PTAB

IPR2026-00250

Toyota Motor Corp v. Bunker Hill Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Propulsion System for Electric or Hybrid Electric Vehicles
  • Brief Description: The ’648 patent describes a propulsion system for hybrid or electric vehicles. The system uses one or more energy storage devices to power multiple electric motors operating on independent channels, which can be combined with an internal combustion engine to split power output and improve overall system efficiency.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 4, 5, 7, 8, 16, and 18-20 by Conlon

  • Prior Art Relied Upon: Conlon (Application # 2009/0176610).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Conlon, which was not considered during prosecution, discloses every element of the challenged claims. Conlon describes a hybrid electric vehicle powertrain with an energy storage device (ESD 86), a first motor/generator (M/G A), and a second motor/generator (M/G B). It further teaches a transmission device (first planetary gear set 20) coupled to the first motor, and a separate gear assembly (second planetary gear set 22) coupled between the second motor and the transmission, allowing the second motor’s output to bypass the transmission device. Conlon also discloses an internal combustion engine and a control system that operates the powertrain in multiple modes (e.g., input-split, compound-split, electric-only) that correspond to the functions recited in the ’648 patent’s control system limitations.

Ground 2: Anticipation of Claims 1, 2, 4-10, and 12-20 by Ortmann

  • Prior Art Relied Upon: Ortmann (Application # 2013/0012347).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Ortmann, also not of record, anticipates the claims by teaching a multi-mode powersplit powertrain. Ortmann discloses an energy storage system (battery 40), a first motor-generator (22), and a second motor-generator (16). The system includes a transmission device comprising a planetary gearset (14) coupled to the first motor. Petitioner mapped Ortmann’s layshaft gearing (18) to the claimed "gear assembly," arguing it is coupled between the second motor (16) and the transmission device (14) such that the second motor’s mechanical power bypasses the transmission to drive the wheels. Ortmann's disclosure of multiple operating modes (e.g., one/two motor electric drive, series, powersplit) was argued to meet the limitations of the claimed control system.

Ground 3: Obviousness of Claims 2, 3, 6, 9-15, and 17 over Conlon in View of Reynolds

  • Prior Art Relied Upon: Conlon (Application # 2009/0176610) and Reynolds (Application # 2014/0100726).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring additional power electronics not explicitly disclosed in Conlon, such as a DC/DC converter (claims 2, 10, 17) and separate inverters for each motor (claim 6). Petitioner asserted that Conlon provides the base powertrain architecture, while Reynolds teaches the use of a DC/DC converter and separate inverters for the motor and generator in a hybrid vehicle.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings because both references address power management in hybrid vehicles. A POSITA would have recognized the drawback of Conlon’s single inverter system, which cannot optimally support simultaneous motor and generator functions as required in certain operating modes. A POSITA would therefore incorporate Reynolds' teaching of separate inverters and a DC/DC converter to create a more stable, reliable, and efficient system, which was a well-known design choice.
    • Expectation of Success: The integration of standard power electronic components like DC/DC converters and inverters into a known powertrain architecture would have yielded predictable results.

  • Additional Grounds: Petitioner asserted an alternative obviousness challenge (Ground 2) over Conlon alone, arguing a POSITA would have found it obvious to add a control system if Conlon were found not to inherently disclose it. Petitioner also asserted an obviousness challenge (Ground 5) to modify Ortmann by adding a second energy storage system to arrive at the subject matter of claims 3 and 11.

4. Key Claim Construction Positions

  • "output of the second traction/electric motor" (claims 1, 9, 16): Petitioner argued this term should be construed as the "mechanical output of the second traction/electric motor." This construction was asserted to clarify that the claim requires a bypass path for mechanical power to drive the vehicle, consistent with the patent's disclosure.
  • "transmission device" (claims 1, 9, 16): Petitioner argued this term should be understood to include clutches. This position was based on the ’648 patent's description of clutches as part of the transmission (EVT) and their necessity for connecting and disconnecting power flow to enable the various operating modes.

5. Relief Requested

  • Petitioner requests institution of IPR for claims 1-20 of the ’648 patent and cancellation of those claims as unpatentable.