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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
REMY, INC., UNIT PARTS COMPANY, and WORLDWIDE AUTOMOTIVE, LLC, Plaintiffs, v. CIF LICENSING, LLC, D/B/A GE LICENSING, WELLS MANUFACTURING CORP., TADITEL US, INC., and WETHERILL ASSOCIATES, INC., Defendants.
) ) ) ) ) ) ) ) ) ) ) ) )
C.A. No. 06-785-***
GE LICENSING'S MOTION TO DISMISS, OR IN THE ALTERNATIVE TO STAY Defendant CIF Licensing, LLC d/b/a GE Licensing ("GE") hereby respectfully moves, pursuant to the first-filed rule, that the Court dismiss plaintiff's claims against GE and GE's counterclaims, without prejudice, on the ground that an earlier-filed action involving all required parties and the same controversy is pending in the United States District Court for the Eastern District of Texas ("the Texas Case"). GE's second amended complaint in that action relates back to its original filing date, preserving that Court's status as the first-filed forum with respect to all parties. In the alternative, GE respectfully requests that this action be stayed pending the resolution of the Texas Case. BACKGROUND This controversy arose because of a suit GE filed in the Eastern District of Texas--CIF Licensing, LLC d/b/a GE Licensing v. Denso Corp., et. al., No. 2:06-cv-345-DF (E.D. Tex.)--on August 30, 2006, alleging infringement of United States Patent No. 4,773,159, the same patent at issue in this case. (See Ex. A, GE's Texas Compl.) Of the three original defendants in the Texas
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suit, two settled, leaving Remy International, Inc. as the only remaining defendant. Remy International is the corporate parent of the plaintiffs in this suit--Remy, Inc., Unit Parts Company, and World Wide Automotive ("the Remy Subsidiaries"). As part of the effort to reach a settlement in the Texas case, Remy International's counsel, who also represents the Remy Subsidiaries, negotiated with GE on behalf of Remy International. On December 21, 2006, once it had become clear that no settlement was possible, Remy International filed a motion to dismiss the Texas case for lack of personal jurisdiction, the same day the Remy Subsidiaries filed this Delaware action seeking a declaration of non-infringement, invalidity, and unenforceability of the `159 Patent. 1 In its motion to dismiss the Texas case, Remy International asserted that it was not the correct defendant because it does not make or sell the accused products, describing itself as "merely a corporate shell owning stock in the various Remy subsidiaries." (See Ex. B, Remy International Texas Mot. To Dismiss, at 1.) In response, GE requested leave to amend its Texas complaint to join the proper defendants, the Remy Subsidiaries, and consented to the dismissal of Remy International if the amendment were permitted. On July 3, 2007 the Texas Court granted GE leave to amend (Ex. C), and GE has filed its Second Amended Complaint, joining the Remy Subsidiaries in the Texas suit (Ex. D) However, in its order granting GE leave to amend, Judge Folsom stayed the Texas suit pending a decision by this Court as to which of the two cases
1
The Remy Subsidiaries' complaint also alleges indemnity claims against their suppliers, Taditel US, Inc, Wells Manufacturing, Inc., and Wetherill Associates, Inc. ("the Indemnity Defendants"). One of the Indemnity Defendants, Wells Manufacturing, has, in turn, asserted a thirdparty indemnity claim against its upstream supplier, STMicroelectronics, Inc.
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should be deemed the first-filed action: "The Court expressly leaves the `first filed' issue for the Delaware court to resolve if properly presented." (Ex. C at 5.) GE accordingly has filed this motion in order to present this Court with an appropriate procedural vehicle to decide which case should be deemed the first-filed action and to thereby determine the venue in which this dispute will be litigated. ARGUMENT I. THE TEXAS CASE IS FIRST-FILED AND SHOULD PROCEED TO JUDGMENT.
When deciding which of two closely related patent infringement cases involving overlapping parties and identical issues should proceed, this court applies the first-filed rule. See, e.g., Genentech, Inc. v. Eli Lilly and Co., 998 F.2d 931, 937 (Fed. Cir. 1993); E.E.O.C. v. University of Pennsylvania, 850 F.2d 969, 971 (3rd Cir. 1988) ("[i]n all cases of federal concurrent jurisdiction, the court which first has possession of the subject must decide it") (quoting Crosley Corp. v. Hazeltine Corp., 122 F.2d 925, 929 (3rd Cir. 1941)); Corixa Corp. v. IDEC Pharm. Corp., 2002 WL 265094, *1 (D. Del. 2002) ("[w]here two patent lawsuits involving the same claims are filed in different jurisdictions, the Federal Circuit requires that the first-filed action be given preference absent special circumstances"). Although the Remy Subsidiaries did not become participants in this controversy until they filed this declaratory judgment suit on December 21, 2006, the Texas Case is nonetheless the first-filed case with respect to these parties because the amended Texas complaint, naming them as defendants, relates back to August 30, 2006, FED. R. CIV. P. 15(c), almost four months prior to the commencement of this Delaware action: Relation back is dependent upon four factors, all of which must be satisfied: (1) the basic claim must have arisen out of the conduct set forth in the original pleading; (2) the party to be brought in must have received such notice that it will not be prejudiced in 3
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maintaining its defense; (3) that party must or should have known that, but for a mistake concerning identity, the action would have been brought against it; and (4) the second and third requirements must have been fulfilled within the prescribed limitations period. Fromson v. Citiplate, Inc., 886 F.2d 1300, 1303 (Fed. Cir. 1989). Schiavone v. Fortune, 477 U.S. 21, 29 (1986). It is uncontroverted that all four factors are satisfied in this case. First, GE's Second Amended Complaint alleges conduct identical to the original complaint--the manufacture and sale of voltage regulators that infringe GE's `159 patent. (See Ex. D). Second, the Remy Subsidiaries received actual knowledge of this action from its inception through their common counsel and, as a result, executed a coordinated litigation strategy by filing this suit and the Motion to Dismiss in the Texas Case on the same day. See also E.I. duPont de Nemours & Co. v. Phillips Petroleum Co., 621 F.Supp. 310, 314 (D. Del. 1985) (applying Rule 15(c) in a patent infringement case where plaintiff sought to add a wholly-owned subsidiary corporation to an action where the parent corporation was already a defendant, and holding that this prong was satisfied because of the "close intercorporate relationship of the parties"). Third, the Remy Subsidiaries therefore knew that they were intended as the proper defendants. Finally, the Remy Subsidiaries had proper notice because they responded to the Texas suit by bringing this action within the prescribed 120 day Rule 4(m) limitations period. (Compare Ex. A with Remy Delaware Compl., Docket Item No. 1.) Courts routinely apply the "first-to-file" rule in patent infringement cases under nearly identical circumstances. For example, in Aerotel, Ltd. v. Sprint Corp., 100 F.Supp.2d 189 (S.D.N.Y. 2000), the plaintiff sued a holding company that, unknown to the plaintiff, did not actually make or sell the infringing products. As here, the holding company's subsidiaries (which actually made and sold the infringing products) rushed into a more preferred forum and sued the patentee for a declaratory judgment. As here, the patentee amended its complaint to add the sub-
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sidiaries, after which the holding company brought a motion to dismiss and/or transfer under the "first-to-file" rule. The court denied the motion under the relation-back doctrine. See also NutriHealth Supplements, LLC v. Block Drug Co., 2007 WL 38159 (D. Ariz. 2007) (applying firstfiled rule to grant motion to dismiss declaratory judgment suit for non-infringement and invalidity because defendant's complaint in other forum related back under Rule 15(c)); Optima, Inc. v. Republic Indus., Inc., 1995 WL 72430 (E.D. La. 1995) (applying Rule 15(c) relation back doctrine to deny motion to dismiss or transfer patent infringement case under first-filed rule where plaintiff initially sued non-existent party and proper defendant subsequently brought declaratory judgment suit in other forum). The same result should occur here. GE should not be deprived of its forum choice simply because Remy International concealed the fact that its subsidiaries were the correct defendants until settlement negotiations broke down, raising the issue only when its subsidiaries were poised to simultaneously ambush GE with a declaratory judgment complaint in Delaware. It is particularly appropriate for this Court to refuse to permit such flagrant forum shopping where, as here, the Remy Subsidiaries have had actual knowledge of these proceedings from their inception and Remy International's participation in settlement negotiations led GE to believe that it was dealing with the proper party. See, e.g., Sorrels v. Sears, Roebuck & Co., 84 F.R.D. 663, 667 (D. Del. 1979) (applying Rule 15(c) and stating, "[w]here a potential defendant misleads a plaintiff into thinking that another party should be sued, that defendant should not be able to claim surprise at its being brought into the action"). II. ALL NECESSARY PARTIES ARE AVAILABLE IN THE TEXAS SUIT.
The just resolution of this case does not depend on the presence of the Indemnity Defendants. Although the Remy Subsidiaries offer no supporting documents, they allege that the In-
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demnity Defendants owe a contractual duty to indemnify one or more of them for liability if the accused products are found to infringe GE's patent. Any such indemnity obligation, if it does exist, is premature until liability on the underlying patent infringement claim becomes fixed and certain. It is black letter law--in both Texas and Delaware--that claims against indemnitors may not be brought unless and until there is a judgment of liability against their indemnitee. See, e.g., Scharf v. Edgcomb Corp., 864 A.2d 909, 919 (Del. Super. 2004) (stating that the cause of action for indemnification does not accrue until the indemnitee is "confident any claim against him . . . has been resolved with certainty"); Chesapeake Utilities Corp. v. Chesapeake and Potomac Tel. Co. of Maryland, 401 A.2d 101, 102 (Del. Super. 1979) (stating that the point at which an indemnification claim is ripe "is the point at which the indemnitee suffers loss or damage through payment of a claim after judgment or settlement"); Ingersoll-Rand Co. v. Valero Energy Corp., 997 S.W.2d 203, 208 (Tex. 1999) ("the longstanding rule [is] that a claim under a liability indemnification clause does not accrue, and thus is not mature, until the indemnitee's liability to the party seeking damages becomes fixed and certain"); D. Wilson Const. Co. v. Cris Equip. Co., Inc., 998 S.W.2d 388, 396 (Tex. App. 1999) ("[i]n the case of a promise to indemnify against liability, a cause of action accrues to the indemnitee only when the liability has become fixed and certain, as by rendition of a judgment"). There is no compelling reason preventing the Remy Subsidiaries from proceeding against the Indemnity Defendants in this forum should the Texas court enter a finding of liability on the underlying patent claim. CONCLUSION For the foregoing reasons, the Remy Subsidiaries' Complaint in this case should be dismissed pursuant to the first-filed rule, or in the alternative, the case should be stayed pending the outcome of Civil Action No. 2:06-cv-00345-DF, currently pending in the Eastern District of Texas. 6
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ASHBY & GEDDES /s/ Lauren E. Maguire __________________________________ Steven J. Balick (I.D. #2114) John G. Day (I.D. #2403) Lauren E. Maguire (I.D. #4261) 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, Delaware 19899 302-654-1888 [email protected] [email protected] [email protected] Attorneys for Defendant CIF Licensing, LLC, d/b/a/ GE Licensing Of Counsel: Bradford Lyerla Jeffrey H. Dean Scott Sanderson Marshall Gerstein & Borun LLP 233 South Wacker Drive 6300 Sears Tower Chicago, IL 60606-6357 (312) 474-6300 Dated: July 17, 2007
182335.1
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UNITED STATES DISTRCT COURT EASTERN DISTRICT OF TEXA MARSHALL DMSION
. FILED CLERK 'U.S. DiSTRICT COURT
lOOG WG 30 Pr-i 4: 36
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CIF Licensing, LLC, d/b/a GE Licensing,
§
§ BY
§ § § § § §
TEM,S E/"STUm
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Plaintif,
v.
§ § Case No. J- " 0 (0 CJ :5 q- y-
I
§ JURY TRIAL DEMANDED
DENSO CORPORATION, Remy International, Inc., and
Valeo, Inc.
Defendants.
PLAINIFF'S ORIGINAL COMPLAINT
Plaintif CIF Licensing, LLC, d/b/ a GE Licensing ("GE Licensing"), brings this action
againt Defendants DENSO CORPORATION ("DENSO"), Remy Interntional, Inc, ("Remy"),
and Valeo, Inc. ("Valeo"), allegig as follows:
The Pares
1. Plaintif GE Licensing is a lited libilty company organed and existig
under the laws of the State of Delaware, with its pricipal place of business in priceton, New
Jersey 08540, GE Licensing is the owner of all right, title, and interest in and to United States
Patent No. 4,733,159 (the "Patent') by assignent, with the right to recover damages for all past
iningement of the Patent. The Patent was duly and legally issued on March 22, 1988 by the
United States Patent and Trademark Offce, The invention of the Patent concern a voltage
regulator system for automobile alternators, including a unque high frequency charge pump. A
copy of the Patent is attched hereto as Exhbit A.
2. Upon inormtion and belief, Defendant DENSO is a Japanese corporation with
its principal place of business and home office at 1-1 Showa-cho, Kariya Aichi 448-8661, Japan.
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Although DENSO does business in Texas by, among other thgs, commttg act that
constitute the tort of ingement of the Patent (see, TEx, Crv. PRAC, & REM, CODE § 17.042),
upon inormation and belief, DENSO does not matain a regular place of business in Texas,
has not regitered to do business in Texas, and does not mainta a designated agent for service
of process in Texas. Therefore, DENSO may be served with process by serving the Texas
Secretary of State, who is deemed to be DENSO's agent for service of process. TEX. Crv, PRC, &
REM. CODE § 17.044.
3. Upon inormation and belief, Defendant Remy is a corporation organed and
existig under the laws of the State of Delaware, with its principal place of business and home
office located at 2902 Enterprise Drive, Anderson, Indiana 46013. Although Remy does business
in Texas by, among other thgs, commttg act that constitute the tort of ingement of the
Patent (see, TEx. Crv, PRAC, & REM. CODE § 17,042), upon inormation and belief, Remy does not
maintain a regular place of business in Texas, has not regitered to do business in Texas, and
does not mainta a designted agent for service of process in Texas, Therefore, Remy may be
served with process by serving the Texas Secreta of State, who is deemed to be Remy's agent
for servce of process, TEx, CiV. PRAC, & REM. CODE § 17.044.
4. Upon inormation and belief, Defendant Valeo is a corporation organed and
existig under the laws of the State of New York, with its pricipal place of business and home
office located at 3000 University Drive, Auburn Hi, Michgan 48326, Upon inormtion and
belief, Valeo maintain branch offices in EI Paso, TX, Fort Worth, TX, and Pharr, TIC Valeo also
does business in Texas by, among other thgs, commttg acts that constitute the tort of
ingement of the Patent and recruitig Texas residents for employment (see, TEx. Crv. PRAC.
& REM. CODE § 17.042). Valeo has not regitered to do business in Texas, and does not maintain
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a designated agent for service of process in Texas. Therefore, Valeo may be served with process
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by serving the person in chrge of its business in Texas. TEX. CN. PRc. & REM. CODE § 17.043.
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Jurisdicton and Venue
I i I
5. Th action for ingement arises under the patent laws of the United States,
Title 35, United States Code, including § 271. Th Court has exclusive juridicton under Title
28, United States Code, particularly § 1338(a).
I
6. Defendant DENSO has commtted the tort of patent inringement in the Eastern
District. Defendant DENSO has sold and shipped into the Eastern Distrct products that inge
on Plaintif GE Licensing's Patent or has sold such product under cicumstaces in which it
was reasonably foreseeable that the products would be shipped into the Eastern District.
Accordigly, Defendant DENSO resides in the Eastern Distrct as the term "reside" is defined in
28 U.s.c. § 1391(c), and, therefore, venue in the Eastern District is proper under 28 U,S,c.
§§ 1391(b) and 1400(b).
7. Defendant DENSO is subject to personal jurisdiction in Texas and this District.
8. Defendant Remy has commtted the tort of patent inrigement in the Eastern
Distrct. Defendant Remy has sold and shipped into the Eastern Distrct products that ininge
on Platif GE Licensing's Patent or has sold such products under cicumstaces in which it
was reasonably foreseeable that the product would be shipped into the Eastern Distrct.
Accordigly, Defendant Remy resides in the Eastern Distrct as the term "reside" is defied in
28 U.S,c. § 1391(c), and, therefore, venue in the Eastern District is proper under 28 U.s.c.
§§ 1391(b) and 1400(b).
9. Defendat Remy is subject to personal jurisdiction in Texas and th District.
10. Defendant Valeo has commtted the tort of patent inringement in the Eastern
District. Defendant Valeo has sold and shipped into the Eastern District products that inringe
on Plaintif GE Licensing's Patent or has sold such products under cicumstaces in which it
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was reasonably foreseeable that the products would be shipped into the Eastern Distrct.
Accordingly, Defendat Valeo resides in the Eastern District as the term "reside" is defined in
28 D.S.C. § 1391(c), and, therefore, venue in the Eastern District is proper under 28 D.S.C.
§§ 1391(b) and (c), and 1400(b).
11. Defendant Valeo is subject to personal juridiction in Texas and this District,
COUN I
(patent Iningement - DENSO)
Defendant DENSO's Activities
1-11. Plaintif hereby repeats and incorporates by reference ~1-11 as ~1-11 of th
Count i.
12. Defendant DENSO operates as a maufacturer and wholesaler of automotive
motor vehicle supplies and parts, includig alternators containg voltage regulator unts.
Defendant DENSO sell such supplies and parts to entities engaged in the automobile industr
in North America.
13. On inormation and belief, the above-mentioned activities by Defendant DENSO
have amounted to inrigement, diectly, by inducement, and/ or by contributig to the
iningement, of the Patent.
14, Plaintif GE Licening is the owner of all right, title and interest in and to the
Patent with the right to recover damages for al past inringement of the Patent.
15. On inormtion and belief, DENSO is inringig the Patent willy and with
knowledge. On inormation and belief, DENSO wi contiue iningig the Patent unless
enjoined by this Court.
16, As a result of DENSa's ingig conduct, GE Licensing has been damaged and
wi contiue to suffer irreparable harm without the issuance of an injunction by this Court.
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17. DENSOs will ingement of the Patent and other conduct make th an
exceptional case under 35 U .S.c. § 285.
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COUN II
(patent Ingement - Remy)
Defendant Remy's Actvities
1-17. Plaintif hereby repeats and incorporates by reference ill-17 of Count I as ill-17
of th Count II,
18. Defendant Remy operates as a maufacturer and re-manufacturer of origial
equipment and aftermarket electrical components for automobiles, light trcks, medium and
heavy duty trcks and other heavy duty vehicles, including alternators containg voltage
regulator unts. Defendant Remy sell such components to origial equipment maufacturers
and dealers, automotive retail chain and warehouse distributors in North America, Europe,
Lati America, and Asia-Pacifc.
19. On inormation and belief, the above-mentioned activities by Defendant Remy
have amounted to inringement, directy, by inducement, and/or by contrbutig to the
inringement, of the Patent,
20. On inormation and belief, Remy is inrigig the Patent willy and with
knowledge. On inormation and belief, Remy wil contiue inringing the Patent unless
enjoined by this Court.
21, As a result of Remy's iningig conduct, GE Licensing has been damaged and
wil contiue to suffer irreparable harm without the issuance of an injunction by th Court,
22. Remy's will inringement of the Patent and other conduct make this an
exceptional case under 35 U.S.c. § 285.
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COUN II
(Patent Inrigement - Valeo)
Defendant V aleo' s Actvities
1-22. Platif hereby repeats and incorporates by reference ill-22 of Count II as ill-22
of this Count III.
23. Defendant Valeo operates as a maufacturer of automotive motor vehicle part,
including alternators containg voltage regulator units. Valeo sell such parts to entities
engaged in the automobile industr, consistig of various divisions of vehicle maufacturers in
North America and Europe.
24, On inormation and belief, the above-mentioned activities by Defendant Valeo
have amounted to inringement, diectly, by inducement, and/ or by contributig to the
inringement, of the Patent.
25. On inormation and belief, Valeo is inringig the Patent willly and with
knowledge, On inormation and belief, Valeo wil contiue inringig the Patent uness
enjoined by this Court.
26, As a result of Valeo' s inringing conduct, GE Licensing has been damaged and
wil contiue to suffer ireparable harm without the issuance of an injunction by th Court.
27. Valeo's wil inrigement of the Patent and other conduct make th an
exceptional case under 35 U.s.c. § 285,
Requested Relief
WHEREFORE, Plaintif GE Licensing prays that th Court enter judgment,
a. Finding that Defendants DENSO, Remy, and Valeo have inringed, induced others to
inrige and/ or commtted acts of contrbutig iningement of the Patent under 35
U.S.c. § 271.
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b. Enjoing Defendants DENSO, Remy, and Valeo and their subsidiaries, agents,
officers and employees, and all others actig in concert with them, from inrigig,
j
inducig inrigement, and contrbutig to the ingement of the Patent.
c. Ordering Defendants DENSO, Remy, and Valeo to award GE Licensing an amount
that adequately compensates GE Licensing for Defendants' ingement, includig
lost profits (and/ or a reasonably royalty), treble damages, court costs, pre-judgment
interest, post-judgment interest and attorney's fees under 35 U.s.c. §§ 284 and 285,
d. Grantig GE Licensing such other and further relief as is just.
Demand tOl, Tu: Trial
Plaintif GE Licensing hereby demads a jury trl on all clim and issues triable of
right by a jury,
Dated August 30, 2006
Respectfully submitted,
BY: êJ L
(signed by permision by Oti Carroll) Bradford P. Lyerla. Lead Attorney Marshall, Gerstein & Boru LLP 6300 Sears Tower 233 South Wacker Drive
Chcago, IL 60606-6357
Tel: (312) 474-6300
Fax: (312) 474-0448
E-mail: blyerlat£marshallD.com
OF COUNSEL:
Anthony G. Sitko Marshall, Gerstein & Boru LLP 6300 Sears Tower 233 South Wacker Drive
Chicago, IL 60606-6357
Tel: (312) 474-6300
Fax: (312) 474-0448
E-Mail: asitko(1mahap.com
Jefey H. Dean
Marshall, Gerstein & Boron LLP 6300 Sears Tower
233 South Wacker Drive
Chicago, IL 60606-6357
Tel: (312) 474-300 Fax: (312) 474-448 E-Mail: jdeani¡marshallp.com
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Anthony S, Hid
Marshall, Gerstein & Boron LLP 6300 Sears Tower
233 South Wacker Drive
Chcago, IL 60606-6357
Tel: (312) 474-6300 Fax: (312) 474-448
E-Mail: ahd~marshalp.com
Oti W. Carroll
Texas Bar No. 03895700 IRELAND, CARROLL & KELLEY, P.e. 6101 South Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600
Fax: (903) 581-1070
E-Mail: Fedservl1cklaw.com
Attorneys for plaintif CIF Licensing, LLC
dlbl a GE Licensing
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United States Patent (19)
Edwards et aI.
(54) CHGE PUM VOLTAGE REGULTOR
(75) Inventors: Arur J. Edwards, Hoffan Estates,
¡1I1. Patent Number:
4,733,159
Mar. 22, 1988
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(45) Date of Patent:
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¡.
Assistant Examiner-Marc S. Hoff Attorney. Agent. or Firm-Phillip H. Melamed
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il.; Mialy Lamoth, Ccppet, Switzerlad
(57J ABSTRCl
A voltage regulator (11) provides a pulse width modulated voltage reguator output (40) to a dnve cicuit (37) to provide field coil excitation for a voltage generator
(15-17) providig a chargig signal for a batt (14).
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(73) Asignee, Motorola Ine. Schaumburg, Il.
(21) Appl. No,: 92,100
(22) File~ Oct. 28, 1986
The voltage -reguator output determes on/off states of an FBT power switchig device (28) coupled in
seres with a field coil (17) acros a maximum power source voltage potenti V BATcorresponding to batter
(51) In/. CI.' ............................................... GOSF 1/56. ¡52) U.s. CI. .................................... 323/282; 32228
(58) Field of Seach .............. 323/282, 284; 318/139; 322/28
(56) Referece Cited
U.S. PATENT DOCUNTS
3,343,06 9/1967 Ingraham .................... 323/282 X
voltage. The drve circuit includes a chage pump (26, 35, 36) with a low capacitance capacitor (26) coupled and deCoupled across a source of voltage potentia at a
rate determed by a high frequency signal (41), pro-
vided by the reguator, havig a frequency substantialy
in exces of the frequency of the voltage regulator out-
3,447,065 5/1969 Kuhn .....................,........ 322/2 X 4.210,856 7/1980 Taylor ..........................."... 320/17
4,346,337 8/1982 Watrus ....;....................... 322/25
4,386.310 5/1983 Sjevers .................................. 322/8
put. The dnve circuit includes a pai of switches (21, 35)
which alteately couple one terminal of the capacitor
to either battery voltage or ground potential in accor-
4,388,586 6/1983 Lamoth ............................ 323/283 4,388,587 6/1983 Laoth et ai. ................... 323/283
4,580,090 4/1986 Bailey et _al. ................. 323/282 X 4,636,711 1/1987 Freymuth ................... 318/139 X
dance with the voltage regulator output. The above
configuation provides a control voltage (44) at the gate battery voltage and of the PET substatialy in exces of
tms inures maximum field curent when the PET is on.
OTHR PUBLICATIONS Motorola Data Sheets XPC1500 for the 16 Ampere Logic-to-Power Switch.
Motorola Data Sheet MPC1500, Logic-to-Power
Ths is achieved with a mimum capacitance for the capacitor. thus reducing cicuit size and cost. Battery curent drai of the drive circuit is aied by disconnectig the one termal of the capacitor from battery voltage when the FET is off.
18 Cl, 2 Drawig Fies
Switch Block Diagram.
Prmary Examiner-Patrck K. Salce
r-------""Tl
V
eAT
13
I 22 23 27 0 13 -28 I r37
o
13A I
26 24
C
34
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FI
I 25
i 13B
I.. _ _ I
B
-36 33
11
r- -l
32
18
10
31 I
t6
15
RECTFIER
CIRCUIT
V BAT
13
14
L_ __ _.. 17
12
VOLTAGE REGULATOR
15
-
20
..
19 REFRENCE SIGNA
~ V'
.
V
BAT
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Case 1:06-cv-00785-GMS
Document 47-2
Filed 07/17/2007
Page 12 of 53
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Case 1:06-cv-00785-GMS
Document 47-2
Filed 07/17/2007
Page 13 of 53
4,733,159
1
2
implemented as par of an integrated circuit so as to
reduce circuit cost.
CHGE PUM VOLTAGE REGULTOR
BACKGROUND OF THE INON
SUMMRY OF THE INENTION
The present invention generaly relates to the field of 5 An object of the present invention is to provide an voltage regulators, and in parcular to voltage regula. improved voltage regulator which overcomes the
tor systems utilized to control the chargig of a battery, aforementioned deficiencies.
such as the battery in a vehicle. A more parcular object of the present invention is to
In prior voltage reguator systems for vehicles it is provide a voltage regulator which does not requie a known to provide a voltage reguator which senes 10 large magntude capacitor but which stil provides a
battery voltage and provides a pulse width modulated switchig control voltage substatially in excess of output sign that vares in duty cycle in accordace battery voltage at the gate of an PET device connec~
with the diference between sesed battry voltage and in series with the field coil that controls the output of a
a reference sign. Th output sign is us to control voltage generator which implements batt chargig.
a power switchig device conneced in sees with a 15 In one embodiment of the prest invention, an ii~
field coil acros the batter voltage potenti. The field proved voltage reguator is provided. The voltage regu.
coil controls excitation of stator widings of a
voltae lator compri: reguator means for receivig a sese
generatig system which) after rectcation of the out- voltage sign and for providig, in response to the put of the stator widings, provides a chagig signal effective comparon of said sensed voltage signal with
for the battery. Such voltage reguator systems. as de. ,20 a reference signal. a regulator output signal, compriing
scribed above. are conventional and wel Understood. pul. having a predetermed frequency and a prede.
In some of the above-noted voltage regulator sys- tered signal charcteritic determed in accordance
tern, it is necesar to provide a relatively large volt- with said comparon; dnve circuit meas coupled to
age, larger than battery voltage. at a control termal of said regulator meas and comprising a power switchig the power switching device so as to insure that max. 25 device having a control termal effectively coupled to
mum field curent is provided when the switchig de. said reguator output signal and having at least two vice is on. In some CA an PET (field effect tristor) output ternals, sai output temuals coupled in series
is utied as tle power switclùg device, with the dra
electrod co led t b It 1 d th with a control element of a voltage control means,
g h the field coil t nd 30 w? etemies sa sensed vo tage sl. ' ~cros~ a termal is connected throu0 g au maumrpower source voltage potential, sai dnve potential. In such a confguration, to provide a gate
voltage in exces of
e nnec 0 a er vo tage an e source hi h d "'d i"gn
batt voltage when it is desied to circuit mean controlling said sensed voltage. via said
have the PET on, a prior voltage regutor system has control mean. in accordance with said characteristic of
utiized a voltage doubler circuit. In the prior voltage said regulator output signal to mainta said sensed. doubler cirC1t. a voltage of approxiately twce bat- 35 voltage signal at a predetered voltage level detertery voltage is seectively provided at the gate termnal mied by said reference -signal. said drve circuit means
to insure that approxiately the entie batter voltage including a peak 'Voltage increaing mean for receiving
potential is applied across the field coil when the PET said reguator output signal and- effecvely providing in
is ,OD. response thereto a correspondig increaed magntude
The voltage doubler circuit of the prior voltage regu- 40 voltage sign generally varing as said regultor out.
lator relies on utilg the pulse width modulted out. put signal but varg up to a peak voltage potential in
put signal of the voltage reguator to selectively couple exces of said maxum power source voltage potenti,
and decouple a lage magnitude capacitor across the wherei the improvement comprises said peak voltage
battry voltage potenti via a switch device. The end . increasing meas compring a capacitor selectively
result is tht essentialy a voltage doubler is provided by 45 series coupled and decoupled across a predetermed
the capacitor and the selective switchig of the capaci. power source voltage potential in accordance with
tor across the battery voltage potentil. However. in pulses of a high frequecy sign having a pulse fre~
such a conftion. a ver large capacitace for the quency substantially in exces of the frequency of said .
capacitor is utiled to insure that at high duty cycle regutor output signal said peak voltage increang percentages of the voltage regulator output signal. the 50 meas, therefore. compriing a high frequency charge
voltage across the capacitor does not substatially de. pump which provides said increaed voltage signal, said
crease dwig the long em-duty cycle ard thereby de- inreas vóitage signal having the sae general wave~
'creae the magntude of the voltage at the gate e1ec- form as said reguator output sign but increasd in
trode of the FET. Whn the prior' voltage regultor voltage magntude to achieve a peak voltage potential
produced an output signal which esentiy resulted in 55 in excess of sad maxum power source voltage poten.
the PET being on al of the tie since field coil current tial. the charge pwnp providing said increaed voltage
was requied al of the tie, additional complex logic s.ignal as an output which is coupled to sad control
circuitry was required to provide some altete cou- termal of sad power switchig device. the capacitor across the battery. Essentialy, the above-recited confgution results in pIing and decouplig of voltage, and th increasd the circut cost. Without this 60 utiization of a relatively smal magnitude capacitor logic cicuitry. the twice battery voltage to whie sti providing a switchig voltage at the control additional
be maitained at one teral of the large capacitace termnal of the power switchig device that is substan.
capacitor would decease due to leage effects and the tialy in exc of the maxum power source voltage
loading of the tued-on PET device. Th is undesr. potentia which preferably corresponds to battery volt. able as it would result in reducing field coil curent 65 age in the vehicle chargig system. Preferably, the when the voltage regulator has indicated that maximum power switchig device comprises' an N chanel field field coil curent should be provided. Also, the required effect transistor (PT) in which the gate electrode is
l~ge magnitude capacitor is expensive. and it cannot be the control terminal the drai electrode is connected to
Case 1:06-cv-00785-GMS
Document 47-2
Filed 07/17/2007
Page 14 of 53
positive battery voltage and the source electrode is tor ar field, and can be implemented by a number of
3 4
4,733,159
connected though a field coil to ground potential. dierent circuit confgurations for the voltage regutor
Preferably, the voltage regulator mea output signal 11. The constant frequency regulator disclosed in U.S.
comprises a pulse width modulated switchig signal Pat. No. 4,386,310 to Sievers. assigned to the same as~ the capacitor, 5 signee as the present invention, can be used for the which selectively couples one termnal of
at which sad increased voltage sign is provided. to above described voltage reguator 11. Also see U.S. Pat.
ground durg one polarty of the duty cycle of the Nos. 4,388,586 and 4,388,587. Essentially, the voltage reguator output signal and durg another polarty of reguator system 10, as is understood, responds to the
the regulator output signal couples thi termal to bat. pul width modulated switchig output signal at the tery voltage. 10 ter20 so as to provide field coil current such that
Preferably the high frequency switchig signal is at the battry voltage at the term13 is maintaed at a
lea two orders of magntude higher th the fre. predeteed voltage with respect to the voltage magquency of the reguator output sign, and.ths results in nitude of the reference signa at the temi 19. This
requig only a ver smal capacitace for the seec opeation is conventional.
tively se coupled capactor thus reucing compo lS Estiy, the present invention involves providing nent cost and siz Th also pets synthesg the a drve cicuit mea so as to couple the pule width
capacitor as part of an integrated cicuit wmch includes modulted re~ator output sign at the termal 20 to field coil 17 so as to control field coil curent excItaother regulator components. In addition, the present the,
invention contemplates utiizg the puls width modn- tien. Th is accomplished in an advantageous maner late output signal of the regulator anda.swith device 20 by a relatively simple and economical drive circuit to alterately couple and ,decouple the capacitive term- utig inexpesive components. The coiistrction and na at which the increased voltage is produced to bat- operation of the dnve cicuit meanis conneCted through is as follows. 13
tery voltage, and this mis battery current drain The battery voltage term
durg duty cycle portions of the reguator output sig- a resîstor 13A to the emitter of a PNP first switch de-
na durig which no field current is desired. Al, this- 2S vice trans'istor 21 which has its collecor coupled iniies no substati battery curent drain when the though a diode 22 to a termal ~ also designated - as voltage regulator is off and a low voltage regulator termal D. The emitter of transiSior 21 is coupled to
output sígnal is provided. ground through an effective 20 volt 'Zener, diode 13B
~X:'. _ and coupled through a resîstor 24 to a termal 25 also
.c"._ For a DESCRIION OF TH DRAWINGS 30 designated as connectedrelativelythe termals C and :;;c BRIF more complete underding of the invention, capacitor 26 is leti C. A between smal magntude
._. _reference should be made to the drawigs. in wlnch: D wherein the capacitor 26 has a tyical capacitace
FIG. 1 is a schematic diagram of a voltage regulator magntude of 50 picofarads.
, : systm constrcted in accordance with the present in~ The teal D is connected through a diode 27 to a . vention; and 35 gate elecrode G of an N chanel PET transistor 28 .. FIG. 2 comprise a series of graphs A though F wherein the gate electrode is also desgnted by the
~::ilustrting waveforms of signals provided at th teI- terminal E. A drai electrode'D of the FET is directly
. Äl: A thugh F in FIG. 1. connecte to the battery voltage termal 13, and a source electrode S of the FET corresponds to a term-
DESCRION OF TH PREFERRD 40 nal F. A Zeaer diode 29 is connected beiween the leni-
,:1;1:::0".
EMBODIMENT nas B and F to ine tha no exceve voltage can be
input capacitace- of the FET is i1us~
the gate and source electrodes which ilustrated in which a substantialy conventional pulse would cause destrction of the PET.-, In FIG. I, the
Referg to FIG. 1. a voltage regulator system 10 is applied between width mod~ated voltage regulator 11 has a voltage efective internal
seing input terin 12 connected toa positive batt 45 trted as an inerent capacitor 30 connected between 13 also designated as V BAT. The term- the gate and source electrodes and having a typica voltage termal
nal13 corresponds to the positive electrode of a vemcle magntude of 100 picofards. The PET 28 is utiized as
batt 14 whích has its negative electode conneCted to a power switchig device tht controls curnt in the
grund potenti. Chargig of the batt 14 is accom~ field coil 17.
plihedbymeaofaplurtyofstatoroutputwidigs 50 The source electrod' of the PET is connected
15 which provide an _output that is reatied 'by a recti- though a cuent sensIng restor 31 to a teal32 at
fier cicuit 16. The output of the stator widigs 15 is which one end of the field coil 17 is conneced and a
controlled, as is conventionaly undertoo; by the cur. cathod of the t1yback diod 18 is connected. Another the diode 18 are
rent excitation applied to a field coil 17 havig a flyback end of the field coilI7 and the anode of
transient suppresion diode 18 connected thereaçross. 5S connected to ground potential.-The amount_offield co~
Esntiy, the voltage acros the battery is sense by curent being drawn 'can be meaured by notig the
the voltage reguator 11 vi the
signal at the teral 12. voltage drop acroSS the resstor 31, ü desired With thi
The voltage reguHitor compares ths voltage to an inte- confgution the output electrodes (dtai and source)
na or external reference voltage_signaI provided at a of the FBTare connected in sees with field coil
17
termal 19, aid in respons to thi comparn pro- -60 betwe,en a maxum power source potential correduces a pulse width modulated reguator output sign spending to the battery voltae.
at an output termal 20. The duty cycle of thi pulse The pulse width modulated regulator output
signal at
width modulated output signal at the termal 20 can the tenninal20 is connected to a tenninal33 also desig..
var from approximately 0% to 100% and is esntialy nated as termal A. Ths terminal is.connected though
detened in accordance with the dífference between 65 a level shifter or isolation device 34 to the base elec': the sese battery voltage and the reference signal at trode of the fist switch device tranistor 21. The tenn-
19. Ths is accomplished in a conventional na33 is also connected directly to the base electrode of maimer as is understood to those in the voltag" regula- an NPN transistor 3S which compries a thrd switch
the termal
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Page 15 of 53
device tristor having its emtter connected to ground Esntialy, in respOnse to the high and low outputs
5 6
4,733,159
and its collector connected to the termnal E. An etTec. provided at the termal 20 by the voltage regulator 11, rive 40 volt Zener diode 3SA is conneced between the the first and thid switch transistor devices 21 and 35,
collector and base electrodes of the transistor 35. A wil be alternately opened and closed. More specifisecond switch device transtor 36 compriing an NPN 5 caly, in response to a high signal level at the terminal transistor has its collector connected to the termal C, A, transistor 35 will be turned on, therefore grounding
its emtter connected to ground potential and its base the gate electode of the FET and litig the voltage electrode connected to a teral B which.is contem- at the teral D to only one this high ~ignallev~l at the diode drop above ground
plated as being an additiona output termal of the potei;tial. At ~he sae time,.
voltage regultor 11 at which a very high frequency 10 t~ A.. via the level s~er 34, ~il result in effecswitchg sign is provided. It is contemplate that the tlVely tug ofT the fit switch dC:V1ce 21 and thereby
high frequency switchig signal at the te B is a deC?uple th~ battery. voltage te:mal 13 fro~ the caconstat frequency signal havig a frequency of
200 to pacitor term D via the trasistor 21 and diode 22.,
300 küohert, as contrasted with the frequency of the Dung the tie that a high or positive logic level .IS
pul width modulted reguator output sign at the 15 pres~t at the teral A. ~d even wh~ a low loglc teral 20 which has an output frequency of 50 to 70 ~ve1 IS p.resent . at theprovided high f~equency 41 ts contiuously te~ A. a at the teal B as
her sign
The operation of the voltage regulator system 10 in ilustrate, in graph B in FIG. ~. The si~al 41 is not
. .' necessy ccnunuously provided dung the duty
i:G. 1 wil now be dis~ussed with reference to ~e 20 cycle polarty 41A of signal 40. Ths high frequency
signal waveform shown in the grph~ A through F in sign contiuay results in turnng the transistor 36 on ~IG. 2. It .should b~noted that the signal waveforms and off and, therfore. alternately connecting the termiilustrated 10 FIG. 2 in graphs A through F correspond al C t d t "I d th a ent' g this' cannee
to e vo ~ge waveiorms 0 e ectn . sign. s provi e tion. When a positive signal
th I 'f I 'ca' al 'dd n .ogroun poen..aan providedp an level is en at termi. at thete~s A though F..respectively. in FIG. 1.. In 25 nal A. the openig and closing of the transitor switch
the ~phs in ~G. 2, the vertical ~ are ~epresentaüve 36 results in providing a corresponding ramp signal 42 of Sigial mas,tude. and the honzontal axes are r~re- at teral C as ilustrted in grph C in FIG. 2. Durig
sentativ.e. of ti7, It should alo be .noted that the .time the tie that the transistor 36 is on, terinal C is eonØ
scae utilize~ to ilustra~.e the ver high fre~uency ~ignal neeted to ground potential, but when transistor 36 is off, at the termal B~ and its affect on other signals, is ~ot 30 the potetial at termal C rises due to a charging cur~rawn to scalewith r~gad to the much slower varyig rent provided from the battery voltage terminal 13
s~gnal of the puls; width modulte regator. output though the resstor Z4, Typically,.the peak of thi
ramp
sign~ at the termal 20.correspondùg to the Sign at sign durg a positive logic state at the tenal A will
te~al A. Ho~ever, tl has b~en done to enhce the be approximately 2.5 volts less than the battery voltage
. M shown m. FIG. 2, the v-Ol.tage reguator 11 ~ro- approxiately 1l.5 vides a pulse width modulated signal volts is the magntude of the
clanty of the .Figues as IS readiy understood. . 35 at the terml 13. which is typicaly 14 volts. Thus.
voltage
40 at the tenal pe of the signal 42 for a positive logic state at the
A wh~ein ~e duty cycle of ~ si~ is vanable and is teral A which corresponds to no field current beig
deteed m accordace with the di~rence beteen conducted. Durg ths same tie, a relatively smal
the sese batter voltage at the teral 12 and the 40 magntu squae wave varyig at the same frequency 19. Duris a as the high frequency signal 41 is at the terminal.D r~ference si~ voltase at the te the duty cycle porton wherein the signl at the teral D is generaly desigø high, or poSitiVe, polanty 4iA of
of the signl 40. no field curent will be drawn, but nated by the reference numeral durg the low, or negative, polanty 41B of the duty magnitude of cycle of the signal the signa143 when a positive logic state
43 in graph D. The peak is
40, field curent wil be provided so 45 at the termnal A is approxitely + 1 volt since at that
40 ilustrte that tie the tranistor 35 is on and the peas of signal at the
as to chage the batter 14. The signal
at a reference tie to there is a high to low trtion terminal D are limited by the clipping action provided
indicag the commencement of a low state for the . by the diode 27. Typicay, a slight negative voltage is
sign 40 durg which field curent wil flow. The provided at the term D when a positive logic state is 40 is tyicay betwee 50 to70 50 present at termal A and the trsistor 36 is tued off. frequency of the signal
hert, and the duty cycle ca var betwee extreme Since a positive logic state at the ter A tu the
percentages such as 0 to 100% depndig upon how transistor 35 on. ths mea that at this time the gate
much field curnt the voltage regutor 11 detennes electrode of the FET is at grund potetial. and, there-
is nec. fore, the PET is turned off. Whe the PET is tured by virte off, 17
In generatig the pul width modulated sign 40 at 55 field curent wi not flow in the field coil
the tenal20, it is contemplated that the voltage regu. of power (curent) supplied by the batter 14. A signal FIG. 2 ilusates the voltage waveform lator may interny use a very high.frequency reference 44 in graph E in
oscilator. Alteatvely. a separte high frequency refø for the signal at the gate electrode of the PET, and a
erence oscilator may be provided with .the voltage sign 45 in graph F in FIG. 2 ilustrates the voltage reguator 11 even though th sign may not be'utiized 60 waveform at the source electrode of the PET. The
to generate the pul width modulated reguator output sign~s at the terminals F and 32 are identica, except for sign 20. In either event, the voltage regulator 11 pro- a mior voltage shift in case field curent is flowig due vides at the termal B a very high frequency signal to. the drop across the resstor 31. Thus a graph of the
comprising a series of pulses wherein the frequecy is signal at term 32 is not provided.
200 to 300 kiohert. This is generally shown in graph B 65 Essentialy, prior to the time to shown in FIG. 2, there' in FIG. 2, even though the time scale for grph B does is no field coil current because the FET 28 is turned off.
not corrpond to the sae time scale utiized for graph At the time to. the transistor 35 which was previously
A. on, is now tured off, thus removing the clamping ac-
Case 1:06-cv-00785-GMS
Document 47-2
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Page 16 of 53
tiOD provided at the gate electrode of of the
7 8
4,733,159
of the transistor21 and 44 has a 10 tery
the FET by virte rentsliould be provided. Th is accomplished by the
trasistor 35 and diode 27. At the same tie, since present circuit providing approxiately battery voltage
a low or negative logic state is now provided at the V BAT at the source electrode of the FET. voltage must In order to
teral A. the transistor 21 is tured on via level shier accomplish this, a much higher than V BAT
34 resultig in applyig approxitely battery voltage 5 he provid.ed at the gate of the N chanel FET to insure
at the termal D by vire
diode tht the FET turs on and remai on since there is a
of the FET can
22. Ths is ilustrated in the graphs in FIG. 2 by the mium gate-to-source threshold which must be ex. abrupt riing ~anent pret at the tie to in the sig- ceeed in order for the PET to be on. The present
nas 43, 44 -and 45. Immediately afer to the signal a magntude of VB AT-l diode drop, sign voltage control signal at the gate
43 ha invention is concerned with how th lager than batbe
magntude ofVBAT-2 diode drops. and sign
45 ha a produce. effciently and with mium expense. It 17 is
magntude of approxitely 7 volts_ represetig the should be noted that the reason that the field coil dierence betwee the signal
44 at the teral E and not provided in the drai circuit of the FET, is that
the gate-to-urce tur..n threshold develope across many voltage reguator systems do not wih to subject
the PE 28. lS the field coil to constat positive voltage potential even
Af the tie to the transistor 36 contiues to be when no field current is to be drawn Thus, in the pres-
switched on and off at a ver rapid rate in accordance ent circuit, the field coil is in the source circuit of the N
with. the pulse of the high frequency signal 41. Ths chanel PET, and the FET estialy acts as a source
results in only a slight change in the pea magntudes of , fonower. Also, an N chanel FET is us since P chao-
42 at the termal C, and thi slight increae in 20 nel PETs are substatially more expenive. ma~tude is due to the fact that the claping action of The presnt invention essentiay provides the apthe signal
the diode 27 to ground potential though the transistor. proximately twice batter voltage signal at the gate of
35 has now been removed. However, the signficace of the PET when it is desired to commence field current. contiuig the high frequency switchig after the time Ths occurs by use of the at the frequency and the use 41 high termnal B switching
to is marc evident in the signals 43 through 45. For 25 provided by the signal
signa143, it is note that what esntialy happens is that of a relatively smal magntude capacitor 26. Ths is
the ramp signal provided at the t,ermal C is now effec- contrasted with pnor voltage regulator systems, which tively tranferred to the terinal D and supenmposed whie recogng that a high gate voltageslow swtchig relatively is desirable, .,.~'ùpon a DC level of approxiately the battery voltage implemented th by utiizg capacitor to form a .
'~~V BATat tle term13 mius the series drop across the 30 speeds with a ver large magntude
'.-tranistor 21 and diode 22. Th esentially results in the battery voltage doublig system. Those prior systems ..J signal 43 reachig pe magntudes of approxitely were not cost effective in implementig field current for
~::1wce the battery voltage sice the AC varation of the 100% of the time, beause they requied utiization of
~signal42 is now effectively superipose on a DG level extensive additional logic cicuitry required to provide
...of approxiately battery voltage. 35 some perodic interrptions (in cas a 100% duty cycle
In response- to the signal 43, the diode 27, -and the was required) for chargig the large capactor. In addi;."etTectve input capacitace 30 of the FET effectively tion, the prior sysms requied an extremely large mag":~~provide a pe rectcation circuit such that the signal nitude capacitor 26 tó insure that there was not a suhn~~estiy follows the envelope of
the sign pe of stantial decrease in the voltage beig maitaned at the
termal D afer commencement of field curent flow. ::G ilustrated in graph E in FIG. 2. The signa145 at the The prest invention avoids thes problems by imple. ':;~tSource electre esntily tracks the -gate voltage and, menting very rapid switchig vi the -trnsistor 36 and, therefore alo increas, but the'maxWD value of the therefore can utilize a ver small capacitor (typically 50 signal 45 is achieved at battery voltage_ since this signal picofarads), for the capaCitor 26. Th enhances circuit
,.~the sigi431es the voltae drop ,acoss diode 27. .Ths- 40
caot exceed the drain voltage wherei the drai e1ec- 45 performance and reduces circuit cost; In the present trode is diectly connected to the relatively constant circuit. rather than relyig on the massive capacitace
voltage VBATat the batter voltage teinal
13. How- of the capacitor 26, now the inerent. gate-ta-soutee
ever, as sen in grph F in FIG. 2, the sign 45 does capacitace of the PET 28 can be relied on to maita
increa from a voltage somewhat below battery volt- an approprite voltage at. the termal E durg, field age'to approxitely batter voltage durg the tie 50 current flow, and thus no additiona large capacitor is
tht field curent is flowing. Ths mea tht maum requied. The small size of the capacitor 26 maes it
, pole field current is_ provided durig the tiie tht a possible to synthesize, on a .sigle integrated cicuit
low logic' level is provided for the ,signal 40 sice the chip, substatiy al of the components of a driver
source. voltage of the PET wi now reach approxi- cicut 37, shown dashed in FIG. 1, and the regulator
.rnately battery voltage due to the effective saturtion of 5S 11, except the FET 28 and the resistor 31.
the FET device 28. Th is possible in the presnt inven- In addition to the abve advantages, the .present in-
tion sice ,the.gate voltage is matained in exce of the vention mies 'battery curent drai durng a condibattry voltage V BATpresnt at the dr elecrode and tionof no field curent flow. This is becaus the- switch
th situation is required in order to mata th PET in 21 wil effectively decouple the capacitor termal D
an on condition with the source at V BAT. At a subse- 60 from
battery voltage when no field cuent is,requied.
quent titx, the sign
40 undergoe a logic state in. If the transistor 21 were replace by a direct comiection
13,
version resultig in the tug off of field current, and between the anode of the diode 22 and the termnal
ths is matained unti a subsequent tie ti at which then there would have to be some provision to prevent
tie the tu-on cycle is reistituted. excessive battery cuent dran because of the shortg
Esntially, the present invention is concerned with 65 action provided by the transistor 35 and additional leakproviding a voltage as high as possible at the tenninal F age current asociat~d with the FET. when this device
such that maxum field coil current can be drawn is off and no field curent is drawn. These problems are
when the voltage regulator 11 indicates that field cur- avoided by utilization of the transistor 21 which is
Case 1:06-cv-00785-GMS
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switched alterately with resect to. but at the same 2. A voltage regulator according to claim 1 wherein
9 10
4,733,159
frequency as, the tranistor 35. Thus trnsistor 21 pre- sai predeterned characteritic of sad regulator Qutvents series coupling the capacitor 26 between V B.4Tat put signal, which characteritic is determed in accor-
teral 13 and ground durig duty cycle portons 41A, dance with said .comparson, compnses duty cycle.
and permts such coupling durg 41B, and ths reduces 5 3. A voltage regulator according to claim 2 wherein
battery current drai. Also, ths insues no substati sad drive circuit means includes mean for selectively
batt curent drai when the voltage reguator is off, preventing sad series coupling of said capacitor across
and, therefore, a low voltage regulator output signal at sad predetennined power source voltage potential durtermal 20 is provided. The effective Zener diode 13B ing duty cycle portons of said regulator output signal of
prote the transtors 21 and 36 from excessive battry 10 a predete polarty and permttg said series cou-
voltage traients causd by batter load vartions~ and pIig durg duty cycle portons of said reguator outthe effective Zener 35A protects the tranistor 3S put signal of an opposite predetermed polarty.
agaist transients at the te E. 4. A voltage reguator acordig to clai 3 wherein
Whe specifc emboents or the prest invention said predetermed power source voltage potential that
have been shown and desbed. fuher modcations. 15 said capacitor is selectively series coupled and .decou-
and improvements wi occur to those skied in the ar pled across substatialy compries sad maum Al such modcations which reta the basic underly- power source voltage potential tht sad power switching priciples _disclosed and claied herein are with ing device and control element of said voltage control
the scope of th invention. mean are coupled across.
We clai: 20 S. A voltage reguator according to claim 4 wherein 1. A voltage regulator compriing: the frequency of said high frequency signal pulses is at
regulator meas for receivig a sensed voltage signal least one order of magntude higher than the frequency
and for providing. in response to the effective com- of said regulator output sign.
pason of said sensed voltage signal with a refer- 2S 6. A voltage
reguator accrding to claim 5 wherein
euee sign, a regulator output sign. compriing said preventig means of said drive circuit means inpulses, having a predetermed frequency and a cIudes a firt switch device which selectively couples a
predetermed signal characteritic detered in fist terml of sad capacitor to a fist predetermined
accordance with sad comparon; voltage in accordance with duty cycle portons of sad
drve circuit meas coupled to said reguator mean 30 reguator output signa of a predetermned polarity and
and comprig a power switchig device havig a decouples sad first termal during duty cycle portions
control ten efectively coupled to sad regua- of said reguator output signal of an opposite predetertor output signal and havig at leat two output mied polarty, and wherein said p~ak voltage increastermals. said output teriinal coupled in series iig meas of said drive circuit means includes a second
with a control element of a voltage control mean 3S switch device which selectively series couples and dewhich determes sad sensed voltage sign. across couples a second terminal of said capacitor to a 5~cond
a maxum power sour voltage potentil, sad predetenned voltage. diferent from said first prededrve circut meas controlliig sad sensd voltage, tered voltage, in accordance with said pulse öf said
vi said control mea. in accordance with sad high frequency sign. chartestic of sad regulator output sign to 40 7. A voltage reguator according to clai 6 wherei
maita sad sensed voltage sign at a predeter- sad drve cicuit meas includes a. third switch device
mied voltage level deteI1ed by sad reference which selectively couples and decouples said one ca-
signal, said drive ciruit mean including a pea pacitor temual to'said seond voltage potential in
voltage increaing meas for receiving said regua- accordace with said regulator output sign. .
tor output signal and effecvely providing in .re- 45 8. A voltage regulator according to claim 1 wherein
sponse thereto a corresponding increaed magn- sad drive circuit means includes a first switch device tude voltage signal generaly varing as said regu- which selectvely cOllples a first terinal of said O8pacilator output signal but varg up to a pea voltage tor to -a firt predetrmed voltage in accordance with potential in exces of said maxum power source duty cycle portions of said regulator output signal of a voltage potential. 50 predetermed polarty and decouples said firt tennal
wherei the improvement compries sai pea volt- durg duty cycle portons of said regulator output
age increasing mea comprising a capacitor se1ec- sign or an 9Pposite predetermed polarty, and
tively series coupled and decoupled across a prede- wherein said pe voltage increasing mean of said
tenned power source voltage potential in accor- drve - circuit meas includes a second switch device
dance with pul of a high frequency sign havig 55 which selectively seres couples and decouples a second
a pulse frequency substatialy in 'excs of the ter of said capacitor to a second predetermed
frequency of sad regulator output Signal, sad pe voltage, different from sad fit predetermined voltage,
voltage increasing means. therefore. comprig a in accordce with said pulses of sad high frequency
high frequency chage pump which provides sad signal.
increased voltage sign, said increaed voltage 60 9. A voltage regutor accordg to cla 8 wherein
sign havig the same genera waveform as sad said drive circuit means includes a thrd switch deVice
regulator output signal but incread in voltage which selectively couples and decouplessaid one 08magntude to achieve a peak voltage potential in pacitor terminal to sad second voltage potential in
excess of said maxum power source voltage accordance with sad reguator output signal. potential, the charge pump providing sad in- 65 10. A voltage regulator accordig to clai 9 wherein
f:reased voltage signal as an output which is cou- said first capacitor termal is coupled to said power
ing device. fying diod.:
pled to sad control terminal of said power switch- switching device control teral through a peak recti':
ii
Case 1:06-cv-00785-GMS
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II
I
11. A voltage regulator according to. clai 10 15. A voltage reguator accordig to clai i wherein
wherin said fist predeteed voltage is coupled to said voltage còntrol mea compries a voltage genera-
11 12
4,733,159
I
said fist capacitor termal though a diode. tor means and wherei said control. field coil. of said a element
U. A voltage regulator according to claim 11 voltage control meas 16. A voltage 5 compries
regulator according to claim 15
wherein said power switchig aevice comprises an wherein said voltage generator means includes stator
FET having gate, drai and source electrodes corre- windings, in addition to said field coil, and a rectifier spoding to said control and output term, respec- circuit means - for receivig the output of said stator
tively. _ windings and providig-a chargig signal for a battery
13. A voltage reguator accordig to clai 12 10 _ so as to maita a predetermed batter voltage there-
wherei sad dr electe is. coupled to a source of across.
constat voltage poteti and wherein the effective 17. A voltage reguator according to clai 16
interal capacitce of sad PET between said gate ,and wherei sad predetered voltage across said battery
soure elecodes is subtatialy larger th-the capaci. corrponds to sad predtermed maxum power
o f 'd r. . sour voltage potenti. tace sa capac"to. 1518. A voltage regulator according to cla 1 wherei
14. .A ~oltage reguator accordmg !O clai 13 the frequency of sad high frequency pulses is at least wherem sad voltage contrl mea compns a voltage one order of magntude 'higher th the frequency of
genertor mea and wherei sad control element of sad reguator output signal. .
sad voltage control mea compries .8 field coil. 20 * * . * *
'25
30
35
40
45
50
5S
60
65
Case 1:06-cv-00785-GMS
Document 47-2
Filed 07/17/2007
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UNITED STATES PATENT