PTAB

IPR2013-00129

KOMatsu America Corp v. Leydig Voit & Mayer Ltd

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1. Case Identification

2. Patent Overview

  • Title: Apparatus for Tracking and Recording Vital Signs and Task-Related Information of a Vehicle to Identify Operating Patterns
  • Brief Description: The ’507 patent discloses a system for identifying operational anomalies in a motorized vehicle. An on-board processor acquires "vital sign" data (indicative of vehicle health) and "task-related" data (indicative of work performed) from vehicle sensors to diagnose the cause of poor vehicle performance or failure.

3. Grounds for Unpatentability

Ground 1: Anticipation by Hagenbuch MIS - Claims 1 and 23 are anticipated under 35 U.S.C. §102 by Hagenbuch MIS.

  • Prior Art Relied Upon: Hagenbuch MIS (SAE Technical Paper Series, Sep. 1986).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hagenbuch MIS, a technical paper authored by the inventor of the ’507 patent more than one year before the patent’s effective filing date, describes an integrated vehicle monitoring system that teaches every limitation of claims 1 and 23. The paper explicitly discloses monitoring both "vital signs" (e.g., oil pressure, temperature) and "performance monitoring" (equivalent to task-related parameters like equipment loading and haul distance). Petitioner asserted that Hagenbuch MIS further discloses identifying a "critical state" through "exception reporting" for abnormal conditions and recording a chronology of data for later review via "historical monitoring."

Ground 2: Obviousness over Hagenbuch MIS and Mitsugi - Claims 3, 8-10, 19, 20, and 24 are obvious over Hagenbuch MIS in view of Mitsugi.

  • Prior Art Relied Upon: Hagenbuch MIS (SAE Technical Paper Series, Sep. 1986) and Mitsugi (Japanese Patent Application H03-0005626).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that while Hagenbuch MIS teaches the core system of monitoring vehicle parameters, identifying critical states, and recording data, it does not explicitly disclose detecting a "crash" as the specific critical state (claim 3) or automatically broadcasting a distress signal in response (claim 8). Mitsugi, which relates to a vehicle navigation and accident reporting system, remedies this by explicitly teaching the use of an acceleration sensor to detect a crash. Upon detection, Mitsugi’s system automatically transmits emergency data, including location and vehicle operation data, to a remote station.
    • Motivation to Combine: A POSITA would combine Mitsugi's crash detection and reporting features into the Hagenbuch MIS system to enhance its existing "exception reporting" capabilities. Since the Hagenbuch system monitors heavy equipment like trucks, which are vulnerable to crashes, adding this feature would provide a clear explanation for certain exceptions (e.g., failure to arrive at a destination) and would directly further the stated objectives of truck and equipment management.
    • Expectation of Success: The integration was argued to be a predictable application of known technologies. Combining sensor-based event detection (a crash from Mitsugi) with an existing vehicle data monitoring and reporting system (Hagenbuch MIS) would have been a straightforward design choice for a POSITA seeking to create a more robust monitoring system.

Ground 3: Anticipation by Zottnik - Claims 1, 3, 23, and 24 are anticipated under §102 by Zottnik.

  • Prior Art Relied Upon: Zottnik (Patent 4,638,289).

  • Core Argument for this Ground:

    • Prior Art Mapping: As an alternative basis for invalidity, Petitioner argued Zottnik alone anticipates the core claims. Zottnik describes an accident data recorder that monitors and preserves vehicle operation data for subsequent analysis. It discloses monitoring vital signs (using an acceleration sensor to detect a crash) and task-related parameters (travel speed, distance). Zottnik identifies a critical state when a "trigger event" is computed and interpreted as an accident. It records a chronology of data leading up to the critical state by cyclically storing parameters in a fixed storage medium and "freezing" the data upon crash detection, preserving the record. Zottnik also teaches recording data for a period after the crash begins, satisfying limitations related to describing how the vehicle operated immediately prior to the crash.

  • Additional Grounds: Petitioner asserted additional challenges, including anticipation by Steiner (Patent 4,939,652) and Hamilton (a 1988 article), and numerous obviousness combinations involving Zottnik, Steiner, Hamilton, Mitsugi, and Asano (Patent 5,157,610). These grounds relied on similar prior art teachings for crash detection from accelerometers, cyclical data recording to a memory buffer, and automatic transmission of a distress signal upon detecting an anomaly.

4. Key Claim Construction Positions

Petitioner proposed the following constructions under the broadest reasonable interpretation standard, arguing they were essential to understanding how the prior art meets the claim limitations.

  • "Vital Signs": This term was construed to include parameters indicative of vehicle health, such as engine oil temperature, pressure, coolant levels, and data from crash/acceleration sensors.
  • "Task-Related Parameters": This term was construed to include parameters providing indicia of the work performed by the vehicle, such as engine RPM, throttle position, ground speed, distance traveled, and load.
  • "Critical State": This term was construed to mean a state of a component or subassembly that, if maintained, will cause it to fail. This includes specific events like a vehicle crash or operational parameters exceeding predefined safety limits.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 3, 8-12, and 19-24 of the ’507 patent as unpatentable.