Autel Robotics USA LLC

Patent Trials and Appeals Board

Sep 21, 2020

IPR2019-00846 (P.T.A.B. Sep. 21, 2020)

Trials@uspto.gov Paper 33
571-272-7822 Date: September 21, 2020

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

SZ DJI TECHNOLOGY CO., LTD.,
Petitioner,

v.

AUTEL ROBOTICS USA LLC,
Patent Owner.
____________

IPR2019-00846
Patent 9,260,184 B2
____________

Before ERICA A. FRANKLIN, JENNIFER MEYER CHAGNON, and
AVELYN M. ROSS, Administrative Patent Judges.

CHAGNON, Administrative Patent Judge.

JUDGMENT
Final Written Decision
Granting Patent Owner’s Non-Contingent Motion to Amend
35 U.S.C. § 318(a)

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I. INTRODUCTION
We have jurisdiction to hear this inter partes review under 35 U.S.C.
§ 6. This Final Written Decision is issued pursuant to 35 U.S.C. § 318(a)
and 37 C.F.R. § 42.73. For the reasons discussed herein, Patent Owner’s
Revised Motion to Amend (Paper 17) is granted.
A. Procedural History
SZ DJI Technology Co., Ltd. (“Petitioner”)1 filed a Petition for inter
partes review of claims 3 and 4 of U.S. Patent No. 9,260,184 B2 (Ex. 1001,
“the ’184 patent”). Paper 2 (“Pet.”). Petitioner provided a Declaration of
Dr. Alfred Ducharme (Ex. 1003) to support its positions. Autel Robotics
USA LLC (“Patent Owner”) did not file a Preliminary Response. Pursuant
to 35 U.S.C. § 314(a), on September 23, 2019, we instituted inter partes
review to determine whether claims 3 and 4 of the ’184 patent would have
been obvious under 35 U.S.C. § 103 in view of Sasaki2 and Sokn.3 See
Paper 6 (“Inst. Dec.”).
Subsequent to institution, Patent Owner did not file a Patent Owner
Response, but filed a non-contingent Motion to Amend (Paper 10), along
with a Declaration of Charles F. Reinholtz, Ph.D. (Ex. 2001) to support its
positions. Petitioner filed an Opposition (Paper 15) to Patent Owner’s
Motion to Amend, along with a Second Declaration of Dr. Ducharme
(Ex. 1028). Pursuant to Patent Owner’s request (Paper 10, 2), we provided

1 Petitioner identifies DJI Technology Inc.; DJI Europe B.V.; iFlight
Technology Company Limited; DJI Japan K.K.; and DJI Research LLC as
additional real parties-in-interest to this proceeding. Pet. 1.
2 JP Appl. Publ’n No. H06-17511, published January 14, 1991 (Ex. 1005;
Ex. 1006 (certified translation)). Citations to Sasaki are to the translation.
3 U.S. Patent No. 5,133,617, issued July 28, 1992 (Ex. 1007).
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Preliminary Guidance on Patent Owner’s Motion to Amend. Paper 16. In
response, Patent Owner filed a non-contingent Revised Motion to Amend
(Paper 17, “Revised Mot. Amend”), along with a Second Declaration of
Dr. Reinholtz (Ex. 2007). Petitioner filed an Opposition (Paper 21, “Opp.”)
to Patent Owner’s Revised Motion to Amend, along with a Third
Declaration of Dr. Ducharme (Ex. 1030). Patent Owner filed a Reply
(Paper 25, “Reply”), along with a Third Declaration of Dr. Reinholtz
(Ex. 2016), and Petitioner filed a Sur-reply (Paper 29, “Sur-reply”).
An oral hearing was held on August 13, 2020. A transcript of the
hearing is included in the record. Paper 32 (“Tr.”).
B. Related Proceedings
The parties identify SZ DJI Tech. Co. v. Autel Robotics USA LLC,
Case No. 16-706-LPS-CJB (D. Del.); Certain Unmanned Aerial Vehicles
and Components Thereof, Inv. No. 337-TA-133 (USITC, instituted Sept. 26,
2018) (“the related ITC proceeding”); and IPR2019-003434 as related
matters. Pet. 2; Paper 4, 2. In the 343 IPR, we issued a Final Written
Decision finding claims 1, 2, 5–9, and 11 of the ’184 patent unpatentable,
based on Microdrones,5 alone or in combination with various other
references not discussed herein. See SZ DJI Tech. Co. v. Autel Robotics
USA LLC, IPR2019-00343, Paper 40 (PTAB May 21, 2020) (“343 FWD”)
(submitted in this proceeding as Ex. 1031).

4 We refer to IPR2019-00343 IPR as “the 343 IPR” herein, and any citations
to documents in the record of the 343 IPR include a “343” prefix.
5 Microdrones User Manual for md4-200 (Version 2.2) (May 2009)
(343 Ex. 1004; submitted in this proceeding as Ex. 1016).
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C. The ’184 Patent
The ’184 patent is titled “Compact Unmanned Rotary Aircraft,” was
filed on May 14, 2014,6 and issued February 16, 2016. Ex. 1001, at
codes (22), (45), (54).
Figure 1 of the ’184 patent is reproduced below.

Figure 1, above, illustrates rotary wing apparatus 1. Id. at 2:31–34. Rotary
wing apparatus 1 includes body 3 and a plurality of arms 5, each including
rotor assembly 7 attached to an outside end thereof. Id. at 3:15–18. Each
rotor assembly 7 includes “rotor blade 9 releasably attached to a driveshaft
by a lock mechanism 11, and a drive . . . rotating the driveshaft.” Id. at
3:18–21.
As described in the Background section of the ’184 patent, in rotary
wing aircraft having “a number of arms extending laterally from the aircraft
body, with a rotor assembly on the end of each arm,” torque on the aircraft
body, which would cause it to spin undesirably, should be avoided. Id. at

6 The ’184 patent claims priority to Canadian application No. 2815885, filed
on May 15, 2013. Ex. 1001, at code (30). Because the application leading
to the ’184 patent was filed after March 16, 2013, patentability is governed
by the Leahy-Smith America Invents Act (“AIA”), Pub L. No. 112-29,
125 Stat. 284 (2011), version of 35 U.S.C. §§ 102 and 103.
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1:15–23. One way in which this torque can be avoided is by having the
rotors rotate in opposite directions. See id. at 1:24–40. Further, “[t]o make
the aircraft more compact for storage and transport the rotors can be
removed and the arms folded into a side by side orientation.” Id. at 1:43–46.
In the embodiment depicted in Figure 1 of the ’184 patent, rotor
blades 9A, 9B rotate in a clockwise direction and rotor blades 9C, 9D rotate
in a counterclockwise direction. Id. at 3:31–37. As described in the ’184
patent, the “rotor blades can be easily detached for transport of storage, and
cannot be placed on driveshafts rotating the wrong direction.” Id. at 2:16–
18. This feature is important because, “in order for the apparatus 1 to
operate properly, the rotor blades 9 must be mounted to drive shafts that are
rotating in the correct direction.” Id. at 3:45–47. In the disclosed
embodiments, “clockwise rotor blades 9A, 9B are engageable only with the
clockwise lock mechanisms 11AB and cannot be engaged in the
counterclockwise lock mechanisms 11CD” and “counterclockwise rotor
blades 9C, 9D are engageable only with the counterclockwise lock
mechanisms 11CD and cannot be engaged in the clockwise lock
mechanisms 11AB.” Id. at 3:47–54.
Figures 4 and 5 of the ’184 patent, as shaded and annotated by
Petitioner (Pet. 8, 9), are reproduced below.

Figure 4 Figure 5
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Annotated Figures 4 and 5, above, illustrate schematic perspective views of
a clockwise lock mechanism in a “ready for engagement” position and an
“engaged and locked” position, respectively. Ex. 1001, 2:41–47. Clockwise
lock mechanism comprises shaft lock portion 15A (labeled in Fig. 9, shaded
yellow above) attached to the corresponding clockwise rotating driveshaft 13
and blade lock portion 17A (labeled in Fig. 9, shaded dark green above)
attached to clockwise rotor blade 9A, 9B (shaded light green above). Id. at
3:55–58. Shaft lock portion (yellow) has recess 21, into which blade lock
portion (dark green) is dropped. Id. at 3:66–4:3. The rotor blade (light
green) is then rotated in direction R (opposite the direction of rotation of the
rotor blade during operation of the rotary wing aircraft, i.e., here,
counterclockwise), “such that the blade 9A slides into slots 23 on each side
of the shaft lock portion 15A under the arrows, and lugs 25A on the blade
lock portion 17A engage notches 27A defined by the shaft lock portion.” Id.
at 4:4–16. The counterclockwise lock mechanisms operate in a similar
manner, but “with an opposite spin direction.” See id. at 3:58–62, 4:16–26,
Figs. 6, 7. This configuration prevents clockwise rotor blades 9A, 9B from
being installed on the shaft lock portion 15C of a counterclockwise lock
mechanism and, similarly, prevents counterclockwise rotor blades 9C, 9D
from being installed on the shaft lock portion 15A of a clockwise lock
mechanism. See id. at 4:27–35, Fig. 8.
D. Proposed Substitute Claims
In its Revised Motion to Amend, Patent Owner proposes to add
substitute claims 12 and 13, which depend directly or indirectly from
claim 1. Claim 1 of the ’184 patent and the proposed substitute claims are
reproduced below. The proposed substitute claims include bracketed,
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italicized subject matter indicative of subject matter deleted from challenged
claims 3 and 4 and underlined subject matter indicative of subject matter
added to challenged claims 12 and 13.
1. A rotary wing aircraft apparatus comprising:
a body;
a plurality of arms extending laterally from the body, and
a rotor assembly attached to an outside end of each arm;
each rotor assembly comprising a rotor blade releasably
attached to a driveshaft by a lock mechanism, and a drive
rotating the driveshaft;
wherein a first driveshaft rotates in a clockwise direction
and a second driveshaft rotates in a counterclockwise direction;
wherein a clockwise rotor blade is releasably attached to
the first driveshaft by engagement in a clockwise lock
mechanism and generates a vertical lift force when rotated in
the clockwise direction, and a counterclockwise rotor blade is
releasably attached to the second driveshaft by engagement in a
counterclockwise lock mechanism and generates a vertical lift
force when rotated in the counterclockwise direction;
wherein the clockwise rotor blade is engageable only
with the clockwise lock mechanism and cannot be engaged in
the counterclockwise lock mechanism, and the
counterclockwise rotor blade is engageable only with the
counterclockwise lock mechanism and cannot be engaged in the
clockwise lock mechanism; and
wherein the clockwise lock mechanism comprises a shaft
lock portion attached to the first driveshaft and a blade lock
portion attached to the clockwise rotor blade, the shaft lock
portion defining notches configured to engage corresponding
lugs on the blade lock portion.
Ex. 1001, 5:35–6:9.
12. The apparatus of claim 1 wherein the blade lock
portion of the clockwise lock mechanism is configured to
engage with the shaft lock portion of the clockwise lock
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mechanism by partial is rotated counterclockwise rotation with
respect to the shaft lock portion thereof of the clockwise lock
mechanism to releasably attach the clockwise rotor blade to the
first driveshaft.
Revised Mot. Amend 27.
13. The apparatus of claim 12 wherein the
counterclockwise lock mechanism comprises a shaft lock
portion attached to the second driveshaft and a blade lock
portion attached to the counterclockwise rotor blade, and
wherein the blade lock portion of the counterclockwise lock
mechanism is configured to engage with the shaft lock portion
of the counterclockwise lock mechanism by partial is rotated
clockwise rotation with respect to the shaft lock portion of the
counterclockwise lock mechanism thereof to releasably attach
the counterclockwise rotor blade to the second driveshaft.
Id.
E. Asserted Grounds of Unpatentability
Petitioner challenges the patentability of proposed substitute claims 12
and 13 on the following grounds:
Claims Challenged 35 U.S.C. § References/Basis
12, 13 103 Sasaki, Sokn
12, 13 103 Sasaki, Philistine7
12, 13 103 Sasaki, Obrist8
12, 13 103 Sasaki, EP0679
See Opp. 1–24; Tr. 9:8–11.

7 U.S. Patent No. 6,929,226 B1, issued August. 16, 2005 (Ex. 1026).
8 U.S. Patent No. 2,470,517, issued May 17, 1949 (Ex. 1017).
9 European Patent Appl. No. EP 0 921 067 A2, published June 9, 1999
(Ex. 1018).
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II. ANALYSIS
A. Principles of Law
In an inter partes review, amended claims are not added to a patent as
of right, but rather must be proposed as a part of a motion to amend.
35 U.S.C. § 316(d). The Board must assess the patentability of proposed
substitute claims “without placing the burden of persuasion on the patent
owner.” Aqua Prods., Inc. v. Matal, 872 F.3d 1290, 1328 (Fed. Cir. 2017)
(en banc); see also Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-001129,
Paper 15 at 3–4 (PTAB Feb. 25, 2019) (precedential). Subsequent to the
issuance of Aqua Products, the Federal Circuit issued a decision in Bosch
Automotive Service Solutions, LLC v. Matal, 878 F.3d 1027 (Fed. Cir. 2017)
(“Bosch”), as well as a follow-up Order amending that decision on
rehearing. See Bosch Auto. Serv. Sols., LLC v. Iancu, No. 2015-1928 (Fed.
Cir. Mar. 15, 2018) (Order on Petition for Panel Rehearing).
In accordance with Aqua Products, Bosch, and Lectrosonics, a patent
owner does not bear the burden of persuasion to demonstrate the
patentability of the substitute claims presented in the motion to amend.
Rather, ordinarily, “the petitioner bears the burden of proving that the
proposed amended claims are unpatentable by a preponderance of the
evidence.” Bosch, 878 F.3d at 1040 (as amended on rehearing); see
Lectrosonics, Paper 15 at 3–4. In determining whether a petitioner has
proven unpatentability of the substitute claims, the Board focuses on
“arguments and theories raised by the petitioner in its petition or opposition
to the motion to amend.” Nike, Inc. v. Adidas AG, 955 F.3d 45, 51 (Fed. Cir.
2020).
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Notwithstanding the foregoing, Patent Owner’s proposed substitute
claims must meet the statutory requirements of 35 U.S.C. § 316(d) and the
procedural requirements of 37 C.F.R. § 42.121. Lectrosonics, Paper 15 at
4–8. Accordingly, Patent Owner must demonstrate: (1) the amendment
proposes a reasonable number of substitute claims; (2) the proposed claims
are supported in the original disclosure (and any earlier filed disclosure for
which the benefit of filing date is sought); (3) the amendment responds to a
ground of unpatentability involved in the trial; and (4) the amendment does
not seek to enlarge the scope of the claims of the patent or introduce new
subject matter. See 35 U.S.C. § 316(d); 37 C.F.R. § 42.121.
As set forth in 35 U.S.C. § 103,
[a] patent for a claimed invention may not be obtained . . . if the
differences between the claimed invention and the prior art are
such that the claimed invention as a whole would have been
obvious before the effective filing date of the claimed invention
to a person having ordinary skill in the art to which the claimed
invention pertains.
The question of obviousness is resolved on the basis of underlying factual
determinations including: (1) the scope and content of the prior art; (2) any
differences between the claimed subject matter and the prior art; (3) the level
of ordinary skill in the art; and (4) objective evidence of nonobviousness.10
Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966). Consideration of the
Graham factors “helps inform the ultimate obviousness determination.”

10 Patent Owner presents evidence and arguments related to long-felt need.
See, e.g., Revised Mot. Amend 23. Because we are not persuaded that
Petitioner has shown that a person of ordinary skill in the art would have
combined Sasaki with any of the other four asserted references to arrive at
the invention recited in the proposed substitute claims (see infra
Section II.E), we do not discuss Patent Owner’s objective evidence further in
this decision.
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Apple Inc. v. Samsung Elecs. Co., 839 F.3d 1034, 1048 (Fed. Cir. 2016)
(en banc).
A patent claim “is not proved obvious merely by demonstrating that
each of its elements was, independently, known in the prior art.” KSR Int’l
Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). An obviousness
determination requires finding “both ‘that a skilled artisan would have been
motivated to combine the teachings of the prior art references to achieve the
claimed invention, and that the skilled artisan would have had a reasonable
expectation of success in doing so.’” Intelligent Bio-Sys., Inc. v. Illumina
Cambridge Ltd., 821 F.3d 1359, 1367–68 (Fed. Cir. 2016) (citation omitted);
see KSR, 550 U.S. at 418 (For an obviousness analysis, “it can be important
to identify a reason that would have prompted a person of ordinary skill in
the relevant field to combine the elements in the way the claimed new
invention does.”). A motivation to combine the teachings of two references
can be “found explicitly or implicitly in market forces; design incentives; the
‘interrelated teachings of multiple patents’; ‘any need or problem known in
the field of endeavor at the time of invention and addressed by the patent’;
and the background knowledge, creativity, and common sense of the person
of ordinary skill.” Plantronics, Inc. v. Aliph, Inc., 724 F.3d 1343, 1354 (Fed.
Cir. 2013) (citation omitted).
However, Petitioner cannot satisfy its burden of proving obviousness
by employing “mere conclusory statements,” but “must instead articulate
specific reasoning, based on evidence of record” to support an obviousness
determination. In re Magnum Oil Tools Int’l, Ltd., 829 F.3d 1364, 1380–81
(Fed. Cir. 2016). The “factual inquiry” into the reasons for “combin[ing]
references must be thorough and searching, and the need for specificity
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pervades.” In re NuVasive, 842 F.3d 1376, 1381–82 (Fed. 2016) (internal
quotation marks and citations omitted). A determination of obviousness
cannot be reached where the record lacks “explanation as to how or why the
references would be combined to produce the claimed invention.”
TriVascular, Inc. v. Samuels, 812 F.3d 1056, 1066 (Fed. Cir. 2016); see
NuVasive, 842 F.3d at 1382–85; Magnum Oil, 829 F.3d at 1380–81. Thus,
to prevail Petitioner must explain how the prior art would have rendered the
challenged claim unpatentable.
We analyze the asserted grounds of unpatentability in accordance with
these principles.
B. Level of Ordinary Skill in the Art
We review the grounds of unpatentability in view of the
understanding of a person of ordinary skill in the art at the time of the
invention. Graham, 383 U.S. at 17. Dr. Ducharme testifies that a person of
ordinary skill in the art “would have had at least an undergraduate degree in
mechanical engineering, or equivalent education, training, or experience,
with at least two years of experience with [Unmanned Aeriel Vehicles
(UAV)].” Ex. 1003 ¶ 72. Dr. Reinholtz testifies that a person of ordinary
skill in the art “would have had a bachelor’s degree in mechanical
engineering and at least two years of experience designing mechanisms and
mechanical structures of the type used in releasable couplings and locking
devices. Additional education could substitute for professional experience
and significant work experience could substitute for formal education.”
Ex. 2001 ¶ 28.
Dr. Reinholtz acknowledges that he does not view “Dr. Ducharme’s
proposed definition as substantially different from [his own].” Ex. 2001
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¶ 30. We agree and note that our consideration of the issues presented does
not turn on which proposed definition is applied. Dr. Ducharme and
Dr. Reinholtz also acknowledge that their respective testimony would
remain the same regardless of which of these definitions of a person of
ordinary skill in the art is applied. See Ex. 1028 ¶ 23; Ex. 2001 ¶ 30. In any
event, for purposes of this Final Written Decision, we adopt Petitioner’s
description of a person of ordinary skill in the art, while maintaining our
prior determination (Inst. Dec. 10) that the prior art reflects the appropriate
level of skill at the time of the claimed invention. See Okajima v. Bourdeau,
261 F.3d 1350, 1355 (Fed. Cir. 2001).
C. Claim Construction
In this inter partes review proceeding, claim terms
shall be construed using the same claim construction standard
that would be used to construe the claim in a civil action under
35 U.S.C. [§] 282(b), including construing the claim in
accordance with the ordinary and customary meaning of such
claim as understood by one of ordinary skill in the art and the
prosecution history pertaining to the patent.
37 C.F.R. § 42.100(b) (2019). Further, “[a]ny prior claim construction
determination concerning a term of the claim in a civil action, or a
proceeding before the International Trade Commission, that is timely made
of record in the inter partes review proceeding will be considered.”11 Id.

11 A claim construction order from the related ITC proceeding is of record in
this proceeding. Ex. 2006. Also of record is an excerpt from the public
version of the ITC’s Initial Determination, dated March 2, 2020. Ex. 2011.
We have reviewed and considered both of these documents for purposes of
claim construction in this proceeding.
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Under the standard set forth in Phillips v. AWH Corp., 415 F.3d 1303,
1312–19 (Fed. Cir. 2005) (en banc), claim terms are given their ordinary and
customary meaning, as would have been understood by a person of ordinary
skill in the art at the time of the invention, in light of the language of the
claims, the specification, and the prosecution history of record. See Thorner
v. Sony Comput. Entm’t Am. LLC, 669 F.3d 1362, 1365–66 (Fed. Cir. 2012).
We construe terms only to the extent necessary to resolve the controversy.
See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d
1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs., Inc. v. Am. Sci. & Eng’g,
Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).
Petitioner proposes constructions for several claim terms, including
“lugs” and “notches”; “lock mechanism” / “clockwise lock mechanism” /
“counterclockwise lock mechanism”; and “drive.” Pet. 21–25. In our
Institution Decision, we construed only the claim terms “lugs” and
“notches.” Inst. Dec. 10–13. In its Revised Motion to Amend, Patent
Owner proposes construction for the Engagement Limitation.12 Revised
Mot. Amend 9–11. In its Opposition, Petitioner argues that Patent Owner is
collaterally estopped from its claim construction position with respect to the
Engagement Limitation, based on our construction of this limitation in the
Final Written Decision in the 343 IPR. Opp. 9–10. We discuss “lugs” and
“notches” and the Engagement Limitation below.

12 Patent Owner uses the term “Engagement Limitation” to reference the
following recitation in claim 1: “the clockwise rotor blade is engageable
only with the clockwise lock mechanism and cannot be engaged in the
counterclockwise lock mechanism, and the counterclockwise rotor blade is
engageable only with the counterclockwise lock mechanism and cannot be
engaged in the clockwise lock mechanism.”
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1. “lugs” and “notches”
Claim 1 recites, inter alia, “the shaft lock portion defining notches
configured to engage corresponding lugs on the blade lock portion.”
Ex. 1001, 6:7–9 (emphasis Petitioner’s (Pet. 23)). In the Institution
Decision, we construed “lugs” and “notches,” in accordance with
Petitioner’s proposal, as “projections” and “indentations,” respectively. See
Inst. Dec. 12; Pet. 24; Ex. 1003 ¶ 86. The parties do not dispute this
construction in their subsequent briefing, and we discern no reason to
change this construction based on the complete record of this proceeding.
Therefore, we maintain our prior construction for purposes of this Final
Written Decision.
2. Engagement Limitation
Claim 1 recites, inter alia, that “the clockwise rotor blade is
engageable only with the clockwise lock mechanism and cannot be engaged
in the counterclockwise lock mechanism, and the counterclockwise rotor
blade is engageable only with the counterclockwise lock mechanism and
cannot be engaged in the clockwise lock mechanism.” Ex. 1001, 5:53–6:4.
We did not construe the Engagement Limitation in our Institution
Decision. See Inst. Dec. 10–13. Subsequent to institution in this
proceeding, we construed the Engagement Limitation in our Final Written
Decision in the related the 343 IPR.13 See 343 FWD 15–19. We incorporate
into this Final Written Decision the discussion and construction of the
Engagement Limitation from the Final Written Decision in the 343 IPR

13 The Final Written Decision in the 343 IPR issued on May 21, 2020. Both
parties had the opportunity to address this construction in subsequent
briefing in this proceeding, as well as at the Oral Hearing.
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(343 FWD, Section II.C.3)14; below, we highlight certain aspects of the
construction as particularly relevant to this proceeding, and we further
discuss the meaning of the phrase “be engaged in” present in the
Engagement Limitation.
Here, as in the 343 IPR, Patent Owner contends that the Engagement
Limitation, which “prevents the engagement of a rotor blade with the
wrong lock mechanism, means that the claimed lock mechanisms prevent a
rotor blade from being attached to the wrong drive.” Revised Mot. Amend
9–10 (citing Ex. 2001 ¶¶ 42–44) (emphasis Patent Owner’s).15 In the
343 IPR, “[w]e agree[d] with Petitioner that the claim recitation that the
rotor blade ‘cannot be engaged in’ the incorrect lock mechanism does not
mean that the rotor blade cannot be improperly attached, i.e., simply
mounted, to the incorrect rotor, as implicated by Patent Owner’s arguments.”
343 FWD 17 (citing 343 Paper 22, 5–6). We determined that “according to
the claimed invention, a proper attachment requires an engagement in the

14 Ex. 1031.
15 As noted above, Petitioner asserts that Patent Owner “is collaterally
estopped from this claim construction position” because we “previously
rejected the same construction of the same limitation of the same claim” in
the 343 IPR. Opp. 9–10. Patent Owner acknowledges it made the same
arguments in the 343 IPR. See Revised Mot. Amend 10 n.3. We need not
decide whether Patent Owner is collaterally estopped from making the
arguments that the claims require preventing a rotor blade from being
attached to the wrong drive because, for the reasons discussed in the
343 Final Written Decision and incorporated herein, those arguments also
are unpersuasive here. However, to the extent Petitioner contends that
Patent Owner is estopped from making any arguments regarding the
construction of the Engagement Limitation and the application of the claims
to the asserted prior art in this proceeding, we disagree. We note, in
particular, that the prior art asserted in this proceeding was not at issue in the
Final Written Decision in the 343 IPR.
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lock mechanism. Insofar as Patent Owner’s position is based upon an
attachment that does not include the required engagement, such is not an
attachment as described by the claims.” Id. at 17–18. In particular, “[w]e
disagree[d] with Patent Owner that the Engagement Limitation requires
prevention of the counterclockwise rotor blade being attached by some other
means, such as mounting to the clockwise driveshaft.” Id. at 18.
Although we disagree with Patent Owner’s assertions regarding
prevention of all forms of attachment generally, the Engagement Limitation,
by its plain language, must prevent, for example, the clockwise lock
mechanism from “be[ing] engaged in” the counterclockwise lock
mechanism. Our application of the Engagement Limitation to the prior art in
the 343 IPR, however, did not require us to explicitly construe the meaning
of the phrase “be engaged in” (i.e., the requirement that the “clockwise rotor
blade . . . cannot be engaged in the counterclockwise lock mechanism”). See
also Tr. 33:21–34:1 (Patent Owner’s counsel confirming that Patent Owner
does not argue that we must change our prior construction, but that we
should supplement it with a discussion of “engage”). We, thus, for this
proceeding, further discuss the meaning of to “be engaged in” in the context
of the proposed substitute claims.
Patent Owner provides evidence of the plain meaning of “engage” in
the form of two dictionary definitions. Reply 3. Specifically, these
dictionaries defined “engage” as “establish a meaningful contact or
connection with” (Ex. 2013, 4) and “to become meshed or interlocked”
(Ex. 2014, 4). We cited yet another dictionary definition in our Final
Written Decision in the 343 IPR, which defines “engage” as “to come
together and interlock.” “Engage” Definition, MERRIAM-WEBSTER.COM
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(available at https://www.merriam-webster.com/dictionary/engage) (cited at
343 FWD 19). Based on these definitions, which evince the plain and
ordinary meaning of engage, we construe “be engaged in” as “being
interlocked.” See also “Interlock” Definition, MERRIAM-WEBSTER.COM
(available at https://www.merriam-webster.com/dictionary/interlock) (“1: to
lock together : UNITE”; “2: to connect so that the motion or operation of
any part is constrained by another”). This construction is consistent with
the Specification of the ’184 patent. See Ex. 1001, 3:63–4:40.
D. Statutory and Regulatory Requirements
As noted above, Patent Owner’s proposed substitute claims must meet
the statutory requirements of 35 U.S.C. § 316(d) and the procedural
requirements of 37 C.F.R. § 42.121. We address each of these requirements
in turn.
1. Reasonable Number of Substitute Claims
A motion to amend must “propose a reasonable number of substitute
claims.” 35 U.S.C. § 316(d)(1)(B); see 37 C.F.R. § 42.121(a)(3) (“A motion
to amend may cancel a challenged claim or propose a reasonable number of
substitute claims.”). Patent Owner proposes two substitute claims in place
of two challenged claims. Revised Mot. Amend 1, 27. “There is a
rebuttable presumption that a reasonable number of substitute claims per
challenged claim is one (1) substitute claim.” Lectrosonics, Paper 15 at 4;
see 37 C.F.R. § 42.121(a)(3). Petitioner does not argue otherwise. See
generally Opp. Therefore, we determine that the amendments propose a
reasonable number of substitute claims.
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2. Respond to Ground of Unpatentability
“A motion to amend may be denied where . . . [t]he amendment does
not respond to a ground of unpatentability involved in the trial.” 37 C.F.R.
§ 42.121(a)(2)(i). Patent Owner asserts that the proposed substitute claims
are patentable over the combination of references that forms the basis of the
obviousness ground on which we instituted trial. Revised Mot. Amend
11–21. In particular, Patent Owner asserts that the “partial rotation [feature
added to substitute claims 12 and 13] provides the UAV with the convenient
twist-lock feature . . . , and is a distinct improvement over conventional
threaded screw-on type attachment mechanisms,” such as those disclosed in
Sasaki. Id. at 11–12 (citing Ex. 2001 ¶¶ 27, 37, 70). Patent Owner further
contends that “a [person of ordinary skill in the art] would not be motivated
to combine Sasaki with Sokn for numerous reasons, including those related
to the ‘partial rotation’ limitation.” Id. at 13 (citing Ex. 2007 ¶¶ 24–32, 39).
Petitioner does not argue otherwise.16 See generally Opp. We determine

16 In Petitioner’s Opposition to Patent Owner’s original Motion to Amend,
Petitioner argues that Patent Owner’s “Motion is merely a pretext to fix the
fatal indefiniteness issues which doomed enforcement of claims 3 and 4 in
the ITC.” Paper 15, 3. In our Preliminary Guidance, we determined that
Patent Owner’s Motion to Amend responded to the grounds of
unpatentability (Paper 16, 4); Petitioner did not repeat these arguments in its
Opposition to Patent Owner’s Revised Motion to Amend. We note also that
“[37 C.F.R. § 42.121(a)(2)(i)] does not require . . . that every word added to
or removed from a claim in a motion to amend be solely for the purpose of
overcoming an instituted ground. Additional modifications that address
potential 35 U.S.C. § 101 or § 112 issues, for example, are not precluded by
rule or statute. Thus, once a proposed claim includes amendments to
address a prior art ground in the trial, a patent owner also may include
additional limitations to address potential § 101 or § 112 issues, if
necessary.” Lectrosonics, Paper 15 at 5–6.
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that the amended language in the proposed substitute claims is responsive to
a ground of unpatentability involved in this trial.
3. Scope of Amended Claims
A motion to amend “may not enlarge the scope of the claims of the
patent.” 35 U.S.C. § 316(d)(3); see 37 C.F.R. § 42.121(a)(2)(ii) (“A motion
to amend may be denied where . . . [t]he amendment seeks to enlarge the
scope of the claims of the patent . . . .”). Petitioner contends that proposed
substitute “[c]laims 12 and 13 improperly enlarge the scope of claims 3 and
4 because they no longer require that the blade lock portion ‘is rotated.’”
Opp. 24; see id. at 24–25. The requirement of 35 U.S.C. § 316(d)(3),
however, is not that a proposed substitute claim cannot enlarge the scope of
the claim that it replaces, but that it cannot “enlarge the scope of the claims
of the patent.” (emphasis added); see also Lectrosonics, Paper 15 at 6
(“[A] proposed substitute claim may not remove a feature of the claim in a
manner that broadens the scope of the claims of the challenged patent.”
(emphasis added)). Proposed substitute claims 12 and 13 are dependent
claims and, therefore, include all of the limitations of independent claim 1.
Thus, they do not enlarge the scope of the claims of the patent such that the
proposed substitute claims would encompass apparatuses outside the scope
of the original claims. Cf. MPEP 1412.03(II) (explaining, in the context of a
reissue application,17 that an amendment that broadens a dependent claim

17 35 U.S.C. § 251, which governs pre-AIA reissue applications, includes
language similar to the “may not enlarge the scope of the claims of the
patent” language in 35 U.S.C. § 316(d)(3). See 35 U.S.C. § 251(d) (“No
reissued patent shall be granted enlarging the scope of the claims of the
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does not broaden the scope of the claims of the patent where the independent
claim is not broadened).
4. New Matter
A motion to amend “may not . . . introduce new matter.” 35 U.S.C.
§ 316(d)(3); see 37 C.F.R. § 42.121(a)(2)(ii) (“A motion to amend may be
denied where . . . [t]he amendment seeks to . . . introduce new subject
matter.”). Patent Owner asserts there is support for the proposed substitute
claims in the disclosure of U.S. Patent Application No. 14/277,370, which
issued as the ’184 patent, as well as in the Canadian priority application
No. 2815885.18 Revised Mot. Amend 4–9 (citing Ex. 2002; Ex. 2003;
Ex. 2001 ¶¶ 35–37). Petitioner does not argue otherwise. See generally
Opp. We have reviewed Patent Owner’s showing and determine that there is
support for the proposed substitute claims in the original application.
E. Patentability of the Proposed Substitute Claims
Petitioner contends that proposed substitute claims 12 and 13 would
have been obvious in view of Sasaki and Sokn, as well as in view of Sasaki
combined with Philistine, Obrist, or EP067. For the reasons discussed
below, we are not persuaded that Petitioner has established, by a
preponderance of the evidence, that proposed substitute claims 12 and 13
would have been obvious in view of any of Petitioner’s asserted
combinations of references.

original patent unless applied for within two years from the grant of the
original patent.” (emphasis added)).
18 Patent Owner confirms that “[t]he ’370 application and the ’885 priority
application have the same figures and written description.” Revised Mot.
Amend 4.
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1. Obviousness in View of Sasaki and Sokn
Petitioner contends that claims 12 and 13 would have been obvious in
view of Sasaki and Sokn. See Pet. 25–51; Opp. 1–8. Patent Owner
disagrees. See Revised Mot. Amend 11–21. For the reasons discussed
below, we are not persuaded by Petitioner’s arguments and evidence in
support of its contention that a person of ordinary skill in the art would have
combined Sasaki and Sokn to arrive at the claimed invention.
a) Overview of Sasaki
Sasaki is a Japanese Application Publication titled “Propeller for
Flying Toy and Fixture Thereof.” Ex. 1006, at code (54). Figure 7 of Sasaki
is reproduced below.

Figure 7, above, shows flying toy 7. Id. at 10:9–11. Flying toy 7 includes
body 71, motors 72, rotating shaft 73, and propellers 1, 1a. Id. at 4:3–7,
27–29. Propellers 1 rotate in the opposite direction as propellers 1a, so that
flying toy 7 can fly. Id. at 4:8–14.
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Figure 8 of Sasaki is reproduced below.

Figure 8, above, shows a prior art way in which propeller 1 is attached to
rotating shaft 73. Id. at 1:49–2:4. Nut 8 is buried in the central portion of
propeller 1 and is attached to screw shaft 74 at the top end of rotating shaft
73. Id. Patent Owner refers to this connection as a “conventional screw-on
type blade attachment mechanism.” Revised Mot. Amend 13. Due to
rotational forces of the UAV, “it is necessary to manufacture a propeller
which rotates right with a left screw, and a propeller which rotates left with a
right nut (8) and a rotating shaft (73).” Ex. 1006, 2:5–8. Petitioner refers to
this configuration as a “directionally threaded coupling mechanism.”
Pet. 28; Ex. 1003 ¶ 96. During rotation of propeller 1, nut 8 and rotating
shaft 73 “receive a force in the tightening 10 direction due to the rotation”;
this force may cause nut 8 to be “tightened more than necessary,” making it
difficult to remove the propeller when needed. Ex. 1006, 2:9–16.
b) Overview of Sokn
Sokn is a U.S. Patent titled “Motor Mount Assembly.” Ex. 1007, at
code (54). Sokn relates to “devices for mounting or supporting electric
motors.” Id. at 1:7–8. Sokn describes that, because “conventional practice
usually provides independent support for the housing and motor assembly, it
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is very difficult to achieve a precise alignment between the motor and the
housing.” Id. at 1:29–32.
Figure 3 of Sokn is reproduced below.

Figure 3, above, shows a partial exploded view of the details of the
mounting ring assembly of Sokn.19 Id. at 2:27–30. Motor mount assembly 1
includes internal ring 21, external ring 23, and cylindrical socket 25. See id.
at 3:4–65. External ring 23 includes “first engagement portion 35 in the
form of a raised helical thread defined by a plurality of circumferentially
spaced thread segments 37.” Id. at 3:29–32. Cylindrical socket 25 includes
“second engagement portion 47 having a thread configuration corresponding
to that of first engagement portion 35 . . . provided on [inner cylindrical]
surface 43 and positioned forwardly of stop members 45.” Id. at 3:45–48.

19 Both Dr. Ducharme and Dr. Reinholtz acknowledge an error in Figure 3 of
Sokn, that the threading of the ring does not match the assembly. Opp. 7 n.1
(citing Ex. 1028 ¶¶ 33–35; Ex. 1027, 167:1–16). A person of ordinary skill
in the art “would recognize [this] is easily fixed by reversing one of the
threads” in the Figure. Id.; see also id. at 6 (annotated figure showing this
correction).
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Second engagement “[p]ortion 47 is defined by four corresponding thread
segments 49 which extend inwardly from surface 43 and are equally and
circumferentially spaced 90° around surface 43.” Id. at 3:49–52.
As described in Sokn,
[t]hrough this arrangement, a large and easily alignable target
area is established between mounting ring assembly 19 and
socket 25 so that ring assembly 19 may be easily aligned and
inserted within socket 25. When this is accomplished, rotation
of ring assembly 19 90° with respect to socket 25 results in a
secure and aligned interlock connection therebetween, as
clearly shown in FIG. 4 [not reproduced herein]. In this
position, ring assembly 19 is disposed in abutting engagement
against stop members 45, thus assuring a secure attachment
between ring assembly 19 and socket 25 which will not become
accidentally loosened or disconnected during operation of
motor 3.
Id. at 3:53–65.
Sokn continues:
It is of course possible to configure first and second
engagement portions 35 and 47, and also stop members 45, in
order to provide a predetermined orientation for the engagement
and interlock connection between ring assembly 19 and socket
24, and also an interference fit therebetween for further assuring
precise alignment and a secure direct attachment of motor 3 to
housing 15.
Id. at 3:66–4:4. “Thus, the invention resides in an improved motor mount
assembly which permits a direct and secure attachment of a motor to an
associated housing in order to realize a precise alignment therebetween.” Id.
at 5:21–24. “This alignment permits a fan blade [driven by the motor and]
mounted on the end of shaft 7 to rotate freely within housing 15 and avoid
impact therewith during operation of motor 3.” Id. at 5:4–7.
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c) Petitioner’s Proposed Combination
Petitioner relies on a combination of Sasaki and Sokn as teaching all
the elements of the proposed substitute claims. See Pet. 25–51; Opp. 1–8.
In its Opposition, Petitioner contends that the “Petition established that the
combination of Sasaki and Sokn discloses the limitations of independent
claim 1 and original claims 3 and 4” and notes that “Petitioner therefore does
not repeat its detailed and uncontested ground here but instead highlights
how the Petition also establishes that the substitute claims are unpatentable.”
Opp. 1. Petitioner also asserts that Patent Owner “does not argue that the
amendments impart patentability to the claims, but instead argues that
claim 1, invalidated by the PTAB in an earlier IPR, provides patentable
subject matter.” Sur-reply 1. We note that the Petition established only a
reasonable likelihood of showing that original challenged claims 3 and 4
were unpatentable. See Paper 6; 35 U.S.C. § 314(a). We also note that the
references asserted in this proceeding are not the same as the references
asserted in the earlier 343 IPR. Here, Petitioner maintains the burden of
showing, by a preponderance of the evidence, that proposed substitute
claims 12 and 13 are unpatentable—in view of the references asserted in this
proceeding—and those claims include the limitations of independent
claim 1. See Bosch, 878 F.3d at 1040 (as amended on rehearing) (holding
that ordinarily “the petitioner bears the burden of proving that the proposed
amended claims are unpatentable by a preponderance of the evidence”);
TriVascular, 812 F.3d at 1068 (noting that “there is a significant difference
between a petitioner’s burden to establish a ‘reasonable likelihood of
success’ at institution, and actually proving invalidity by a preponderance of
the evidence at trial”).
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According to Petitioner, a person of ordinary skill in the art “would
have been motivated to replace Sasaki’s directionally-threaded mechanism
with a mechanism that does not suffer from the overtightening problem, is
easy to use, and maintains the ‘mistake-proofing’[20] of the prior art.” Pet. 29
(citing Ex. 1003 ¶ 100); see also Opp. 3 (“[A person of ordinary skill in the
art], looking at Sasaki, would have been motivated to improve the threaded
design while maintaining the mistake-proofing feature.” (citing Ex. 1030
¶ 37)). Petitioner points to Sokn as providing such a connection mechanism.
Pet. 29; see Opp. 5 (“In the instituted ground, the directional continuously-
threaded screw coupling mechanism of Sasaki’s prior art UAV is replaced
with the segmented coupling mechanism of Sokn.”).
In Petitioner’s combination, Sasaki’s threaded screw coupling
mechanism (screw shaft 74, nut 8, see Ex. 1006, Fig. 8) that attaches
propellers 1, 1a to rotating shaft 73 of flying toy 7, is replaced by the
modified threaded coupling mechanism of Sokn (first engagement portion
35, stop members 45, second engagement portion 47, see Ex. 1007, Fig. 3).
See Pet. 28, 32–33. Petitioner provides an annotated illustration of this
proposed combination (id. at 33), reproduced below.

20 See Pet. 28 (“Because of th[e] directional threading [disclosed in Sasaki],
the clockwise propeller cannot be used on the counterclockwise driveshaft
and vice versa. That is, Sasaki’s threaded coupling mechanism is
‘mistake-proof.’” (citing Ex. 1003 ¶ 96)).
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The figure above illustrates Petitioner’s proposed combination in which
nut 8 of Sasaki is replaced by Sokn’s stop members 45 and second
engagement portion 47, and screw shaft 74 of Sasaki is replaced by Sokn’s
first engagement portion 35. Pet. 32–33. Petitioner provides testimony from
Dr. Ducharme that the “scaling of Sokn’s coupling components is a matter
of mechanical design well within the capabilities of a [person of ordinary
skill in the art].” Ex. 1003 ¶ 108 (cited at Pet. 33–34).
Petitioner further contends that, based on Sokn’s teaching of
“provid[ing] a predetermined orientation” for engagement and interlock
connection (Ex. 1007, 3:66–4:4) and Sasaki’s teaching of a directionally
threaded coupling mechanism (see Ex. 1006, 2:5–8), a person of ordinary
skill in the art “would have been motivated to orient the thread segments and
corresponding notches for the clockwise coupling mechanism of the
clockwise propeller in a left helical direction (similar to a left screw)” and,
likewise, “to orient the thread segments and corresponding notches for the
counterclockwise coupling mechanism of the counterclockwise propeller in
a right helical direction (similar to a right screw).” Pet. 34–35 (citing
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Ex. 1003 ¶¶ 109, 110). As noted above with respect to Sasaki, “[w]ith this
orientation, the rotation force during operation is in the locking direction,”
“prevent[ing] disassembly during operation.” Id. at 35 (citing Ex. 1003
¶ 109). According to Petitioner, the stop members of Sokn’s coupling
mechanism, however, prevent the overtightening problem present with
Sasaki’s threaded screw coupling mechanism “by restricting further
rotation.” Id.; Ex. 1003 ¶ 109; see also Opp. 5 (“Sokn’s coupling
mechanism solves [the overtightening problem] by using both a plurality of
thread segments and stop members that resist further rotation after
installation and only require a 90° rotation.”).
Petitioner provides several reasons a person of ordinary skill in the art
would have been motivated to make this proposed modification, including
(1) that “Sokn’s coupling mechanism maintains the ‘mistake-proofing’ of
Sasaki’s prior art directionally threaded screw fastener without suffering
from overtightening” (Pet. 36 (citing Ex. 1003 ¶ 111)); (2) “provid[ing]
increased design flexibility,” such as the ability to increase the size of the
quadcopter (id. (citing Ex. 1003 ¶ 112)); and (3) “improv[ing] useability,”
specifically (a) allowing easy alignment and insertion, (b) allowing assembly
and disassembly with a half turn as opposed to three-to-four turns, and
(c) improved mechanical alignment, reducing cross-threading issues (id. at
37 (citing Ex. 1003 ¶ 113)). See also Opp. 2 (summarizing these Petition
arguments).
d) Discussion
We note several problems with the arguments and theories raised by
Petitioner regarding the combination of Sasaki with Sokn, leading us to a
conclusion that Petitioner has not shown that a person of ordinary skill in the
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art would have combined Sasaki with Sokn to arrive at the proposed
substitute claims.
As Patent Owner points out, Petitioner’s reasons for combining the
references are premised largely on “maintaining the mistake-proofing
feature” (Opp. 3 (emphasis added)) of Sasaki. See, e.g., Revised Mot.
Amend 15; Reply 1; Ex. 2016 ¶ 26 (“Petitioner’s proposed obviousness
combinations are all based on the false premise that Sasaki is mistake-
proof.”). For example, Petitioner contends that “[u]sing opposite-threaded
blades [as taught in Sasaki] prevents inadvertent disassembly during
operation and achieves the well-known design goal of ‘mistake-proofing’ the
lock mechanism so that the wrong blade is not installed on the wrong
propeller.” Opp. 8 (emphasis added) (citing Pet. 34–36; Ex. 1003 ¶¶ 54–57,
64; Ex. 1027, 37:1–13; Ex. 1014, 3). According to Petitioner, “Sasaki
teaches a directional threading where blades designed to rotate in different
directions are installed with opposite directions of rotation,” and that a
person of ordinary skill in the art “would have . . . used [this] directional
rotation to ensure proper installation” of the rotor blades. Id. at 3, 8 (internal
citations omitted); see also Ex. 1028 ¶ 41 (“Using opposite-threaded blades
achieves the well-known design goal of ‘mistake-proofing’ the lock
mechanism so that the wrong blade is not installed on the wrong
propeller.”).
Nothing in Sasaki expressly teaches or suggests that the directional
threading taught by Sasaki is for ensuring proper installation. See Ex. 2001
¶ 46. Rather, as Patent Owner notes, the directional threading of Sasaki
prevents “a loosening effect” during rotation of the blades. See Revised
Mot. Amend 14 (citing Ex. 2001 ¶ 46). Patent Owner presents evidence,
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discussed below, that “the conventional screw-on type blade attachment
mechanism does not prevent the attachment of a blade to the wrong drive.”
Id. at 15. Petitioner contends, however, that this evidence “is irrelevant
because the Petition does not rely on a conventional screw-on attachment
coupling mechanism.” Opp. 12 (citing Pet. 44–47); see Sur-reply 2–3.
We note, however, that Petitioner relies on the disclosure of
directional threading in Sasaki to support its assertion that Sasaki is
“mistake-proof.” For example, Petitioner contends that “[b]ecause of this
directional threading, the clockwise propeller [of Sasaki] cannot be used on
the counterclockwise driveshaft and vice versa. That is, Sasaki’s
directionally threaded coupling mechanism is ‘mistake-proof.’” Pet. 28
(citing Ex. 1003 ¶ 96) (emphases added); see also Ex. 1003 ¶ 96 (“[W]ith
this coupling mechanism [i.e., the directional threading of Sasaki], the user
cannot place a propeller on the wrong driveshaft—that is, the coupling
mechanism is ‘mistake-proof.’”).
Similarly, Petitioner contends it does not rely on Sasaki as teaching
the Engagement Limitation, but instead relies on Sokn as teaching this claim
feature. Sur-reply 1; Opp. 12. However, Petitioner’s evidence that Sokn
teaches the Engagement Limitation refers back to its discussion of Sasaki.
See, e.g., Opp. 13 (noting that “the combination in the Petition . . . explicitly
details a [person of ordinary skill in the art’s] motivation for modifying Sokn
according to the directional threading taught by Sasaki” (emphasis added)).
Petitioner also claims that Dr. Reinholtz “agrees that Sokn ‘probably
wouldn’t work’ if someone tried to screw a right-hand threaded ring into a
left-hand threaded socket, as is shown in Figure 3 of Sokn.” Sur-reply 1
(quoting Dr. Reinholtz’s deposition testimony, Ex. 1027, 166:22–167:16).
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We agree with Patent Owner, however, that a review of this testimony
indicates that Dr. Reinholtz was “pointing out the mistake in [Figure 3 of]
Sokn. He’s not saying you couldn’t misthread a blade if you used the Sokn
threading.” Tr. 36:11–12.
We, thus, address the parties’ dispute regarding whether a blade
screwed onto the wrong driveshaft, when using a conventional threaded
attachment mechanism (such as that described in Sasaki) is actually
“mistake-proof.” Based on the evidence of record, we determine that it is
not. Or, in other words, we determine that the conventional threaded
attachment mechanism taught by Sasaki does not teach the Engagement
Limitation (i.e., it does not prevent the clockwise lock mechanism from
“be[ing] engaged in” the counterclockwise lock mechanism).
According to Patent Owner, “the conventional screw-on type blade
attachment mechanism does not prevent the attachment of a blade to the
wrong drive.” Revised Mot. Amend 15 (citing Ex. 2001 ¶¶ 52–54, 59).
Patent Owner contends that “it is relatively easy to attach a blade on the
wrong drive on a UAV that utilizes the conventional screw-on type
connection mechanism.” Id. (citing Ex. 2001 ¶¶ 52–54); see also Ex. 2006
(video created by Dr. Reinholtz demonstrating that a blade can be attached
to the wrong drive using a screw-on type attachment mechanism). In its
Reply, Patent Owner argues, again relying on the testimony of
Dr. Reinholtz, that “[w]ith a conventional threaded attachment mechanism,
when a blade is screwed onto the wrong driveshaft, the blade becomes
engaged in the lock mechanism.” Reply 2 (citing Ex. 2016 ¶¶ 20–24).
Petitioner, on the other hand, relying on the testimony of
Dr. Ducharme, contends that “[w]hen a blade is forced onto the driveshaft
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and the threads are ‘stripped’, the blade is not, and cannot be, ‘engaged’ with
the lock mechanism”; “[r]ather, the metal threads on the shaft lock portion
are likely carving out new notches in the blade lock portion.” Opp. 12
(citing Ex. 1028 ¶ 49).
According to Patent Owner, however, the “[i]ntent of the UAV
designer is not a part of the Engagement Limitation.” Reply 2; see id.
(noting that “Petitioner’s position appears to be premised on the incorrect
notion that the Engagement Limitation requires the engagement of lock
mechanism components in the precise way that is intended by the designer
of the UAV”). Patent Owner contends that to “be engaged in,” as properly
construed, “include[s] the type of connection between threads when a blade
is screwed onto the wrong driveshaft.” Id. at 3. As we have construed it, to
“be engaged in” merely requires “being interlocked.” See supra
Section II.C.2. Relying on testimony of Dr. Reinholtz, Patent Owner further
contends that “when a blade is screwed onto the wrong driveshaft, the
threads on the blade mate or interlock with the threads on the driveshaft.”
Reply 3 (citing Ex. 2016 ¶¶ 20, 23–24); see also Tr. 31:8–12 (“[A]s
Dr. Reinholtz explains [at Ex. 2016 ¶ 23], that when a blade is misthreaded,
a mechanical connection is created by engagement between the threads
either because threads on the blade are deformed around threads on the shaft
or threads on the shaft carved through threads on the blade.”). As shown in
Dr. Reinholtz’s video, when the blades are screwed onto the wrong
driveshaft, the blade and shaft are locked together (i.e., “interlocked” or
“engaged”). Ex. 2006; see also Ex. 2001 ¶ 54 (describing the video, and
indicating that the incorrectly installed blades “do not fall off” and are
“securely attached”).
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Dr. Ducharme testifies “this ability to force a propeller on the wrong
driveshaft is not an intrinsic feature of all threaded couplings, but relates to
the specific materials and thread pitch used in the UAV in Dr. Reinholtz’s
video.” Ex. 1028 ¶ 49 (citing Ex. 1027, 161:12–163:11). However,
Dr. Reinholtz testifies, “[a]s a practical matter, multirotor UAVs typically
use plastic or composite propellers for both the clockwise and
counterclockwise blades. Because this material is soft and the driveshafts
are much harder metal, it is relatively easy to thread a clockwise rotor blade
on a motor shaft intended for a counterclockwise blade, and vice versa.”
Ex. 2001 ¶ 52.
We are persuaded by Dr. Reinholtz’s testimony and find that a blade
screwed onto the wrong driveshaft of a UAV, when using a conventional
threaded attachment mechanism, is engaged in the lock mechanism within
the meaning of the claims.21 We, thus, are not persuaded that Sasaki teaches
a “mistake-proof” design.
Because we are not persuaded that Sasaki teaches a “mistake-proof”
design, we also are not persuaded by Petitioner’s motivation to combine
arguments that are premised on maintaining the alleged “mistake-proof”
teachings of Sasaki. Petitioner contends that “the motivation to combine

21 Though not dispositive to our analysis here, we also note that Petitioner
seems to recognize that two components of a conventional threaded
attachment mechanism can be engaged, without being connected as
intended. See Pet. 37 (“[A]s rotor blades get larger, mounting them using
Sasaki’s threaded mechanism would be difficult to achieve without
increased potential for ‘crossthreading’ and damaging the mechanism.
Cross-threading occurs when two t[h]readed components are engaged
without properly aligning the threads. The misaligned threads cut into each
other and cause irreparable damage.” (emphasis added) (citing Ex. 1003
¶ 112)).
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Sasaki with Sokn . . . is not defeated by Sasaki’s alleged non-disclosure of
the engagement limitation.” Sur-reply 3. We disagree. According to
Petitioner, “there is no dispute that a [person of ordinary skill in the art]
would have been motivated to modify Sasaki in a way that was
mistake-proof.” Id.; see id. at 5–6. However, without any express teaching
in Sasaki regarding lock mechanisms that are mistake-proof (or the
desirability thereof), we determine that this is an impermissible exercise of
hindsight with the claims of the ’184 patent serving as a guide, which is not
appropriate for a conclusion of obviousness. See Otsuka Pharm. Co. v.
Sandoz, Inc., 678 F.3d 1280, 1296 (Fed. Cir. 2012) (“The inventor’s own
path itself never leads to a conclusion of obviousness; that is hindsight.”);
In re NTP, Inc., 654 F.3d 1279, 1299 (Fed. Cir. 2011) (“Care must be taken
to avoid hindsight reconstruction by using ‘the patent in suit as a guide
through the maze of prior art references, combining the right references in
the right way so as to achieve the result of the claims in suit.’” (internal
citations omitted)); In re Fritch, 972 F.2d 1260, 1266 (Fed. Cir. 1992) (“It is
impermissible to use the claimed invention as an instruction manual or
‘template’ to piece together the teachings of the prior art so that the claimed
invention is obvious.” (internal citations omitted)).
Petitioner’s motivation to combine arguments also rely on an assertion
that Sokn’s coupling mechanism solves the overtightening problem
discussed in Sasaki. See Pet. 35; Opp. 17–18; Sur-reply 7–8. In particular,
Petitioner contends that “[t]he stops [of Sokn] prevent overtightening by
restricting further rotation.” Pet. 35–36 (citing Ex. 1003 ¶ 109).
Dr. Ducharme testifies, without further explanation, that “the stop members
prevent any further rotation of ring assembly after installation.” Ex. 1003
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¶ 111; see also Ex. 1028 ¶ 48 (Dr. Ducharme testifying, again without
further explanation, that “[t]he use of the term ‘stop members’ informs a
[person of ordinary skill in the art] that they stop rotation.”).
We agree with Dr. Reinholtz that “Sokn never [expressly] suggests
that [stop members 45] can or will prevent overtightening.” Ex. 2001 ¶ 68.
Dr. Reinholtz testifies that, instead, “[i]n the applications envisioned by
Sokn [which do not include further rotation after installation], installation
torque can be accurately set to assure a secure connection.” Id. Further,
Dr. Reinholtz provides detailed testimony rebutting Dr. Ducharme’s
unsupported assertion that the stop members of Sokn prevent overtightening.
Ex. 2001 ¶¶ 67–69; Ex. 2007 ¶¶ 28–30; see Revised Mot. Amend 19–20. In
particular, Dr. Reinholtz testifies that “[p]ositive, non-frictional stops require
stop elements that abut radially rather than axially.” Ex. 2007 ¶ 28.
Dr. Reinholtz explains that “Sokn requires frictional contact between the
stops 45 . . . and the resilient ring 21 . . . to terminate rotation.” Id. ¶ 29.
Dr. Reinholtz recognizes that “[i]t is true that, at a certain applied torque,
[Sokn’s stop members] will stop rotation. But it is also true that additional
torque will cause additional rotation and that this will result in
overtightening up to the point where rotation is stopped.” Ex. 2016 ¶ 27; see
also Reply 4 (arguing that Petitioner has not rebutted Dr. Reinholtz’s
testimony regarding the stop members of Sokn). Petitioner, on the other
hand, contends that it “has already rebutted this argument” (Sur-reply 7),
pointing to pages 17 to 18 of its Opposition. Here, Petitioner does not rebut
Patent Owner’s evidence, but merely argues that Patent Owner “has no
corroborating evidence” and that Patent Owner’s position “is based on
nothing more than speculation.” Opp. 17; but see Ex. 2016 ¶ 27
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(Dr. Reinholtz testifying that “it is common sense (and would be clearly
understood by a [person of ordinary skill in the art]) that frictional stops such
as used in Sokn or a on a jar lid can be overtightened”). It is noteworthy that
neither Petitioner nor Dr. Ducharme contends that Sokn’s mechanism cannot
be overtightened. See generally Opp.; see also Bosch, 878 F.3d at 1040 (as
amended on rehearing) (holding that ordinarily “the petitioner bears the
burden of proving that the proposed amended claims are unpatentable by a
preponderance of the evidence”). Further, we agree with Patent Owner that
the argument presented in Petitioner’s Sur-reply—that “if Sokn had viewed
overtightening to be an issue, it would have placed radial stops [(as
illustrated in Figure 5 of Sokn)] in Figure 3” (Sur-reply 8)—is based on
hindsight. Tr. 38:18–21.
We find Patent Owner’s arguments and evidence on this point more
persuasive, and we are not persuaded that Sokn’s coupling mechanism
solves the overtightening problem discussed in Sasaki.
Petitioner provides additional rationales in support of its proposed
modifications to Sasaki—to “provide increased design flexibility” and to
“improve usability.” Pet. 36–38; Ex. 1003 ¶¶ 112, 113. We are not
persuaded that these rationales, alone, are sufficient to support a finding that
a person of ordinary skill in the art would have been motivated to modify
Sasaki with the connection mechanism of Sokn, as proposed by Petitioner.
To rely solely on these general rationales, which are not grounded in what a
person of ordinary skill in the art would have gleaned from the teachings of
the prior art, would be an impermissible exercise of hindsight with the
claims of the ’184 patent serving as a guide. See Otsuka Pharm., 678 F.3d at
1296; In re NTP, Inc., 654 F.3d at 1299; In re Fritch, 972 F.2d at 1266.
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For these reasons, we not persuaded by Petitioner’s arguments and
evidence in support of its contention that a person of ordinary skill in the art
would have combined Sasaki with Sokn to arrive at the invention recited in
the proposed substitute claims.
2. Obviousness in View of Sasaki and Philistine, Obrist, or
EP067
Petitioner argues that “mechanisms [using partial rotation, with lugs
and notches, to install one component onto another component] were known
for over a century.” Opp. 18 (citing Pet. 13–16; Ex. 1027, 96:6–15). In this
regard, Petitioner points to three references disclosing such a mechanism—
Philistine, Obrist, and EP067—and contends that a person of ordinary skill
in the art would have been motivated to combine each of these references
with Sasaki to arrive at the invention of the proposed substitute claims. See
id. at 18–24. Patent Owner argues that “Petitioner has failed to establish that
a [person of ordinary skill in the art] would combine these references with
Sasaki, or that, even if combined, that they would render the revised
substitute claims unpatentable.” Revised Mot. Amend 21.
For the reasons discussed below, we are not persuaded by Petitioner’s
arguments and evidence in support of its contention that a person of ordinary
skill in the art would have combined Sasaki with any of Philistine, Obrist, or
EP067 to arrive at the claimed invention.
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a) Sasaki and Philistine
Philistine discloses a “twist lock mount for quick mounting and
positioning a device to a support.” Ex. 1026, at code (57). Figure 1 of
Philistine is reproduced below.

Figure 1, above, shows a top view of one embodiment of the quick release
mount of Philistine. Id. at 2:14–15. Philistine’s mechanism includes a
“mounting member 110 that is secured to or integrated with a device to be
mounted, and a receiving member 116 that is secured to or integrated with a
mounting surface or support.” Id. at 2:33–44. Petitioner describes that
“mounting member 110 slides into the channel 123 and securely locks in
place with a 90° . . . rotation of the mounting plate relative to the receiving
member, engaging ‘lugs 150’ on the mounting plate with notches (‘recesses
119’) on the receiving member.” Opp. 19 (citing Ex. 1026, 2:33–44,
3:10–22, 4:24–27, Figs. 1, 2). According to Petitioner, “[t]he mechanism
[of Philistine] is not susceptible to overtightening because ‘mounting
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member 110 is locked into position and will resist further rotation in the
counterclockwise direction.’” Id. (citing Ex. 1026, 4:27–29; Ex. 1028 ¶ 51).
Petitioner contends a person or ordinary skill in the art “would have
been motivated to use Philistine . . . to mount a UAV blade onto a driveshaft
for several reasons.” Id. at 20. These reasons include “solv[ing] the
overtightening problem of Sasaki’s prior art threads while maintaining the
well-known ‘mistake-proof’ design” thereof (id. (citing Ex. 1028 ¶ 57)) and
that Philistine’s “mechanism allows for easy installation and de-installation
while being secure enough for ‘harsh environments where extreme vibration
and shock loading is expected’” (id. (quoting Ex. 1026, 1:25–28; citing
Ex. 1028 ¶ 57)). Petitioner also contends that “Philistine is analogous art to
Sasaki because it discloses a general-purpose twist-lock mechanism, which
is reasonably pertinent to the problem of attaching a blade to a UAV
driveshaft.” Id. (citing Ex. 1028 ¶ 57).
We note certain problems with the arguments and theories raised by
Petitioner regarding the combination of Sasaki with Philistine, leading us to
a conclusion that Petitioner has not shown that a person of ordinary skill in
the art would have combined Sasaki with Philistine to arrive at the proposed
substitute claims.
According to Petitioner’s combination of Philistine with Sasaki,
“Philistine’s mounting plate is attached or integrated onto the blade, forming
the ‘blade lock portion,’ and Philistine’s receiving member is attached or
integrated onto the shaft, forming the ‘shaft lock portion.’” Id. at 21 (citing
Ex. 1028 ¶ 59). We recognize that Philistine discloses that its mounting
system “provide[s] simple, ergonomic, easily securable, quickly releasable,
low profile, mounting mechanisms for a variety of equipment, components
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and devices in a number of different working environments.” Ex. 1026,
5:31–36 (emphasis added by Petitioner at Opp. 22). Philistine, however,
relates to “surface mounting of devices in confined spaces.” See id. at 3:5–6
(emphasis added); see also, e.g., id. at 6:7–8 (Claim 1 recites a “twist-lock
mount for mounting and positioning a device to a support.” (emphasis
added)). Petitioner does not describe how receiving member 116 of
Philistine—which includes “channel 123 that is defined by a pair of
opposing, parallel guide rails 121 [that] . . . extend longitudinally (in the
x direction) and provide inner guide surfaces 125 that make up the walls of
channel 123” (Ex. 1026, 2:50–54)—would be “attached or integrated onto
the shaft” (Opp. 21) of Sasaki. See TriVascular, 812 F.3d at 1066.
Petitioner also argues that a person of ordinary skill in the art “would
have been motivated to mirror the design of Philistine’s Figure 1
embodiment” to form the clockwise and counterclockwise lock mechanisms.
Opp. 21. Petitioner’s mirror-image arguments, however, are premised, at
least in part, on the assertion that the combination “maintain[s] the
well-known ‘mistake-proof’ design” of Sasaki” (id. at 20). See id. at 21–22.
We are not persuaded by these arguments for the same reasons discussed
above regarding the combination of Sasaki and Sokn. See supra Section
II.E.1.d; Reply 7 (“Petitioner’s . . . assertions on motivation are based on the
false premise that Sasaki is mistake-proof.”). Further, we agree with Patent
Owner that Philistine does not “disclose more than one configuration for
their connection mechanisms.” Revised Mot. Amend 22. For these reasons,
we are not persuaded by Petitioner’s arguments and evidence in support of
its contention that a person of ordinary skill in the art would have combined
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Sasaki with Philistine to arrive at the invention recited in the proposed
substitute claims.
b) Sasaki and Obrist or EP067
The parties’ arguments address the combination of Sasaki with Obrist
or EP067 together. We, thus, also address these combinations in a single
discussion. We note certain problems with the arguments and theories
raised by Petitioner regarding the combination of Sasaki with Obrist or
EP067, leading us to a conclusion that Petitioner has not shown that a person
of ordinary skill in the art would have combined Sasaki with either of Obrist
or EP067 to arrive at the proposed substitute claims.
Obrist relates to a “variable-pitch propeller for ships, aircraft and
centrifugal machines, provided with cranks for varying the pitch of the
propeller blades.” Ex. 1017, 1:1–4. As described in Obrist:
The operation of mounting a blade root 2 in the hub is
carried out as follows. The root 2 is so positioned (see, for
example, Fig. 6) that its bayonet lugs 6 can be introduced
through recesses 8. After such introduction and the insertion of
the trunnion 9 into the bearing provided therefor near the center
of the hub the root and its attached adjusting crank are turned
about 90° so that the lugs 6 are displaced from the recesses 8
through which they entered, and engage an arcuate seat formed
therefor on the internal face of the hub.
Id. at 2:44–54. “In Obrist, the projections 6 resist radial force, i.e., the
centrifugal force, that tries to sling the blade radially outward from the hub
as shown in Figure 2 below.” Ex. 2007 ¶ 22.
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Annotated Figure 2, above, is a sectional view of the variable-pitch ship
propeller of Obrist. Ex. 1017, 1:33–38.
EP067 relates to a “variable-pitch propeller.” Ex. 1018, at code (57).
As described therein, the propeller
has angularly displaceable blade support plates (1) which can
be rotated about respective radial axes (2). The plates (1) are
provided with radially inwardly directed claws (4) which
engage in circumferential grooves (11) of bases (7) of the
blades (8). The latter have radial projections (12) reaching
beneath the claws (4). The resulting bayonet connection
simplifies mounting and dismounting of the propeller blades (8)
even under water.
Id. “For mounting of a new blade, the base of the new blade is fitted onto
the plate so that the claws engage in the cutouts and the blade is then rotated
through a fraction of a full revolution about its radial axis until the claws
engage in the groove and the projections engage beneath the claws. Id. ¶ 8.
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As described above, both Obrist and EP067 relate to variable-pitch
propellers. Ex. 1017, 1:1–5; Ex. 1018, at code (57); see also Revised Mot.
Amend 21 (“EP067 and Obrist relate to pitch-control for propeller blades.”
(citing Ex. 2007 ¶¶ 20–22)). As Dr. Reinholtz testifies, “propeller blades in
EP067 are fixed to the hub, as shown . . . in EP067 Figure 5, and do not
rotate around the axis of the driveshaft like a UAV propeller blade.”
Ex. 2007 ¶ 20. The configuration of Obrist is similar. See id. ¶ 21
(“Obrist . . . , like EP067, relates to pitch control and does not at all relate to
clockwise and counterclockwise rotating blades.”).
Dr. Reinholtz testifies, more specifically, that “[t]he boat propeller
blades in EP067 are fixed to the hub and rotate only through a fraction of a
revolution to adjust the pitch of the blade. In EP067, the axis of the drive
motor is perpendicular to the blade.” Id. ¶ 36; see, e.g., Ex. 1018 ¶ 17
(“In FIGS. 5 and 6, the hub has been represented at 20, the hub axis at 21
and the pitch-adjustment mechanism has been shown at 22 within the hub
for angularly displacing each of the blades 8 about the respective radial axis
2 to vary the pitch of the propeller”), claim 10 (reciting a “variable-pitch
boat propeller . . . comprising: a hub provided with a pitch-adjustment
mechanism; a plurality of blade-support plates angularly spaced apart on
said hub and rotatable about respective radial axes by said mechanism; and
respective blade members affixed to said blade-support members”).
Because both Obrist and EP067 relate to variable-pitch propellers, the same
would apply to Obrist. The propellers of Obrist and EP067 simply have a
configuration that is different than the blades of a UAV generally, and of
Sasaki more specifically.
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In describing the combination of Sasaki with Obrist or EP067,
Petitioner asserts that
[f]or example, the portion of the blade foot integrated into the
propeller in the combined UAV of Sasaki and EP067 that has
cutouts 11 and projections is the “blade lock portion.”
Projections 12 are “lugs on the blade lock portion.” Support
plate 1 integrated into the driveshaft in the combined UAV of
Sasaki and EP067 is the recited “shaft lock portion” and gaps 5
are the recited “notches.”
Opp. 22–23 (citing Ex. 1028 ¶ 62). We note, however, that although
Petitioner references “the blade foot integrated into the propeller in the
combined UAV of Sasaki and EP067” (Id. at 22), nowhere does Petitioner
describe how this combination is implemented. It is not a sufficient
explanation for combining with Sasaki that these references relate to
propellers. As discussed above, the propellers in Obrist and EP067 are fixed
to a hub, and they do not rotate around the axis of the driveshaft like a UAV
propeller blade, such as that of Sasaki. See Ex. 2007 ¶ 20. Dr. Ducharme
does not sufficiently address these differences in his declarations.
Further, Petitioner acknowledges that “the forces are different with the
UAV connection,” but asserts that a person of ordinary skill in the art
“would understand how to apply the teachings of Obrist and EP067 to the
rotational forces experienced by the blades in a UAV, such as Sasaki.”
Opp. 20 (citing Ex. 1028 ¶ 56); see also Ex. 2007 ¶ 33 (noting that
Dr. Ducharme “fails to demonstrate how these combinations would be
implemented”). Petitioner contends that “[b]oth Obrist and EP067 explain
that the force in rotation of the propeller maintains the lugs in position.”
Opp. 20 (citing Pet. 19–20; Ex. 1017, 2:55–3:4; Ex. 1018 ¶ 11). The cited
portions of Obrist and EP067, however, do not relate to rotational forces
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such as those found in a UAV propeller, and Petitioner provides no
additional explanation in this regard. For example, Obrist states that
“projections 6 act as a lock with regard to the centrifugal forces exerted on
the corrected place 1 in that they rest directly against the inner surface of the
hub 3.” Ex. 1017, 3:1–4. EP067 states that “hydrodynamic flow forces
suffice to prevent rotation of the blade angularly to release the bayonet
connection [of the individual propeller blade].” Ex. 1018 ¶ 11. And, as
discussed above, the propeller blades in Obrist and EP067 are fixed to the
hub and do not rotate around the axis of the driveshaft as in a UAV. See
Ex. 2007 ¶¶ 20–21. We, thus, are not persuaded that Petitioner has
sufficiently described how a person of ordinary skill in the art would have
implemented the combination of Sasaki and Obrist or EP067. See
TriVascular, 812 F.3d at 1066.
As to motivation to combine, Petitioner contends a person of ordinary
skill in the art “would have been motivated to use . . . Obrist or EP067 to
mount a UAV blade onto a driveshaft for several reasons.” Opp. 20. The
only reason Petitioner provides that is not specific to Philistine, however, is
“solv[ing] the overtightening problem of Sasaki’s prior art threads while
maintaining the well-known ‘mistake-proof’ design” of Sasaki. Id. (citing
Ex. 1028 ¶ 57). As discussed above in our discussion of the combination of
Sasaki and Sokn, we do not find these arguments to be persuasive. See
supra Section II.E.1.d; Reply 7 (“Petitioner’s . . . assertions on motivation
are based on the false premise that Sasaki is mistake-proof.”).
For these reasons, we are not persuaded by Petitioner’s arguments and
evidence in support of its contention that a person of ordinary skill in the art
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would have combined Sasaki with Obrist or EP067 to arrive at the invention
recited in the proposed substitute claims.
III. CONCLUSION
Pursuant to Patent Owner’s non-contingent request, we cancel claims
3 and 4, and for the reasons set forth above, we grant Patent Owner’s motion
to amend the ’184 patent to add proposed substitute claims 12 and 13, as
summarized in the following table:
Motion to Amend Outcome Claims
Original Claims Cancelled by Amendment 3, 4
Substitute Claims Proposed in the Amendment 12, 13
Substitute Claims: Motion to Amend Granted 12, 13
Substitute Claims: Motion to Amend Denied
Substitute Claims: Not Reached

IV. ORDER
Accordingly, it is
ORDERED that Patent Owner’s Motion to Amend is granted as to its
non-contingent request to cancel claims 3 and 4; and
FURTHER ORDERED that Patent Owner’s Motion to Amend is
granted as to substitute claims 12 and 13.
This is a final decision. Parties to the proceeding seeking judicial
review of the decision must comply with the notice and service requirements
of 37 C.F.R. § 90.2.
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PETITIONER:
Lori A. Gordon
Steven W. Peters
KING & SPALDING LLP
lgordon@kslaw.com
speters@kslaw.com

PATENT OWNER:
John Abramic
Matthew Bathon
Timothy Bickham
Harold Fox
Gretchen Miller
STEPTOE & JOHNSON LLP
jabramic@steptoe.com
mbathon@steptoe.com
tbickham@steptoe.com
hfox@steptoe.com
gmiller@steptoe.com