PTAB

IPR2013-00227

IONRoad Ltd v. Mobileye Technologies Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Estimating Ego-Motion of a Moving Vehicle Using Successive Images Recorded Along the Vehicle's Path of Motion
  • Brief Description: The ’621 patent discloses an image-processing system for determining the ego-motion of a vehicle relative to a roadway. The system uses an image receiver and a processor to generate an ego-motion estimate, including forward translation and rotation around a vertical axis, by processing at least two successive images recorded as the vehicle moves.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 13, and 35 by Bhanu

  • Prior Art Relied Upon: Bhanu (Patent 4,969,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bhanu, which issued nine years before the ’621 patent’s priority date, discloses every element of the challenged claims. Bhanu teaches a system for computing the three-dimensional "self-motion" of an imaging device by analyzing sequences of images, with a stated application for autonomous land vehicles. Petitioner asserted that Bhanu’s disclosure of an image receiver (a television camera) and processor (an I2S processor and VAX computer) that estimate the vehicle's translation and rotation "with respect to stationary locations in the scene" inherently discloses generating an ego-motion estimate relative to the roadway, as the roadway is a stationary part of the scene.

Ground 2: Anticipation or Obviousness of Claims 1, 13, and 35 over Hanna

  • Prior Art Relied Upon: Hanna (Patent 5,259,040).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Hanna discloses or renders obvious all limitations of the challenged claims. Hanna teaches a system for determining the motion of an image sensor through a scene by analyzing brightness derivatives between an image pair. Petitioner emphasized that Hanna expressly suggests using its invention "[a]s part of a vehicle navigation system" to analyze "image regions like the road ahead or an oncoming object." This direct suggestion was argued to satisfy the claim preambles. Hanna's system, comprising an image sensor and processors, generates estimates of global sensor motion, which Petitioner equated with the claimed "ego-motion estimate of the vehicle relative to the roadway."
    • Motivation to Combine (for §103 grounds): To the extent any limitation was not explicitly disclosed, Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to apply Hanna's navigation system to a land vehicle. Hanna's explicit suggestion to analyze the "road ahead" provides a clear reason to implement the system for the exact purpose claimed in the ’621 patent.
    • Expectation of Success: A POSITA would have a high expectation of success, as applying Hanna's disclosed methods to a land vehicle for navigation would be a predictable application of the technology for its intended purpose.

Ground 3: Obviousness of Claims 1, 13, and 35 over Sahli

  • Prior Art Relied Upon: Sahli (A Kalman Filter-Based Update Scheme for Road Following, IAPR Workshop, Nov. 1996).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Sahli, while not expressly disclosing the calculation of "ego-motion," renders it obvious. Sahli teaches a vision-based road following system that uses a sequence of images to dynamically update the lateral position and orientation of a vehicle with respect to lane markers on a highway. The challenged claims require estimating ego-motion (i.e., velocity and rotation), not just position.
    • Motivation to Combine: Petitioner asserted that a POSITA, seeking to implement Sahli's system for its stated purpose of vehicle navigation, would have been motivated to calculate the vehicle's ego-motion. Deriving velocity from a series of timed positional data points (v = Δd/Δt) is a fundamental concept in physics. This calculation would be a necessary and obvious step to enhance Sahli's system, for example, to determine the vehicle's lateral drift velocity to alert the driver or enable automatic control.
    • Expectation of Success: A POSITA would have had a very high expectation of success in calculating ego-motion from the positional data provided by Sahli. The relationship between position, time, and velocity is well-understood and its application would yield predictable results in the context of vehicle navigation.

  • Additional Grounds: Petitioner asserted additional anticipation challenges under 35 U.S.C. §102 against claims 1, 13, and 35 based on Giachetti (a 1998 journal article) and Suzuki (a 1999 conference proceeding), which both disclose systems for estimating vehicle ego-motion using optical flow from camera images.

4. Key Claim Construction Positions

  • Preamble: Petitioner argued the preambles of claims 1, 13, and 35 (e.g., "[a]n ego-motion determination system...") are not limiting. It was contended that the preamble merely provides a descriptive name for the invention and that the claim body is structurally complete without it.
  • "Ego-Motion": Petitioner proposed that, under the broadest reasonable interpretation, this term means "one or more components of the self-motion of an observer or camera... with respect to a static environment." This construction was argued to be consistent with the specification's description of ego-motion including translation and rotation.
  • "relative to the roadway": Petitioner argued this phrase should be interpreted broadly to mean with respect to the roadway or features on it, such as lane markings. This construction was central to the obviousness argument over Sahli, which tracks vehicle position relative to lane markers rather than the road edge itself.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 13, and 35 of the ’621 patent as unpatentable.