PTAB

IPR2017-01539

Aisin Seiki Co., Ltd. v. Intellectual Ventures II LLC

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1. Case Identification

2. Patent Overview

  • Title: Fluid-Cooled Electromagnetic Field-Functioning Device
  • Brief Description: The ’509 patent discloses electromagnetic devices, such as motors and pumps, where components are substantially encapsulated in a monolithic body of a phase-change material like thermoplastic. This configuration is intended to protect the device's internal components while providing improved cooling via a fluid channel running through the monolithic body.

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, which describes an electromagnetic pump, teaches most elements of the challenged claims, including a fluid-cooled device with electrical conductors (coils) and a non-linear fluid pathway for cooling. However, Umeda discloses a two-part housing (a molded stator and a cover) made of an unspecified "resin." To address the "monolithic body of injection molded thermoplastic" limitation, Petitioner cited Neal. Neal taught the benefits of using a single, unitized (monolithic) body made of injection-molded thermoplastic to encapsulate motor components, thereby reducing part count, improving component alignment, and lowering manufacturing costs. Raible was cited as further evidence, disclosing a pump with a housing injection-molded as a single piece from a polymer like polycarbonate.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the pump design of Umeda with the manufacturing method and material taught by Neal and Raible. The motivation would be to achieve the predictable advantages described in Neal, such as reduced manufacturing costs and improved tolerances, by forming Umeda's two-part housing as a single, injection-molded thermoplastic component.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. The proposed modification involved applying a well-known manufacturing process (injection molding) with a preferred material (thermoplastic), as taught by Neal and Raible, to a known device type (Umeda's pump) to achieve predictable improvements.

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 (DE Application # 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" in co-pending litigation, where multiple attached pieces could be considered "monolithic." Petitioner argued that under this broad construction, Umeda's attached two-part housing (molded stator and cover) already met the limitation. However, if a more specific attachment method like "fusing" were required, Stephan taught welding two injection-molded thermoplastic housing halves together to form a permanent, sealed motor casing.
    • Motivation to Combine: A POSITA seeking to permanently join the two plastic housing components of Umeda's pump would be motivated to use a known, effective technique. Stephan provided an explicit teaching of welding such components to achieve a sealed, unitary casing, which is a limited and well-understood engineering choice for joining plastic parts.
    • Expectation of Success: Welding plastic components was a conventional and predictable technique. Applying Stephan's teaching of welding to join the housing parts of Umeda's pump would be a straightforward modification with 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 asserted that Bramm, which discloses an electromagnetic blood pump, taught a fluid-cooled device with a monolithic plastic housing encapsulating the stator coils and featuring a non-linear fluid pathway. However, Bramm did not explicitly state that the plastic was a thermoplastic or that the housing was formed by injection molding. Watterson was cited to supply these missing details. Watterson taught a similar electromagnetic pump whose housing was made by injection molding from a non-conducting thermoplastic material (Lexan polycarbonate), with windings encapsulated during the molding process.
    • Motivation to Combine: A POSITA implementing Bramm's design would be motivated to use the common and advantageous manufacturing process taught by Watterson. Watterson’s disclosure of using injection-molded thermoplastic for a similar pump provided a clear reason to apply the same material and method to construct Bramm's pump housing.
    • Expectation of Success: A POSITA would have reasonably expected success in modifying Bramm's design with Watterson's teachings. The modification involved using a standard manufacturing process (injection molding) with a commercially available and suitable material (thermoplastic) for its known purpose of creating an encapsulated pump housing.

4. Key Claim Construction Positions

  • "Monolithic body" (claims 1, 3, 14): Petitioner argued that the broadest reasonable interpretation of this term, based on the ’509 patent’s specification, is "a body formed as a single piece." This construction was central to the petition, as the specification explicitly distinguished a "single unitized body" from prior art devices using "multiple parts" joined together. Petitioner contended this construction was critical because the Patent Owner had asserted in co-pending litigation that "monolithic" could encompass multiple pieces that are "fused" together, a position Petitioner argued was contrary to the patent's own disclosure.

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.