Reply Brief in Support of KSR's Motion for Summary ... - Fried Frank

5adjuster member utizig the guide blocks 30 and 34,adjuster scrw 54 is selectaly adjuste to bring toe portons52b into engagement with the lower edges 18h of the sideplate portons 18a of the adjuster member so as to tae upany slack in the sliding assembly of the peda an on theadjuster member and preclude relative anguar movement ofthe ped ar relative to the adjuster member, therebyelimitig any anoyig wobble of the peal ar relativeto the adjuster membe and any resultat rattg noises.ea member 22 (FGS. 2 and 4) include an upwardlyextendig forward porton 22 pOsitioned between adjustermember porons 18k and pivotaly mouited on a pin 50extendig between the upper ends of adjuster member sideplat portons 18k; a lower ar slot 22b; and an upwardlyextending reard porton 22c mountig a pivot axs pin 60(FG. 3) includig portons 60 extndig lateray fromeach side face of the cam membe. Each pin porton 60a ispositioned in arcuate slots 18e and 16c of a respetiveadjuste member porton 1M and bracket poon 16b.Link 24 is pivotaly mounted at its rearard end 24 to theuppe porton 2òa of the pedar above nut 38 as, forexample, by a pi 62 and includes a cam pin 64 mounted onits forward end 24band camgly and slidaly received incam member slot 22b. Lin 24 includes a cr porton 24cto accomiodte the latera displacement of the cam platerelative to the peal ar.Cable 46 is drvigly secured to one end of the outputshaf 66a of a small elecc motor 66 (FG; 3) seured to thedash panel 14 of the vehicle between bre peal assembly10 and accelertor pedàl assembly 12.It wil be seen th eIiergation of motor ,66 results inrotation of cable 46. The rotaon of cable 46 is conver bytrmission device 42 into rota movànent of screw 40wmch in tu coacts wtti nut 38 to produce liea or slidigmovement of pedal ar,' 20 along adjuster member 18 toselectively adjust the position of pe pad 28 relative to thedrver. As the pe ai moves fore and af reiatveto theadjuster member18, th li 24 is moved fore and af tomove cam pin 64 in ea plate slot 22 so as to selectivelypivot the ea plate abut th axs of pin 50 and selectivelymove pivot axs pin 60 upwardly and downwary in algnedarcuat slots 18e, 16c so as to selectively adjust the pivotaxs of the pe ar and the adjute member as the positionof the ped ar is adjusted relatve to the adjuster member.The viuous pareters of the apparat ar pieferly 45chosen such that the movement of the pivot ax,in responseto adjustig movement of the peal ar on, the adjustemember ha the effect of maig a substatialy constatratio between the distace from th pivot axs to thepeal pad and the distace frm the pivot, axs to the 50atthment point of the braeactuon ro 48 so as tomata a substatialy unor mecJical advatage andrelÙtat feel for th bre ped assembly iiespetive of thememb,er S5adjusted position of the pe ar relative to the adjusteAcce1eor pe assembly 12 (FG.1) includes a braket70, an adjuster member 72, a pedal ar 74, and' a eamember 76. Al of the members, uness otherwise indicatedar formed of a suitale ferous maal.Brackt 70 includes a base porton 70a secued to the dahpaneltion.14 in latery space relation to the65brae peæsembly and a pai of side plate poons 70b extendigrearardly from base porton 70a in lateraly 'spac rela-Adjuste membe 72 (FG. 6) includes spaced side plateportons 72a jo~ at a reard end wal 72b. One of the5,460,0616side plate portons tla includes a forward upwardly extendingporton 72c definig an atthment flange porton 72d atits upper end for atthment of the accelerator contrl cale78. A guide pin 80 proximate the base of upstadig porton5 72c guides in an arcuate guide groove 70c in one of the baseside plate portions 70b. Each of the side plate poons 7ladefies an aruate ,generally vertcaly extndig groove 72eproxite its forward end which is vercally aligned with,and correspondig in configution to, an arcuae groove10 70d in the assocate bracket side plate porton 70b.'Peda ar 74 (FG. 10) has a hollow reaardlyopenigU-shape èonfgurtion in cross section and includes anupper porton 74a positioned between adjuster member sideplate portons tla and a lower porton 74b definig a loweris end 74c (FG. 6) for pivota or fixe athment of anaclerator peda 82. A pai of upper guide blocks84 arpivotay positioned on opposite sides of the upper porton74a of the pe ar by a pin 86 passing though the pear and a pai of lower guide blocks 88 ar pivotay20 positioned on opposite sides of the upper porton 74a of tbepeda ar by a pin 90 passing though t,e peda block. Eachupper guide block 84 defies a downwary openigU-shaped grove 84 slidably engagig th upper edge 72/(FIG. 6) of a respective adjuster membe side plate porton25 tla and each lower block 88 defies ai upwardly openingU-shaped groove 88a slidably engagig the lower edge 72g(FG. 6) of a respective adjuster member side plate porton72a. Upper and lower gude blocks 84 and RS wil be seento mount the peal an for selectve sliding fore and af30 movement along the adjuster membr, 72 to adjust theposition of the aceleraor pedal 82 relative to the drver.A plastic nut 92 (FGS. 9 and II)) is fixedly positionedbetween the space side wals 74dof the upper end of thepe ar and includes a thded b()Ie 92a theadably35 reciving a screw member 94 secured to the output shaf ofa tranmission device 96 (FG. 6) suitaly secured to one ofthe side plate portons 72a of the adjuster member andincluding a cable iIput fittg 96, Jecivig, a cable 98connecte to the other end of the output sha 66 of electrc40 motor 66 (FG. 3). Tranmission device 96 may be identica. to the trsmission device 42 of the brae pe assembly.It wil be seen tht energiaton of motor 66 provides rotacable movement to the aclertor assembly 12 which isconverd to rotar movement of screw niember 94 bytrsmission device 96 so as to move the pe an fore andaf slidably along the adjuster member to Selectively adjustthe position of accelerator peal 82 relatve to the drver.A slack taeup device 100 (FGS. 6, 7, Sand 18) ispositioned at the intersecon of the upper en 74a of thepear and the adjuster meiber. Slack taup deVice 100inèlude a braket 102 secured as by weldig to the re face74e of the ped ar immedately below the inrsection ofthe ped ar and the adjuster member, and a plastic block104 including a groove l04a receivig the ~ard end,porton 10la of brket 102 so as to position the blocl 104in underlying relation to the adjacnt porton of the adjustemember. Takeup assembly 100 fur includes a pai ofplugs 106 reeived in a pai ofvercal bore 104b in block104 and includig ratchet teeth 106a. Plugs 106 may, for60 example, be of the type avaiable frm Pen Engieenngand Manufuctg Company of Danbcro, Pa as Par No.NPPA~M5. Followig the a&Stmbly of the pe ar to theadjuste member to mount the pedi ar slidably on theadjuster membr, plugs 106 are inert upwary though, bores 1,06a until the upper ends 106b of the pl\lgs engage thelower edges 72g of the sidear portnns tla of the adjustrmembe so as to tae up slack in the pe an,and adjuste