PTAB

IPR2019-00015

Toyota Motor Corporation v. GE Hybrid Technologies, LLC

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1. Case Identification

2. Patent Overview

  • Title: Starting Method for Hybrid Electric Vehicle
  • Brief Description: The ’052 patent discloses a method and apparatus for starting a hybrid electric vehicle in low-temperature conditions. The system determines if the battery temperature is below a threshold, uses an integrated starter generator (ISG) to start the internal combustion engine, and then executes a heating process to warm the battery with a dedicated battery heater.

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) and Sugimoto (U.S. Patent Application Publication No. 2010/0219794).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fassnacht taught the core method of operating a hybrid vehicle by starting its engine and then heating the battery if its temperature was below a predefined minimum (e.g., 0°C) to prevent degradation. Petitioner contended that Sugimoto, which addresses the same field, provided the conventional implementation details for Fassnacht’s system. Specifically, Sugimoto was cited for teaching a specific ISG (inverter and motor generator) that converts DC battery power to AC power to start the engine, as well as a relay switch (SR1) and control unit for managing power flow from the battery.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references because they are directed to the same technical problem of managing battery performance in hybrid vehicles. A POSITA would look to Sugimoto to supply the specific, conventional electrical components (switches, inverters, control logic) needed to implement the broader battery heating strategy described in Fassnacht.
    • Expectation of Success: The combination involved applying known components from the Sugimoto ’794 application for their intended purposes within the known system of Fassnacht. Petitioner argued this would lead to predictable results, as it was a combination of known elements performing their known functions.

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 (U.S. Patent Application Publication No. 2006/0016793).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this three-way combination taught the limitations of the dependent method claims (2-4, 6-16) and the apparatus claims (5-16). The Fassnacht/Sugimoto combination provided the base hybrid vehicle system with its starter-generator and primary battery switch. Zhu was argued to add a modular battery heater controlled by its own dedicated switch (switch 116). This combination allegedly taught the detailed control steps of the dependent claims, such as turning off the main battery switch (Sugimoto's SR1) while heating, using the ISG's rectifier sub-mode to generate DC power for the heater, and controlling the heater with a second, separate switch (Zhu's 116).
    • Motivation to Combine: A POSITA, having combined Fassnacht and Sugimoto, would be motivated to incorporate Zhu’s modular and independently switched heater. This modification would provide the known advantages of increased design flexibility and more precise, efficient control over the battery heating process, which were recognized design goals in the art.
    • Expectation of Success: Petitioner asserted that adding Zhu’s conventional heater and switch module to the hybrid vehicle architecture of Fassnacht/Sugimoto was a simple integration of known elements. A POSITA would expect this combination to function as designed and yield predictable improvements in the control of battery thermal management.

4. Key Claim Construction Positions

  • "starter mode": Petitioner proposed this term means a mode in which the ISG starts the internal combustion engine.
  • "generator mode": Petitioner proposed this term means a mode in which the ISG is driven by the engine to supply electric power.
  • "rectifier sub-mode": Petitioner construed this as a sub-mode of the "generator mode" that converts AC power from the ISG to DC power. This construction was critical to the argument that the ISG could power the DC-operated battery heater as claimed.
  • "a relatively low temperature": Petitioner argued this phrase, which is not explicitly defined, should be construed based on the patent's only example ("below zero-degree Celsius") and the teachings of the prior art. This construction was used to align the patent's scope with the disclosures in Fassnacht.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the proposed grounds should not be denied as cumulative under §325(d). The basis for this argument was that the primary references relied upon—Fassnacht, Sugimoto, and Zhu—were never considered by the Examiner during the original prosecution of the ’052 patent. Therefore, the invalidity arguments presented in the petition were not the same or substantially the same as those previously considered by the USPTO.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-16 of Patent 8,409,052 as unpatentable under 35 U.S.C. §103.