PTAB

IPR2013-00130

KOMatsu America Corp v. Leydig Voit & Mayer Ltd

Key Events

Petition

petition

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 systems and methods for identifying operational anomalies in a motorized vehicle by collecting, at predetermined intervals, "vital sign" data (e.g., engine health) and "task-related" data (e.g., production metrics) via on-board sensors. When a poor state of vehicle health is detected, recently collected data is used to diagnose the cause.

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, an article authored by the named inventor of the ’507 patent more than seven years prior, discloses every limitation of the challenged claims. The article describes an integrated vehicle monitoring system that monitors both "vital signs" (e.g., oil pressure, water temperature) and "performance monitoring" parameters (e.g., equipment loading, amount being hauled). The system explicitly detects an overweight condition by disclosing that a red light is lit "as soon as measured tonnage equals or exceeds the programmed truck load." Hagenbuch MIS further discloses recording these values, noting the need for "data storage," and associating a "date and time" with the recorded events, thereby anticipating the limitations of independent claims 2, 13, and 25.

Prior Art Relied Upon: Hagenbuch (Patent 4,839,835) and Hamilton (a 1988 article in Microcomputers in Civil Engineering).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the Hagenbuch ’835 patent, also from the same inventor, teaches a truck operation monitoring apparatus that measures payload weight, compares it to a predetermined maximum, and detects an "overload condition." It also records task-related parameters like distance traveled. Hamilton discloses a real-time vehicle monitoring system with a "black box" feature that continuously records the last 10 minutes of data, including vital signs like engine temperature and acceleration. Hamilton explicitly teaches that for such recording, "the time and date must be recorded versus the operating parameters."
- Motivation to Combine: A POSITA would combine Hamilton's explicit teaching on time-stamping with the vehicle monitoring system of Hagenbuch ’835. The motivation would be to gain the well-understood benefits of maintaining an accurate chronological record of events, which is a simple and predictable design choice for improving data analysis and integrity.
- Expectation of Success: Combining a standard time-stamping function with a data recording system was a routine and well-understood practice, presenting no technical hurdles and thus providing a high expectation of success.

Prior Art Relied Upon: Hamilton (a 1988 article in Microcomputers in Civil Engineering).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued Hamilton alone anticipates the subject matter of independent claims 13 and 25. Hamilton discloses a method and apparatus for recording vehicle events by monitoring "production-related parameters" like vehicle speed and engine speed. It further discloses detecting a "critical state," such as a collision, by monitoring acceleration data from an accelerometer. Upon detection, Hamilton's "black box" feature retains the last 10 minutes of data, thereby "recording values of the production-related parameters leading up to the detection of the critical" state. Critically, Hamilton teaches that in this mode, "the time and date must be recorded versus the operating parameters," thus meeting all limitations of claims 13 and 25.
Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges, including claims 13 and 25 being anticipated by Steiner (Patent 4,939,652) and Zottnik (Patent 4,638,289), and other claims being obvious over various combinations of Hamilton, Steiner, Zottnik, and Hagenbuch MIS.

"Vital Signs": Petitioner argued this term should be construed to include vehicle parameters indicative of the health of the vehicle, such as engine oil temperature, coolant level, and tire pressure.
"Task-Related Parameters" / "Production-Related Parameters": Petitioner argued these interchangeable terms should be construed to include vehicle parameters that indicate the work being done, such as engine RPM, ground speed, load, and distance traveled.
"Critical State": Petitioner proposed this term includes a state of a component that, if maintained, will cause that component to fail.
Importance: These proposed constructions are broad and align with the plain and ordinary meaning of the terms. Petitioner used these constructions to argue that the functions described in the prior art references, such as monitoring engine temperature or vehicle speed, fall squarely within the scope of the claims.

Petitioner requests institution of an inter partes review and cancellation of claims 2, 4-7, 13-18, and 25-36 of the ’507 patent as unpatentable.