PTAB

IPR2019-00017

Toyota Motor Corp v. General Electric Co

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Energy Storage and Management System
  • Brief Description: The ’668 patent is directed to energy storage and management systems (ESMS) for electric or hybrid vehicles. The technology aims to optimize recharge time for multiple energy storage devices by obtaining sensor feedback from the devices and comparing that feedback to their operating limits to control the charging scheme.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 10 are obvious over Mitsutani

  • Prior Art Relied Upon: Mitsutani (Application # 2011/0101915).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mitsutani teaches an energy management system for a hybrid vehicle that discloses nearly every feature of independent claims 1 and 10. This includes a plurality of energy ports, DC electrical conversion devices (converters 12-1 and 12-2), switching devices (relays 11-1 to 11-3), and a controller that receives sensor feedback from both energy storage devices and charging devices to control charging. The primary alleged difference is that Mitsutani discloses a distributed control system (multiple Electronic Control Units or ECUs), whereas the claims recite "a controller."
    • Motivation to Combine: Petitioner contended that even if "a controller" is narrowly construed to mean a single device, it would have been obvious to modify Mitsutani’s distributed system into a single-device controller. A POSITA would consolidate the functionality of Mitsutani's multiple ECUs into a single chip to improve reliability, reduce system complexity and cost, and simplify diagnostics and servicing. The ’668 patent itself notes that "fewer components improve[s] reliability."
    • Expectation of Success: A POSITA would have had a high expectation of success, as consolidating control logic onto a single chip was a well-known design choice in the art, representing a predictable variation.

Ground 2: Claim 2 is obvious over Mitsutani in view of Robinson

  • Prior Art Relied Upon: Mitsutani (Application # 2011/0101915) and Robinson (Application # 2011/0006603).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses dependent claim 2, which adds the limitation that the ESMS comprises a "third buck-boost module." Mitsutani explicitly discloses two such modules (converters 12-1 and 12-2). Robinson discloses a portable power manager with multiple power converters, including buck-boost converters, to flexibly charge various devices.
    • Motivation to Combine: Petitioner argued that a POSITA would be motivated to add a third buck-boost converter from Robinson to Mitsutani’s system to increase flexibility and efficiency. In Mitsutani, a single converter (12-2) is shared between two power storage devices (10-2 and 10-3), preventing their simultaneous charging. Adding a third converter, as taught by Robinson, would provide an independent path for each device, allowing for simultaneous charging and greater total power-handling capability.
    • Expectation of Success: This modification involved duplicating existing functionality (adding another known converter module), which would have been a straightforward modification for a POSITA with a reasonable expectation of success.

Ground 3: Claims 3-9 and 11-15 are obvious over Mitsutani and Robinson in view of Gale

  • Prior Art Relied Upon: Mitsutani (Application # 2011/0101915), Robinson (’603 application), and Gale (Application # 2012/0280646).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses dependent claims reciting specific features such as high-voltage and low-voltage storage devices, comparing sensor feedback to operating limits, and determining a power split factor. Gale explicitly teaches vehicle systems with separate high-voltage loads (e.g., traction battery) and low-voltage loads (e.g., auxiliary battery). Robinson teaches a controller that obtains operating limits (e.g., operating voltage, charging current) for connected devices and compares sensor feedback to those limits to manage power distribution.
    • Motivation to Combine: A POSITA would combine these teachings for known benefits. Incorporating Gale’s high/low voltage architecture into the Mitsutani/Robinson system was a common practice in hybrid vehicles to optimize cost and efficiency. Implementing Robinson’s control logic—obtaining device operating limits and allocating charging power accordingly—was a known method for safely and efficiently charging multiple, disparate devices. The combination would result in an advanced, flexible charging system that leverages the strengths of each reference.
    • Expectation of Success: Combining these known elements—a multi-converter architecture (Mitsutani/Robinson), a high/low voltage battery configuration (Gale), and intelligent power allocation based on device limits (Robinson)—was a predictable integration of established automotive and power management principles.

4. Key Claim Construction Positions

  • "coupleable": Petitioner proposed construing "coupleable" to mean "capable of being or configured to be coupled." This position was based on the express definition the patent owner provided to the Examiner during the original prosecution to overcome an indefiniteness rejection. Petitioner adopted this definition for the purposes of the proceeding.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that its grounds are not cumulative of art previously considered by the USPTO. It asserted that the primary references, Mitsutani and Robinson, were not before the Examiner during the prosecution of the ’668 patent. Furthermore, while a different reference by the same inventor (Gale) was previously cited, the specific Gale application relied upon in this petition was not before the Examiner.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-15 of the ’668 patent as unpatentable.