PTAB

IPR2019-00015

Toyota Motor Corp v. Ge Hybrid Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Starting Method for Hybrid Electric Vehicle
  • Brief Description: The ’052 patent discloses a starting method and apparatus for a hybrid electric vehicle designed to operate in low temperatures. The technology involves detecting when the vehicle's battery is below a temperature threshold and, if so, executing a heating process using a battery heater to warm the battery to an operational temperature.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 5 are obvious over Fassnacht in view of Sugimoto

  • Prior Art Relied Upon: Fassnacht (WO 2009/019085), Sugimoto (Application # 2010/0219794).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fassnacht taught the core method of a hybrid vehicle starting process: detecting a battery temperature below a predefined minimum (e.g., 0°C), starting the internal combustion engine using an "electric machine" (an integrated starter generator, or ISG), and then executing a heating process for the battery while it is operated without load. However, Fassnacht lacked specific implementation details for the electrical components. Petitioner contended that Sugimoto supplied these details, disclosing a conventional hybrid vehicle architecture with specific components that a POSITA would use to implement Fassnacht’s method. This included a switch (relay SR1) to control power from the battery and an ISG (inverter 30 and motor generator MG1) that converts DC battery power to AC power to start the engine. Sugimoto also disclosed other conventional components like a traction motor, transmission, and control unit, mapping to the apparatus limitations of claim 5.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references because both are directed to operating hybrid vehicles and managing battery performance. Petitioner asserted a POSITA, seeking to implement the general heating strategy of Fassnacht, would naturally look to a reference like Sugimoto, which describes specific implementations of conventional electrical components, to arrive at a functional and predictable system. Using Sugimoto’s teachings was presented as a straightforward application of a known technique to improve a similar device.
    • Expectation of Success: A POSITA would have a high expectation of success because incorporating Sugimoto’s conventional starter generator and switch into Fassnacht’s system involved applying known technologies for their intended purpose to yield predictable results.

Ground 2: Claims 2-4 and 6-16 are obvious over Fassnacht in view of Sugimoto and Zhu

  • Prior Art Relied Upon: Fassnacht (WO 2009/019085), Sugimoto (Application # 2010/0219794), and Zhu (Application # 2006/0016793).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Fassnacht/Sugimoto combination to address the limitations of the dependent claims. Petitioner argued that Zhu taught specific thermal controls for a vehicle's electrical storage device, explicitly addressing performance degradation in low temperatures. Zhu disclosed a modular battery heater system controlled by a dedicated switch (switch 116). This teaching was used to meet limitations in the dependent claims requiring a second switch for the battery heater (claim 14), turning off the first switch while activating the heater (claim 2), and changing the ISG control mode to a "rectifier sub-mode" to power the heater (claim 2). Zhu’s teaching of ceasing heater operation above a certain temperature threshold was argued to render obvious the claim limitation of using a second temperature threshold to stop heating (claim 11).
    • Motivation to Combine: Petitioner argued that since Fassnacht, Sugimoto, and Zhu all address the same problem of battery performance in cold weather, a POSITA would have been motivated to integrate Zhu’s modular, switch-controlled heater into the Fassnacht/Sugimoto system. This would provide more precise control over the heating process, improve efficiency by only using the heater when needed, and allow for a modular design adaptable to different climates. Powering Zhu’s heater with the ISG from the primary combination would be a logical modification to avoid reliance on an external power source.
    • Expectation of Success: A POSITA would have reasonably expected success in this combination. Integrating a well-understood, switch-controlled resistive heater like that in Zhu into the conventional hybrid vehicle architecture established by Fassnacht and Sugimoto was a predictable design choice within the skill of a POSITA.

4. Key Claim Construction Positions

  • "starter mode": Petitioner proposed this term be construed as "a mode in which the integrated starter generator may start the internal combustion engine." This construction was based on the specification's description of the vehicle control unit switching the ISG inverter to the starter mode for this purpose.
  • "generator mode": Petitioner proposed this term be construed as "a mode in which the integrated starter generator may supply electric power to the vehicle." This was based on the specification explaining that in this mode, power is supplied from the ISG inverter.
  • "rectifier sub-mode": Petitioner proposed this term be construed as "a sub-mode of the generator mode that converts AC current to DC current." The specification describes switching to this mode to direct DC power outputted from the ISG.
  • "a relatively low temperature": Petitioner argued that based on the specification's only example of "a temperature below zero-degree Celsius," this term should be understood to be satisfied by at least a temperature of 0°C.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-16 of the ’052 patent as unpatentable under 35 U.S.C. §103.