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

565,063,811FIG. 1 to the wide-open-throttle position as represented computerized control (not shown) that there is a malinphantom line in FIG. I, the secondary peçlal blade function or a concern to be acted upon.wil translate the control rod 124 over an axial travel . The follower member 220 comprises a pair of annspath indicated at 126. The control rod 124 as controlled 266 and 268. Each is connected to the other as a rigidby the secondary pedal blade can either operate or be 5 structure by pins 270. At one end of the follower memoperatedby mechanism components outside the vehicle bers, 'there is provided a car follower in the fonn of acab, e.g., mechanically modulated automatic transmis- roller 272 rotatably mounted on a pin 274 which extendssions. though the slot 234 of accelerator pedal flange 230.In FIGS. 6-8, there is shown an alternative embodi- The cam follower bers against earn surface 232 in thement to the accelerator pedal assembly. 10 same manner as described previously in connectionThe accelerator pedal assembly 200 includes with the embodiment shown in FIGS. 1-5.sae basiC components, namely, an accelerator pedal The follower member 220 is spring biased by torsion210, a base bracket member 212 having a housing por- coil spring 276 in the idle position as shown in solid line276 istion 214 with a rotay potentiometer 216 and idle vali~ in FIG. 6. For purposes of clarty, the springdation switch 218 mounted thereon, and a spnng biaed 15 omitted from FIG. 7. A pin 278 extends from wall 250follower member 220 rotatably supported on apotenti- to wall 280 of the housing and acts as a stop memberometer input shaft 222 at one end and coupled to the against which the top side ofthe anns 266,268 wil bearaccelerator pedal 210 at its other end. as seen in FIG. 6. One ann member 266 includes at itsThe accelerator peda 210 has a single rubber covered opposite end an elongated actuating lever 280 whichplate member 224 having a hinge 226 at its lower end 20 engages the idle validation switch in the same manner asand a coupling member 228 at its upper end. Laterally lever 72 of the earlier described embodiment.extendif!g' plate portion 230 includes a earn surface 232 Other than the foregoing, the embodiment shown inat its underside. However, unlike the embodiInents FIGS. 6-8 is the same as that shown in the earlier deshoVv"nin FIGS. j-S, the carn surface is flat rather than scribed embodiment and the operation is also the samearcuate, and the slot 234 is linea rather than arcuate. 25 as that to be described in connection with the first em-With the present arrgement, the deviation in the rota- bodiment.tion of the follower member 220 as a linear relationship In operation, the driver applies pressure to the pedato the rotation of accelerator pedal 210 is electronically 22 and fori; it against the bias of spring 88 towardsadjusted by a suitable control circuit. wide-open-throttle to accelerate, then releases the pres-The base bracket member 212 comprises a lower 30 sure to allow the pedal to return toward idle, causingportion 236 formed as a stamping and an upper portion the vehicle to' slow down. As the driver pushes the238 formed as a casting. The two members, may be 'pedal down, the cam surface 62 forces rotation of themember 32 to whichsecured to one another by the sae bolt 24 securng cam follower 66 and the followerthe assembly to the toe board. Secured to the lower it is pinned. When the driver removes the pedal presmember236 at the intennediate portion of the base 35 sure,. the followermember 32, being spring loaded,bracket member is a stop member 242 in the fonn of a rotates back to the idle position, forcing the pedal backthreaded bolt 24 having a rubber head 24 andthread- to its idle position. Each oscilation of thet'olloweringly recived within nut member 24 which is affxed member causes rotation of the potentiometer input shaftto the lower member 236. The height of stop member 70 which drves the electricalpedal position indicating242 may be adjusted by turning it relative to the nut 24. 40 components 28 and 30 of the asembly.Looking at the housing portion 214, the potentiome- Rotation of the input shaft 70 rotates the resistiveter 216 is, secured to the outboard side of wall 250 element of the potentiometer, varng the output voltthereofwhile the idle validation switch 218 is secured iige leveL. The eomputer then reads the voltage level,on the interior side of the same wall 250. compares this with stored infonnation correlating volt-As shown paricularly in FIGS. 7 and 8, the input 4S age level and pedal position, and detennines the pedalshaft 222 is received within the potentiometer 216 and position.iicludes an elongated, rectangularly cross-sectioned tab ine design of most software logic requires the use of252 at its end. The iabis designed to slidingly interft an idle validation switch 30. The switch is' actuated byinput shat 70 as the pedalwithina'slot 256 formed by appoitely disposed'quad- ,trp lever 73 on the rotatingrat sectors 258 on the input member of the potentiome- SO leaves or teturn to 'the idle position. The changig stateter. Eåch quadrant sector 258 has a dñving race 260.' of the switch is monitored by the computer, and com-:Between the quadrant sectors is an open quadrat sec- pared'ta the signal from the potentiometer. Th comtion262. In operation, the input member 264 is driven in parsen is used as a protective measure against potentithediectionofthe arow as the pedal moves from the, ometet inalrunètion. ', idle position to the wide open throttle' position. The 55 ' Torsionspñng 88 returns the pedal back to the idledñven input member is sprig biased in' a dirècon ' positionand provides resistance to the pressure exertedopposite that of the arrow. As ,a saety feature, should by the drver's foot. When the operator reduces thethe input member 264 fail to, return to the idle position, pedal force, the torque from, the spring' acting on thebackthe open qiadrantsection 262 wil allow the input sha' 'follower member 32 rotates the follower and pedal222 to rotate 90°; which is suffcient to allow it to'retil 60 to idle. The spring provides a reSistance to pedal rotatothe idle position, thereby precluding what might tionby pushing the pedal back agaist the driver's foot.otherwise be a possibilty thatthe input shaft and thus Th r~stance increases as the pedal rotateS towardsthe accelerator, pedal asembly, would be held in an side open throttle position requiring the driver to applyopen throttle, position; Thus, the accelerator pedal ,as- an increasing amount of pedal effortsembIy remains operationaL. The idle validation switch 6S The motion of the pedal is constrained at the widewil indicate &hatthè accelerator pedal is iIi the idle open throttle position and the idle position by the baseposition wherea the potentiometer wil ,indicate that it briiçket member 20. When the pedal reaches the wideis in an open throttle position, thus indièatlngto the ,open throttle posttion, it' is halted, by the, wide open