PTAB
IPR2017-01539
Aisin Seiki Co Ltd v. Intellectual Ventures II LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2017-01539
- Patent #: 7,683,509
- Filed: June 9, 2017
- Petitioner(s): Aisin Seiki Co., Ltd., Toyota Motor Corp.
- Patent Owner(s): Intellectual Ventures II LLC
- Challenged Claims: 1–3, 7, and 14–15
2. Patent Overview
- Title: Electromagnetic Devices with Encapsulated Components
- Brief Description: The ’509 patent discloses electromagnetic devices, such as fluid pumps, where components are substantially encapsulated in a monolithic body of phase-change material like thermoplastic. This configuration includes a coolant channel running through the body to protect device parts from corrosive environments and provide improved cooling.
3. Grounds for Unpatentability
Ground 1: Claims 1–3, 7, and 14–15 are obvious over Umeda in view of Raible and Neal.
- Prior Art Relied Upon: Umeda (JP Publication No. H11-166500), Raible (Patent 5,368,438), and Neal (Patent 6,362,554).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Umeda, a fluid-cooled electromagnetic pump, taught most limitations of the challenged claims, including a resin-molded stator with electrical conductors and a non-linear fluid pathway. However, Umeda’s pump casing consisted of two attached pieces (a molded stator and a cover) and did not explicitly teach an injection-molded thermoplastic material. Neal was cited for expressly teaching a motor with a monolithic body made of injection-molded thermoplastic that encapsulates conductors. Raible was cited for disclosing a pump with a housing injection-molded as a single piece. Petitioner asserted that combining these references would supply the missing elements of a truly monolithic body formed from injection-molded thermoplastic.
- Motivation to Combine: A POSITA would combine Umeda with Neal and Raible to achieve the well-understood benefits described by Neal: reducing manufacturing costs, decreasing the number of parts, improving component alignment, and avoiding stack-up tolerances by replacing Umeda’s two-part assembly with a single, integrated monolithic body. It was well-known to use injection molding for encapsulating pump motors.
- Expectation of Success: A POSITA would have a reasonable expectation of success because injection molding of thermoplastics was a common and well-established technique for manufacturing encapsulated motors, and the combination involved applying known technologies for their predictable results.
Ground 2: Claims 1–3, 7, and 14–15 are obvious over Umeda in view of Stephan.
- Prior Art Relied Upon: Umeda (JP Publication No. H11-166500) and Stephan (German Application No. 103 07 696).
- Core Argument for this Ground:
- Prior Art Mapping: This ground was presented as an alternative based on the Patent Owner's alleged broad construction of "monolithic body" to include multiple pieces attached or fused together. Under this construction, Petitioner argued that Umeda’s two-part pump casing (molded stator and attached cover) already met the "monolithic body" limitation. To the extent an explicit attachment method was required, Stephan taught a pump with a housing made of two injection-molded thermoplastic halves that are permanently attached by welding.
- Motivation to Combine: A POSITA would combine Umeda's two-part housing design with Stephan's teaching on welding for the simple and predictable purpose of creating a sealed, unitary casing. Welding was a known and limited option for permanently joining two plastic components, and its application here would be a straightforward design choice to improve a similar device in a known way.
- Expectation of Success: The proposed modification simply applied a known technique (welding plastic parts) to achieve a predictable result (a sealed housing), giving a POSITA a high expectation of success.
Ground 3: Claims 1–3 and 14–15 are obvious over Bramm in view of Watterson.
- Prior Art Relied Upon: Bramm (Patent 4,944,748) and Watterson (Patent 6,227,797).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Bramm, an electromagnetic blood pump, taught a monolithic plastic housing that encapsulates stator coils and includes an integral, non-linear fluid pathway with inlets and outlets, thus meeting most claim limitations. However, Bramm did not explicitly teach that its plastic housing was made of an injection-molded thermoplastic. Watterson was introduced to supply this teaching, as it described an electromagnetic pump with housing components made by injection molding from a non-conducting thermoplastic (Lexan polycarbonate).
- Motivation to Combine: A POSITA would be motivated to modify Bramm's pump to use the specific materials and manufacturing methods taught by Watterson. Watterson identified injection-molded polycarbonate as a preferred embodiment, and a POSITA would recognize that such a thermoplastic is well-suited for pump applications due to its high heat conductivity and the efficiency of the injection molding process.
- Expectation of Success: A POSITA would have a reasonable expectation of successfully implementing Bramm's pump using the thermoplastic and injection molding techniques from Watterson, as these were common, well-known manufacturing choices for such devices.
4. Key Claim Construction Positions
- "Monolithic body": Petitioner argued this term is central to the dispute and should be construed as "a body formed as a single piece." This construction is based on the patent's express definition and its distinction from prior art devices formed from multiple joined parts. Petitioner contrasted this with the Patent Owner's apparent position in co-pending litigation that "monolithic" can encompass multiple pieces that are "fused" together. Petitioner's primary invalidity ground (Ground 1) relied on the "single piece" construction, while Ground 2 was presented as an alternative to address the broader "fused pieces" construction.
5. Relief Requested
- Petitioner requested institution of an inter partes review and cancellation of claims 1–3, 7, and 14–15 of the ’509 patent as unpatentable.
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