Filed May 27, 2025
`
`
`
`On behalf of FreightCar America, Inc.
`By: Philip Nelson (Reg. No. 62,676)
`Ted M. Cannon (Reg. No. 55,036)
`Justin Gillett (Reg. No. 71,099)
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`Tel.: (949) 760-0404
`Fax: (949) 760-9502
`Email: FCAIPR-515-048@knobbe.com
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`FREIGHTCAR AMERICA, INC.,
`Petitioner,
`
`v.
`
`NATIONAL STEEL CAR LIMITED,
`Patent Owner.
`
`
`Case IPR2025-01048
`Patent 8,132,515
`
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 8,132,515
`
`
`
`
`
`
`
`On behalf of FreightCar America, Inc.
`By: Philip Nelson (Reg. No. 62,676)
`Ted M. Cannon (Reg. No. 55,036)
`Justin Gillett (Reg. No. 71,099)
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`Tel.: (949) 760-0404
`Fax: (949) 760-9502
`Email: FCAIPR-515-048@knobbe.com
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`FREIGHTCAR AMERICA, INC.,
`Petitioner,
`
`v.
`
`NATIONAL STEEL CAR LIMITED,
`Patent Owner.
`
`
`Case IPR2025-01048
`Patent 8,132,515
`
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 8,132,515
`
`
`
`
`
`TABLE OF CONTENTS
`
`Page No.
`
`I.
`
`INTRODUCTION .................................................................................. 20
`
`II.
`
`PRELIMINARY MATTERS ................................................................. 22
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`Priority Date ................................................................................. 22
`
`Prosecution History ...................................................................... 22
`
`Prior Art ........................................................................................ 24
`
`Claim Construction....................................................................... 29
`
`Reliance on Expert Analysis and Testimony ............................... 30
`
`Level of Ordinary Skill ................................................................ 30
`
`III. STATEMENT OF PRECISE RELIEF REQUESTED .......................... 30
`
`A.
`
`B.
`
`Statutory Grounds for Cancellation ............................................. 30
`
`Status of References as Prior Art ................................................. 31
`
`IV. SPECIFIC PROPOSED GROUNDS FOR UNPATENTABILITY ...... 32
`
`A. Ground 1: Claims 1-2, 5-6, 20, and 23 are obvious over the
`1946 Cyclopedia and either Coates or the 1922 Cyclopedia. ...... 33
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Independent Claim 1 .......................................................... 33
`
`Claim 2 ............................................................................... 63
`
`Claim 5 ............................................................................... 63
`
`Claim 6 ............................................................................... 68
`
`Independent Claim 20 ........................................................ 69
`
`i
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`
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`TABLE OF CONTENTS
`(cont’d)
`
`Page No.
`
`6.
`
`Claim 23 ............................................................................. 76
`
`B. Ground 2: Claims 3 and 21-22 are obvious over the 1946
`Cyclopedia, Coates or the 1922 Cyclopedia, and Schuller. ......... 78
`
`1.
`
`2.
`
`3.
`
`Claim 3 ............................................................................... 78
`
`Claim 21 ............................................................................. 80
`
`Claim 22 ............................................................................. 80
`
`C. Ground 3: Claim 4 is obvious over the 1946 Cyclopedia,
`Coates or the 1922 Cyclopedia, Schuller, and Karig. .................. 80
`
`1.
`
`Claim 4 ............................................................................... 80
`
`D. Ground 4: Claims 7–16, 18–19, 24–27, 30–35, and 38–42
`are obvious over the 1946 Cyclopedia and Wong. ...................... 81
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`Independent Claim 7 .......................................................... 81
`
`Claim 8 ............................................................................... 92
`
`Claim 9 ............................................................................... 94
`
`Claim 10 ............................................................................. 94
`
`Claim 11 ............................................................................. 95
`
`Claim 12 ............................................................................. 96
`
`Claim 13 ............................................................................. 96
`
`Claim 14 ............................................................................. 98
`
`Claim 15 ............................................................................. 99
`
`ii
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`TABLE OF CONTENTS
`(cont’d)
`
`Page No.
`
`10. Claim 16 ........................................................................... 102
`
`11.
`
`Independent Claim 18 ...................................................... 102
`
`12. Claim 19 ........................................................................... 107
`
`13.
`
`Independent Claim 24 ...................................................... 107
`
`14. Claim 25 ........................................................................... 111
`
`15. Claim 26 ........................................................................... 111
`
`16. Claim 27 ........................................................................... 112
`
`17. Claim 30 ........................................................................... 112
`
`18. Claim 31 ........................................................................... 112
`
`19.
`
`Independent Claim 32 ...................................................... 112
`
`20. Claim 33 ........................................................................... 123
`
`21. Claim 34 ........................................................................... 123
`
`22. Claim 35 ........................................................................... 123
`
`23. Claim 38 ........................................................................... 124
`
`24. Claim 39 ........................................................................... 124
`
`25. Claim 40 ........................................................................... 126
`
`26. Claim 41 ........................................................................... 136
`
`27. Claim 42 ........................................................................... 137
`
`iii
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`TABLE OF CONTENTS
`(cont’d)
`
`Page No.
`
`E.
`
`Ground 5: Claim 17 is obvious over the 1946 Cyclopedia,
`Wong, and Campbell ’051. ........................................................ 138
`
`1.
`
`Claim 17 ........................................................................... 138
`
`F.
`
`Ground 6: Claim 28 is obvious over the 1946 Cyclopedia,
`Wong and Coates or the 1922 Cyclopedia. ................................ 140
`
`1.
`
`Claim 28 is free of any other primary structure.” ............ 140
`
`G. Ground 7: Claim 29 is obvious over the 1946 Cyclopedia,
`Wong, Coates or the 1922 Cyclopedia, and Schuller. ............... 140
`
`1.
`
`Claim 29 ........................................................................... 140
`
`H. Ground 8 ..................................................................................... 141
`
`1.
`
`2.
`
`Claim 36 ........................................................................... 141
`
`Claim 37 ........................................................................... 141
`
`I.
`
`Ground 9: Claims 43-44 are obvious over the 1946
`Cyclopedia, Wong and Lindström. ............................................ 143
`
`1.
`
`2.
`
`Claim 43 ........................................................................... 143
`
`Claim 44 ........................................................................... 146
`
`V. CONCLUSION ..................................................................................... 147
`
`VI. MANDATORY NOTICES, GROUNDS FOR STANDING,
`AND FEE PAYMENT ......................................................................... 147
`
`A.
`
`B.
`
`Real Party-In-Interest (37 C.F.R. §42.8(b)(1)) .......................... 147
`
`Related Matters (37 C.F.R. §42.8(b)(2)) .................................... 147
`
`iv
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`
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`TABLE OF CONTENTS
`(cont’d)
`
`Page No.
`
`C.
`
`D.
`
`E.
`
`F.
`
`Lead and Backup Counsel (37 C.F.R. §42.8(b)(3)) ................... 148
`
`Service Information (37 C.F.R. §42.8(b)(4)) ............................. 148
`
`Grounds for Standing (37 C.F.R. §42.104) ................................ 148
`
`Payment of Fees (37 C.F.R. §42.15(a)) ..................................... 149
`
`
`
`
`
`v
`
`
`
`TABLE OF AUTHORITIES
`
`Page No(s).
`
`In re Bond,
`910 F.2d 831 (Fed. Cir. 1990) .............................................................. passim
`
`National Steel Car Limited v. FreightCar America, Inc., et al.,
`C.A. No. 1:24-cv-00594-JLH (D. Del.) ..................................................... 147
`
`Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co. Ltd.,
`868 F.3d 1013 (Fed. Cir. 2017) ................................................................... 29
`
`In re Nilssen,
`851 F.2d 1401 (Fed. Cir. 1988) ................................................................... 32
`
`Unwired Planet, LLC v. Google Inc.,
`841 F.3d 995 (Fed. Cir. 2016) ..................................................................... 32
`
`OTHER AUTHORITIES
`
`35 U.S.C. §102 ...................................................................................... 30, 31, 32
`
`35 U.S.C. §103 .................................................................................................. 30
`
`37 C.F.R. §42.8 ....................................................................................... 147, 148
`
`37 C.F.R. §42.10 ............................................................................................. 148
`
`37 C.F.R. §42.15 ............................................................................................. 149
`
`37 C.F.R. §42.24 ............................................................................................. 150
`
`37 C.F.R. §42.104 ........................................................................................... 148
`
`
`
`
`
`vi
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`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`LIST OF EXHIBITS
`
`Exhibit No. Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`U.S. Patent No. 8,132,515 (“the ’515 Patent”)
`
`File History of the ’515 Patent
`
`Declaration of Mehdi Ahmadian, Ph.D.
`
`Excerpts from 1946 Car Builders’ Cyclopedia, 17th ed.
`(“1946 Cyclopedia”)
`
`U.S. Patent No. 1,321,928 (“Lindström”)
`
`U.S. Patent No. 4,941,411 (“Wong”)
`
`Excerpts from Lancashire & Yorkshire Wagons, Vol. II, by Noel
`Coates, Copyright 2006 (“Coates”)
`
`1008
`
`U.S. Patent No. 992,192 (“Hart”)
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`Excerpts from The Car Builders’ Dictionary, 1906 Edition
`(“1906 Cyclopedia”)
`
`Excerpts from Car Builders’ Dictionary, 1912 (Seventh) Edition
`(“1912 Cyclopedia”)
`
`Excerpts from Car Builders’ Cyclopedia of American Practice,
`Tenth Edition—1922 (“1922 Cyclopedia”)
`
`U.S. Patent No. 1,537,051 (“Campbell ’051”)
`
`U.S. Patent No. 1,999,652 (“Campbell ’652”)
`
`U.S. Patent No. 3,710,729 (“Schuller”)
`
`U.S. Patent No. 4,348,962 (“Smith”)
`
`Excerpts from COAL CARS: The First Three Hundred Years, by
`Martin Robert Karig III, Copyright 2007 (“Karig”)
`
`Exhibit List, Page 1
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Exhibit No. Description
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1024
`
`
`
`Excerpts from Modern Private Owner Wagons on British Rail, by
`David Ratcliffe, Copyright 1989 (“Ratcliffe 1”)
`
`Excerpts from Private-Owner Wagons in Colour, For the Modeller
`and Historian, by David Ratcliffe, Copyright 2009 (“Ratcliffe 2”)
`
`Excerpts from Wagons of the Final Years of the British Railways, By
`David Larkin, Copyright 2008 (“Larkin 1”)
`
`Excerpts from Working Wagons, Vol. 3 1980–1984, by David
`Larkin, Copyright 2001 (“Larkin 2”)
`
`Excerpts from Wagon Recognition, Vol. 1 Carkinds – B to W, by
`Martin Buck and Mark Rawlinson (“Buck”)
`
`Declaration of Sylvia Hall-Ellis
`
`Excerpts from Private Owner Wagons, Vol. 1, by Andrew Marshall,
`Copyright 1989 (“Marshall”)
`
`Exhibit List, Page 2
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`CLAIM LISTING
`
`Limitation
`
`Claim Language
`
`A railroad hopper car for carrying particulate material,
`said hopper car comprising:
`a hopper;
`first and second end sections for carriage by respective first
`and second rail road car trucks for rolling motion along
`railroad tracks in a longitudinal direction;
`said hopper being suspended between said first and second
`end sections,
`
`said hopper having a discharge section
`through which to release lading, and first and second end
`slope sheets oriented toward said first and second end
`sections, said end slope sheets being inclined in the
`longitudinal direction to feed said discharge section;
`
`said first end section including a draft sill extending in the
`longitudinal direction, a main bolster extending crosswise
`to said draft sill, and a shear plate mounted to said
`draft sill and to said main bolster, said shear plate
`extending lengthwise along said draft sill and cross-wise
`from side to side of said hopper car;
`
`said first end slope sheet of said hopper over hanging said
`shear plate of said first end section; and
`
`
`said hopper car being free of primary structure directly
`above said shear plate of said first end section under said
`overhang of said first end slope sheet of said hopper;
`
`1a
`
`1b
`
`1c
`
`1d
`
`1e
`
`1
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`1f
`
`1g
`
`1h
`
`1i
`
`2
`
`3a
`
`3b
`
`one of:
`(a) said first end slope sheet has an upper margin and said
`hopper car includes an end post extending upwardly
`from said draft sill to said upper margin of said first end slope
`sheet; and
`(b) said first end slope sheet has an upper margin terminating
`at an end wall, and said hopper car includes an end post
`extending upwardly from draft stub sill to said end wall;
`
`said shear plate has a longitudinally outboard margin and
`said draft sill has a striker located outboard of said
`longitudinally outboard margin of said shear plate, and said
`end post is one of:
`(a) rooted to said draft sill adjacent to said striker;
`(b) rooted to said shear plate adjacent to said longitudinally
`outboard margin of said shear plate;
`
`said bolster has first and second laterally outboard distal
`ends, and said hopper car has corner posts extending
`upwardly from said distal ends of said bolster to said first
`end slope sheet; and
`
`said hopper car has a machinery space bounded by (a) said
`first end slope sheet; (b) said shear plate of said first end
`section; (c) said end post; and (d) said corner posts, and
`said machinery space is free of any other primary structure.
`
`The railroad hopper car of claim 1 wherein said bolster has
`first and second laterally outboard distal ends, and said hopper
`car has corner posts extending upwardly from said distal ends
`of said hopper to said first end slope sheet.
`
`The railroad hopper car of claim 1 wherein: said hopper car
`has at least one longitudinally hinged discharge door, said
`discharge door being movable cross-wise between open and
`closed positions; and
`
`a longitudinally acting pneumatic actuator is at least partially
`lodged in said machinery space directly above said draft sill.
`
`2
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`4
`
`5a
`
`5b
`
`5c
`
`5d
`
`5e
`
`6
`
`7a
`
`7b
`
`The railroad hopper car of claim 3 wherein a brake reservoir
`is also at least partially lodged in said machinery space.
`
`The railroad hopper car of claim 1 wherein: said shear plate is
`mounted above, and to, said main bolster and defines an upper
`flange thereof;
`
`said main bolster has a lower flange downwardly spaced from
`said upper flange, said lower flange terminating at respective
`distal end portions at either side of said car;
`
`said car includes a side sill running along said car between
`said first and second end sections;
`
`said side sill has an upper flange, said upper flange of said side
`sill being substantially co-planar with, and connected to, said
`shear plate; and
`
`said side sill has a lower flange, said lower flange of said side
`sill being substantially co-planar with a respective one of said
`distal end portions of said lower flange of said main bolster.
`
`The railroad hopper car of claim 5 wherein said shear plate
`defines an upper flange of said draft sill whereby said draft sill
`upper flange, said shear plate and said side sill upper flange
`are all substantially co-planar.
`
`A railroad hopper car, said hopper car comprising:
`a hopper; first and second end sections for carriage by
`respective first and second rail road car trucks for rolling
`motion along railroad tracks in a longitudinal direction; said
`hopper being suspended between said first and second end
`sections,
`
`said hopper having a discharge section through which to
`release lading, and a first end slope sheet oriented toward said
`first end section, said first end slope sheet being inclined in
`the longitudinal direction to feed said discharge section;
`
`3
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`said first end section including a draft sill extending in the
`longitudinal direction, a main bolster extending cross-wise to
`said draft sill, and a shear plate mounted to said draft sill and
`to said main bolster, said shear plate extending lengthwise
`along said draft sill and cross-wise from side to side of said
`hopper car;
`
`said first end slope sheet of said hopper over-hanging said
`shear plate of said first end section;
`
`
`first and second side walls running lengthwise along first and
`second sides of said car, said first end slope sheet of said
`hopper extending cross-wise between said first and second
`side walls;
`
`a first laterally extending reinforcement mounted cross-wise to said
`first end slope sheet adjacent to said shear plate;
`said shear plate of said first end section being connected to said first
`laterally extending reinforcement;
`said first end slope sheet of said first end section being connected to
`said first laterally extending reinforcement;
`said first laterally extending reinforcement defining part of a
`first hollow section beam extending across said hopper car
`between said first and second side walls;
`
`said hopper car being free of longitudinally oriented elephant ears
`extending between said draft sill and said end slope sheet;
`
`7c
`
`7d
`
`7e
`
`7f
`
`7g
`
`4
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`said hopper car has a first end wall member running cross-wise
`between said first and second side walls;
`said first end slope sheet has an upper margin that meets said first
`end wall member at a first junction;
`said first end wall member extends upwardly from said first junction;
`said first end wall member has a lower portion extending downward
`of said first junction;
`said lower portion of said first end wall member and said upper
`margin of said first end slope sheet co-operate to define portions of
`the cross-section of a second hollow section beam extending cross-
`wise across said hopper car between said first and second side walls.
`
`The railroad hopper car of claim 7 wherein said laterally extending
`reinforcement member includes a first edge mounted cross-wise
`along said first end slope sheet; a second edge mounted cross-wise
`along said first end slope sheet and spaced from said first edge, and
`a third portion mounted across said shear plate of said first end
`section.
`
`The railroad hopper car of claim 7 wherein said laterally extending
`member has a pair of first and second spaced apart toes, and said
`laterally extending member is mounted toes-in against said first end
`slope sheet, whereby said first hollow section beam is defined by
`said laterally extending reinforcement and said first end slope sheet.
`
`The railroad hopper car of claim 7 wherein said laterally extending
`reinforcement has, when seen in section, a first toe, a second toe, and
`a back; said laterally extending reinforcement is mounted toes-in
`against said first end slope sheet; and said back is mounted to said
`shear plate of said first end section.
`
`The railroad hopper car of claim 10 wherein said laterally extending
`reinforcement is an angle iron mounted toes-in to said first end slope
`sheet.
`
`7h
`
`8
`
`9
`
`10
`
`11
`
`5
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18a
`
`The railroad hopper car of claim 7 wherein said lower portion of said
`first end wall member has a lower margin that is bent to meet said
`upper margin of said first end slope sheet at a location lower than
`said first junction.
`
`The railroad hopper car of claim 7 wherein said first end wall
`member has an upper margin that terminates at a top chord, said top
`chord extending from side to side of said hopper car.
`
`The railroad hopper car of claim 7 wherein said car includes an
`upstanding end post, said end post being mounted over said draft sill
`longitudinally outboard of said main bolster and extending upwardly
`therefrom to meet said first end wall member.
`
`The railroad hopper car of claim 7 wherein an intermediate beam
`extends across said first end slope sheet between said first and
`second side walls at a position intermediate said first hollow section
`beam and said second hollow section beam.
`
`The railroad hopper car of claim 15 wherein said intermediate beam
`includes a cross-wise extending structural member mounted toes-in
`against said first end slope sheet to define a closed hollow section.
`
`The railroad hopper car of claim 7 wherein said first and second side
`walls of said hopper car define sidewalls of said hopper, and said
`first and second side walls include end portions that are stepped
`laterally inboard, and said second hollow section beam extends
`between said end portions of said first and second side walls that are
`stepped laterally inboard.
`
`A railroad hopper car, said hopper car comprising: a hopper; first and
`second end sections for carriage by respective first and second rail
`road car trucks for rolling motion along railroad tracks in a
`longitudinal direction; said hopper being suspended between said
`first and second end sections,
`
`6
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`18b
`
`18c
`
`18d
`
`18e
`
`18f
`
`said hopper having a discharge section through which to release
`lading, and a first end slope sheet oriented toward said first end
`section, said first end slope sheet being inclined in the longitudinal
`direction to feed said discharge section;
`
`said first end section including a draft sill extending in the
`longitudinal direction, a main bolster extending cross-wise to said
`draft sill, and a shear plate mounted to said draft sill and to said main
`bolster, said shear plate extending lengthwise along said draft sill
`and cross-wise from side to side of said hopper car;
`
`said first end slope sheet of said hopper over-hanging said shear plate
`of said first end section;
`
`
`first and second side walls running lengthwise along first and second
`sides of said car, said first end slope sheet of said hopper extending
`cross-wise between said first and second side walls;
`
`a first laterally extending reinforcement mounted cross-wise to said
`first end slope sheet adjacent to said shear plate;
`said shear plate of said first end section being connected to said first
`laterally extending reinforcement;
`said first end slope sheet of said first end section being connected to
`said first laterally extending reinforcement;
`said first laterally extending reinforcement defining part of a first
`hollow section beam extending across said hopper car between said
`first and second side walls;
`
`18g
`
`said hopper car being free of longitudinally oriented shear webs ears
`extending between said draft sill and said end slope sheet;
`
`7
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`18h
`
`18i
`
`18j
`
`18k
`
`19
`
`said hopper car has second, and third hollow section beams as well
`as said first hollow section beam, said first, second and third hollow
`section beams extending thereacross between said first and second
`side walls thereof;
`said first end slope sheet has an uppermost margin, and said second
`hollow section beam runs along said uppermost margin of said first
`end slope sheet;
`said third hollow section beam is located intermediate said first and
`second hollow section beams;
`
`said hopper car has an end post mounted over said draft sill, said end
`post being located longitudinally outboard of said main bolster of
`said first end section;
`said end post extends upwardly to meet said second hollow section
`beam;
`
`said hopper car has first and second side sills running longitudinally
`along either side thereof, said first and second side walls extending
`upwardly of said first and second side sills respectively;
`said first and second side sills mate with first and second ends of said
`main bolster of said first end section; and
`
`
`said first and second side sills have upper flanges that mate with said
`shear plate of said first and section.
`
`The railroad hopper car of claim 18 wherein:
`there is an end wall that extends from sidewall to sidewall;
`said end wall has an upper portion that has an upper margin
`terminating at a top chord of said end wall;
`said first end slope sheet has an uppermost margin, said uppermost
`margin of said first end slope sheet meeting said end wall along a
`first juncture;
`said end wall has a lower portion extending below said first juncture,
`said lower portion being bent to define a portion of said second
`hollow section beam; and
`said end post extends past said second hollow section beam along
`said end wall to mate with said top chord of said end wall.
`
`8
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`20a
`
`20b
`
`20c
`
`20d
`
`20e
`
`20f
`
`A railroad hopper car, said hopper car comprising:
`a hopper;
`first and second end sections for carriage by respective first and
`second rail road car trucks for rolling motion along railroad tracks in
`a longitudinal direction; said hopper being suspended between said
`first and second end sections,
`
`said hopper having a discharge section through which to release
`lading, and a first end slope sheet oriented toward said first end
`section, said first end slope sheet being inclined in the longitudinal
`direction to feed said discharge section;
`
`said first end section including a draft sill extending in the
`longitudinal direction, a main bolster extending cross-wise to said
`draft sill, and a shear plate mounted to said draft sill and to said main
`bolster, said shear plate extending lengthwise along said draft sill
`and cross-wise from side to side of said hopper car;
`
`said first end slope sheet of said hopper over-hanging said shear plate
`of said first end section;
`
`
`first and second side walls running lengthwise along first and second
`sides of said car, said first end slope sheet of said hopper extending
`cross-wise between said first and second side walls;
`
`a first laterally extending reinforcement mounted cross-wise to said
`first end slope sheet adjacent to said shear plate;
`said shear plate of said first end section being connected to said first
`laterally extending reinforcement;
`said first end slope sheet of said first end section being connected to
`said first laterally extending reinforcement;
`said first laterally extending reinforcement defining part of a first
`hollow section beam extending across said hopper car between said
`first and second side walls;
`
`20g
`
`said hopper car being free of longitudinally oriented elephant ears
`extending between said draft sill and said end slope sheet;
`
`9
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`20h
`
`20i
`
`20j
`
`21
`
`22
`
`23
`
`said main bolster of said first end section of said railroad hopper car
`has first and second ends at laterally outboard extremities thereof;
`said hopper car has first and second corner posts mounted at said first
`and second ends of said main bolster of said first end section, said
`corner posts extending upwardly from said main bolster to said first
`end slope sheet;
`
`said draft sill has a longitudinally outboard end;
`an end post stands upwardly of said longitudinally outboard end of
`said draft sill;
`
`a machinery space is defined above said shear plate, below said first
`end slope sheet, longitudinally inboard of said end post, and between
`said corner posts; and
`said machinery space is free of any other primary structure.
`
`The railroad hopper car of claim 20 wherein:
`said hopper has a movable door by which egress of lading is
`governed;
`said hopper car has an actuator and a drive train, said drive train
`being connected between said actuator and said door, said actuator
`being operable to move said door; and
`said actuator is mounted in said machinery space.
`
`The railroad hopper car of claim 21 wherein said first side wall has
`an aperture formed therein at a location higher than said shear plate,
`lower than said first end slope sheet, and longitudinally inboard of
`said first corner post.
`
`The railroad hopper car of claim 20 wherein
`said first and second side walls of said car have openings defined
`therein longitudinally inboard of said respective corner posts, above
`said shear plate, and below said first end slope sheet.
`
`10
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`24a
`
`24b
`
`24c
`
`24d
`
`24e
`
`A railroad hopper car, said hopper car comprising:
`a hopper;
`first and second end sections for carriage by respective first and
`second rail road car trucks for rolling motion along railroad tracks in
`a longitudinal direction; said hopper being suspended between said
`first and second end sections,
`
`said hopper having a discharge section through which to release
`lading, and a first end slope sheet oriented toward said first end
`section, said first end slope sheet being inclined in the longitudinal
`direction to feed said discharge section;
`
`said first end section including a draft sill extending in the
`longitudinal direction, a main bolster extending cross-wise to said
`draft sill, and a shear plate overlying said draft sill and said main
`bolster, said shear plate extending along said draft sill and cross-wise
`from side to side of said hopper car;
`
`said first end slope sheet over-hanging said shear plate of said first
`end section;
`
`
`first and second side walls running lengthwise along first and second
`sides of said car, said first end slope sheet of said hopper extending
`cross-wise between said first and second side walls;
`
`11
`
`
`
`FreightCar America v. National Steel Car
`IPR Petition – U.S. Patent No. 8,132,515
`
`
`Limitation
`
`Claim Language
`
`there being a first end wall extending between said first and second
`side walls;
`said first end slope sheet having an uppermost margin, said
`uppermost margin meeting said first end wall at a first junction;
`said hopper car having a first beam extending cross-wise between
`said first and second side walls at said first junction of said
`uppermost margin of said first end slope sheet and said first end wall,
`said first beam being a beam of hollow section;
`said first end wall has an upper portion and a lower portion;
`said upper portion of said first end wall extends upwardly of said
`first junction of said uppermost margin of said first end slope sheet
`and said first end wall;
`said lower portion of said end wall extends downwardly of said first
`junction of said uppermost margin of said first end slope sheet and
`said first end wall; and
`said lower portion of said first end wall forms part of said first beam;
`
`said draft sill having longitudinally extending draft sill webs;
`
`said first end section being free of longitudinally oriented elephant
`ears extending upwardly of said draft sill webs to meet said end slope
`sheet;
`
`said lower portion of said first end wall has a margin, and said margin
`is bent to mate with said first end slope sheet as a second junction
`distant from the first junction, said lower portion of said first end
`wall and said uppermost margin of said first end slope sheet co-
`operating to define said first beam.
`
`The rail
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