PTAB

IPR2017-01494

Toyota Motor Corp v. Intellectual Ventures II LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electromagnetic Device with Open Non-Linear Heat Transfer System
  • Brief Description: The ’509 patent discloses fluid-cooled electromagnetic devices, such as motors and pumps, featuring a “monolithic body” of injection-molded thermoplastic. This body encapsulates electrical conductors and integrates a non-linear pathway for heat transfer fluid to cool the device.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 14, and 15 are obvious over Stephan in view of Raible and Neal ’554.

  • Prior Art Relied Upon: Stephan (German Unexamined Patent Specification DE10307696A1), Raible (Patent 5,368,438), and Neal ’554 (Patent 6,362,554).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stephan discloses a fluid-cooled pump with nearly all claimed features: an injection-molded thermoplastic housing that encapsulates drive coils (conductors), a non-linear fluid pathway for coolant, and a housing that covers the device except for an inlet and outlet. The sole alleged difference is that Stephan’s housing is formed from two halves welded together, whereas the claims require a "monolithic body," which Petitioner construes as a single piece.
    • Motivation to Combine: A POSITA would combine the teachings of Raible and Neal ’554 with Stephan’s device. Raible teaches injection molding a pump housing as a single piece over a rotor. Neal ’554 explicitly teaches the known benefits of forming a motor body as a single monolithic piece, including reduced manufacturing costs, better component alignment, and the avoidance of "stack up tolerances" that arise from joining multiple parts. Petitioner contended that a POSITA would apply these well-understood principles to Stephan’s two-part housing to achieve the same predictable benefits.
    • Expectation of Success: A POSITA would have had a high expectation of success in forming Stephan’s thermoplastic housing as a single monolithic piece using conventional injection molding techniques, as taught by Raible, to realize the advantages described by Neal ’554.

Ground 2: Claims 1, 2, 14, and 15 are anticipated by Stephan under the Patent Owner’s Alleged Claim Construction.

  • Prior Art Relied Upon: Stephan (German Unexamined Patent Specification DE10307696A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative based on the Patent Owner's alleged claim construction of "monolithic body" in co-pending litigation. Petitioner asserted that the Patent Owner construed the term broadly to include multiple pieces that are "fused" together. Under this broad construction, the two injection-molded thermoplastic halves of Stephan’s housing, which are permanently welded together, would constitute a "monolithic body." Because Stephan otherwise discloses all other limitations of claims 1, 2, 14, and 15—including the encapsulated conductors, non-linear fluid path, inlet/outlet, and complete exterior coverage—Stephan would anticipate all challenged claims.
    • Key Aspects: This argument is contingent on the adoption of a claim construction that Petitioner argues is overly broad and inconsistent with the patent's specification.

4. Key Claim Construction Positions

  • “monolithic body” (claims 1 and 14): This term was central to the petition’s alternative invalidity theories.
    • Petitioner’s Proposed Construction: "a body formed as a single piece." Petitioner argued this construction is required by the patent’s express definition (“Monolithic is defined as being formed as a single piece”) and the specification’s consistent distinction between its "single unitized body" and prior art devices made of multiple parts joined together.
    • Contrasted Construction: Petitioner highlighted that the Patent Owner, in a related ITC proceeding, had advanced a broader interpretation where "monolithic body" could be formed from multiple pieces that are "visibly fused" together.
    • Significance: The invalidity argument bifurcates based on this construction. Under Petitioner's "single piece" construction, Stephan does not anticipate but renders the claims obvious in view of secondary references (Ground 1). Under the Patent Owner’s alleged "fused together" construction, Stephan’s welded housing would meet the limitation, making it an anticipating reference (Ground 2).

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 14, and 15 of the ’509 patent as unpatentable.