PTAB

IPR2012-00001

Garmin International, Inc. v. Cuozzo Speed Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Speed Limit Indicator and Method for Displaying Speed and the Relevant Speed Limit
  • Brief Description: The ’074 patent discloses a speed limit indicator for vehicles that determines the current speed limit corresponding to the vehicle's location and displays both the vehicle's speed and the relevant speed limit to the driver. The system uses a global positioning receiver to determine the location, accesses a speed limit database, and presents the information on a display, such as a speedometer with a colored filter or an LCD screen, to alert the driver when the speed limit is exceeded.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 6, 7, 9, 10, and others by Aumayer

  • Prior Art Relied Upon: Aumayer (Patent 6,633,811).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Aumayer teaches all limitations of the challenged claims. Specifically for independent claim 1, Aumayer discloses a speed display device that uses a GPS to determine a vehicle's location and displays the corresponding speed limit on the speedometer scale. Aumayer explicitly teaches that a scale mark indicating the speed limit can be a different color (e.g., red, yellow, or orange) and longer or wider than other marks, thus serving as a "colored display." This colored mark is "integrally attached" to the speedometer as it is displayed on the same LCD screen or as colored background lighting on a mechanical display. Aumayer’s display controller adjusts this colored display independently of the speedometer needle to continuously update the speed limit delineation based on the vehicle's location.
    • Key Aspects: Petitioner contended Aumayer's disclosure of an LCD displaying both a speedometer and a colored tick mark for the speed limit on the same screen satisfies the "integrally attached" limitation, a position consistent with the Patent Owner’s infringement allegations against Petitioner’s own LCD products.

Ground 2: Anticipation of Claims 1, 2, 6, 7, and others by Tegethoff

  • Prior Art Relied Upon: Tegethoff (DE 197 55 470 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Tegethoff independently anticipates the core invention. Tegethoff discloses a freely programmable LCD screen for displaying vehicle information, including a speedometer and a colored tick mark indicating the current maximum permissible speed. This speed limit is determined based on the vehicle's location using a navigation element and a database. The colored mark (e.g., red for a critical limit) is displayed on the same screen as the speedometer, satisfying the "integrally attached" limitation. Tegethoff's image-generating computer acts as a display controller, adjusting the colored mark's position on the scale based on location data, independent of the speedometer pointer, to delineate speeds in violation of the limit.

Ground 3: Obviousness over Tegethoff and Awada

  • Prior Art Relied Upon: Tegethoff (DE 197 55 470 A1) and Awada (Patent 6,515,596).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground primarily addresses independent claim 10 and its dependents. Petitioner argued that while Tegethoff teaches an integrated display system with a location-based speed limit indicator, it does not explicitly state its navigation element is a GPS. Awada, however, expressly discloses using a GPS receiver to determine vehicle position for the purpose of reporting a posted speed limit from a database.
    • Motivation to Combine: A POSITA would combine Tegethoff's integrated display with Awada's GPS receiver to improve the accuracy and reliability of the location-determining function in Tegethoff's system. Awada's teaching to use GPS for speed limit reporting provides a clear motivation to implement Tegethoff's navigation element with a known, highly accurate GPS technology.
    • Expectation of Success: Combining a standard GPS for location input into a display system was a well-understood and common practice in the art, presenting no technical hurdles and leading to a predictable improvement in location accuracy.

  • Additional Grounds: Petitioner asserted numerous additional anticipation and obviousness challenges. These included anticipation of claim 1 by Tokunaga (Patent 5,375,043) and obviousness of various claims by combining Aumayer or Tegethoff with references like Evans (Patent 3,980,041) for a colored filter, Awada for a tone generator, and Hamamura (JP H07-182598) or Wendt (Patent 2,711,153) for other specific features.

4. Key Claim Construction Positions

  • "integrally attached": Petitioner argued that for the purposes of the IPR, this term should be construed broadly, consistent with the Patent Owner's infringement contentions against Garmin's products. Under this construction, displaying a speedometer and a colored speed limit indicator (like a tick mark) on the same LCD screen satisfies the limitation. This construction is central to the anticipation arguments based on Aumayer and Tegethoff, which both disclose such integrated LCDs.

5. Key Technical Contentions

  • Rebuttal of Prosecution History: Petitioner's central technical contention was that the prior art, particularly Aumayer and Tegethoff, already solved the very problem the Patent Owner relied upon to secure allowance of the ’074 patent. During prosecution, the Patent Owner distinguished the invention from prior art (Awada) by arguing that Awada forced drivers to look at two separate locations, whereas the ’074 patent provided an "integrated display" to reduce driver distraction. Petitioner contended that references like Aumayer and Tegethoff, which were not before the examiner, explicitly teach displaying the speed limit directly on the speedometer face for the exact same safety and usability reasons, rendering the claims obvious.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of Patent 6,778,074 as unpatentable under 35 U.S.C. §102 and/or §103.