is controlled by an electronic controller that adjusts valve timing based on parameters including engine temperature, load, operating mode, and speed.

3. Grounds for Unpatentability

Ground 1: Claims 1-10, 17, 19-23, 26, and 28 are anticipated under 35 U.S.C. §102 by Sono

  • Prior Art Relied Upon: Sono (Patent 5,140,955).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sono disclosed every element of independent claim 1 and the relevant dependent claims. Specifically, Sono was asserted to teach a hydraulic lost motion system with a first piston (cam side piston 56) and a second piston (valve side piston 54) connected by a hydraulic circuit. Petitioner contended that Sono’s electronic control unit (ECU) functions as the claimed controller, actuating a solenoid to control the engine valve in response to the same four parameters recited in claim 1: temperature (via an oil temperature sensor), engine load (via an accelerator pedal sensor), at least one engine operating mode (Sono discloses normal, high coolant temperature, knocking, and abnormal modes), and engine speed (via a crank angle sensor). Petitioner further argued that Sono disclosed the limitations of the challenged dependent claims, such as using engine oil as the hydraulic fluid, responding to a plurality of operating modes, and controlling an intake valve.

Ground 2: Claim 27 is obvious over Sono in view of Bowman

  • Prior Art Relied Upon: Sono (Patent 5,140,955) and Bowman (Patent 5,127,375).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Sono taught all elements of claim 1, upon which claim 27 depends. Claim 27 adds the limitation that the engine valve is movable by the second piston via "at least one intermediate valve train component." While Sono’s second piston directly abuts the engine valve, Petitioner argued that Bowman disclosed a lash adjustor assembly—a well-known intermediate component used in such systems to control the degree to which a poppet valve seats on its valve seat.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would be motivated to incorporate Bowman’s lash adjustor into Sono’s system to achieve the well-known benefit of adjusting valve lash. Petitioner noted that the ’276 patent itself acknowledged the existence of separate lash adjustment hardware in the prior art, suggesting it was a known solution to a known problem.
    • Expectation of Success: The combination was presented as a straightforward integration of a known component (lash adjustor) into a known system (hydraulic valve actuator) to achieve a predictable result (controlled valve seating), and therefore would have been obvious with a reasonable expectation of success.

Ground 3: Claims 6, 8-10, and 19-22 are obvious over Sono in view of Wunning

  • Prior Art Relied Upon: Sono (Patent 5,140,955) and Wunning (Patent 5,201,296).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Sono already disclosed the "normal" and "transient" modes required by dependent claim 6. As an alternative position, Petitioner argued that if Sono's disclosed modes were deemed insufficient, Wunning explicitly taught additional relevant modes, such as engine starting (a warm-up mode) and engine braking (a transient mode). Wunning also taught sophisticated control strategies for optimizing both valve opening and closing timing based on a wide set of inputs, including engine mode, speed, load, and temperature. This disclosure was argued to meet the functional limitations of claims 8-10 (timing as a function of speed, load, and crank angle) and 19-22 (advancing or delaying valve timing).
    • Motivation to Combine: A POSITA would combine Wunning’s advanced control logic with Sono’s hydraulic actuator system to better achieve Sono’s stated objective of "optimum" valve timing and improved engine output. Wunning provided a more comprehensive control strategy that would allow for optimization over a wider range of operating conditions than Sono’s more basic approach.
    • Expectation of Success: Petitioner argued that applying a known, more advanced control strategy (Wunning) to a known mechanical system (Sono) to enhance its performance was a predictable application of known techniques. Wunning itself suggested that its valve timing maps could be readily substituted into other systems.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-10, 17, 19-23, and 26-28 of Patent 8,820,276 as unpatentable.