PTAB

IPR2016-00502

Valeo North America Inc v. Schaeffler Technologies Ag & Co KG

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Rotational Speed Adaptive Absorber
  • Brief Description: The ’740 patent describes a force transmission device, such as a torque converter, containing a rotational speed adaptive vibration absorber. The core concept is "overtuning" a centrifugal pendulum absorber by a specific "order shift value" to improve damping properties by compensating for the influence of the oil in which it operates.

3. Grounds for Unpatentability

Ground 1: Claims 1-13 are obvious over Eckel in view of Sudau and Speckhart

  • Prior Art Relied Upon: Eckel (Patent 6,450,065), Sudau (Patent 6,026,940), and Speckhart (Patent 5,295,411).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Eckel taught a speed-adaptive dynamic vibration absorber that uses a tuning factor (k) to modify its geometry and shift its effective absorption order. This tuning explicitly compensated for "hydrostatic and hydrodynamic effects resulting from a lubricant," such as oil. Petitioner contended that Eckel's tuning factor k was mathematically equivalent to the ’740 patent’s "order shift value" (qF). For example, Eckel's disclosed k value of 0.8 for a four-cylinder engine resulted in an order shift of 0.236, which fell squarely within the ’740 patent’s claimed range of 0.05 to 0.5 for compensating for oil influence. Sudau taught a conventional torque converter with a vibration damper operating in fluid, and Speckhart taught that centrifugal pendulum absorbers like Eckel’s were well-suited for use in various powertrain components, including torque converters.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Eckel's advanced, lubricant-compensating absorber with Sudau's standard torque converter to predictably achieve the known benefit of improved vibration damping in a powertrain. Speckhart explicitly provided the rationale by teaching that such absorbers are suitable for precisely this application.
    • Expectation of Success: A POSITA would have a high expectation of success, as applying a known vibration absorber to a known rotating component to damp known vibrations was a common and predictable engineering practice.

Ground 2: Claims 1-4 and 6-13 are obvious over Nester in view of Sudau and Speckhart

  • Prior Art Relied Upon: Nester (SAE Paper 2003-01-1484), Sudau (Patent 6,026,940), and Speckhart (Patent 5,295,411).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Nester taught the benefits of "slightly overtuned" crankshaft-mounted pendulum absorbers operating in lubricating oil to extend their effective range. For a four-cylinder engine with a second-order vibration (order q = 2), Nester explicitly taught tuning the absorber to an effective order of 2.15. This created an order shift of 0.15, which is within the ’740 patent’s disclosed range (0.05-0.5) and nearly identical to the patent’s preferred embodiment value of approximately 0.14. The arguments for combining this teaching with Sudau and Speckhart were analogous to those in Ground 1.
    • Motivation to Combine: The motivation was the same as in Ground 1: a POSITA would apply the known benefits of Nester's overtuned absorber, which already operated in oil, to a standard torque converter as taught by Sudau to achieve improved vibration damping. Speckhart again confirmed the suitability of this combination.
    • Expectation of Success: Success would be predictable, as the principles of applying Nester's overtuned absorber to a different rotating part of a powertrain (a torque converter instead of a crankshaft) were well-understood.

Ground 3: Claim 5 is obvious over Nester, Sudau, and Speckhart in view of Eckel

  • Prior Art Relied Upon: Nester (SAE Paper 2003-01-1484), Sudau (Patent 6,026,940), Speckhart (Patent 5,295,411), and Eckel (Patent 6,450,065).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targeted claim 5, which required that the size of the order shift value (qF) changes proportionally to a change in the excitation order (q). Petitioner argued that while the primary combination including Nester established an overtuned absorber, Nester only provided a single data point and did not explicitly teach this proportional relationship. Eckel, however, provided a general tuning formula (R = k * L/x²) from which this proportional relationship could be directly derived.
    • Motivation to Combine: A POSITA, having combined Nester with Sudau and Speckhart, would be motivated to consult a reference like Eckel to generalize the overtuning principle for different engine types (e.g., 6-cylinder vs. 4-cylinder engines), which have different excitation orders. Eckel’s formula provided the explicit, predictable mathematical relationship needed to implement this, thus rendering the proportional limitation of claim 5 obvious.

4. Key Claim Construction Positions

  • "tuned as a function of an oil influence" (Claims 1-13): Petitioner argued this term should be construed to mean "overtuned by an order shift value within the range that compensates for the influence of oil on the absorber." Petitioner contended that the only explanation the ’740 patent provided for this "function" was the bald identification of a numerical range for the order shift (0.05 to 0.5), making this range the essential character of the invention and the proper scope of the claim term. This construction was critical to mapping the specific numerical results from Eckel and Nester onto the claims.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-13 of the ’740 patent as unpatentable.