PTAB

IPR2013-00240

K40 Electronics LLC v. Escort Inc

Key Events

Petition

petition

Title: Radar Warning Receiver With Position and Velocity Sensitive Functions
Brief Description: The ’905 patent relates to a police warning receiver system that integrates a position determining circuit (e.g., GPS) with a radar/laser detector. The system uses the vehicle's geographic position and/or velocity to filter incoming signals against a database of known false alarm locations to reduce unwanted alerts.

Prior Art Relied Upon: Hoffberg (Patent 6,252,544)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Hoffberg anticipates the challenged claims by disclosing all elements of the claimed invention. Hoffberg described a mobile communications device integrating a police radar detector, a LIDAR (laser) detector, a GPS receiver, a processor, and a database memory. This system was taught to detect police radar signals, store the locations of events like false alarms, and use this stored location data to correlate with newly detected signals to suppress or modify an alert. This mapping was asserted to meet the limitations of independent claim 1, including the receiver, alert section, position determining circuit, and the function of altering alerts based on a location correlated to a "rejectable signal." Petitioner contended that Hoffberg's teachings also extended to the various features of the dependent claims, such as storing vehicle history, using different signal types (radar, laser), and interfacing with external data sources.

Prior Art Relied Upon: Fleming (Patent 6,204,798)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Fleming also anticipates a broad set of claims by disclosing a police radar detector that includes a GPS receiver and a microprocessor. Fleming’s system determined whether to generate alerts for incoming radar signals based upon the detector's position with respect to previously stored false alarm locations. Fleming explicitly taught storing the position of a known false alarm source (e.g., an automatic door opener) in memory and then suppressing an alert if a radar signal was detected when the vehicle was near that stored location. Petitioner asserted this directly taught the core functionality of claim 1. Fleming further disclosed storing vehicle velocity, comparing signal frequencies to identify rejectable signals, and obtaining false alarm information gathered by other detectors via general-purpose computers, which Petitioner mapped to numerous dependent claims.

Prior Art Relied Upon: Fleming (Patent 6,204,798) and Hoffberg (Patent 6,252,544).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that, should the Board find Fleming does not anticipate all limitations (particularly those related to laser detection), it would have been obvious to a person of ordinary skill in the art (POSITA) to combine the teachings of Fleming and Hoffberg. This combination would involve augmenting Fleming’s GPS-enabled radar detector with Hoffberg's disclosed LIDAR (laser) detector and communications subsystem.
- Motivation to Combine: A POSITA would combine these references to create an improved, more comprehensive warning receiver. The primary motivation was to enhance the position-based false alarm suppression taught by Fleming to also cover laser signals, which Hoffberg explicitly taught. Incorporating Hoffberg's communications subsystem would also allow the Fleming device to receive updated false alarm information from a remote database, a known method for improving system reliability.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. The integration of a LIDAR detector and a communications module into a GPS-based radar detector was a straightforward combination of known components for their intended purposes to yield predictable results—namely, a more robust device capable of filtering both radar and laser false alarms.

"Flag": Petitioner argued that, under the broadest reasonable construction, this term should be interpreted to mean "a code that identifies some condition." This construction was based on the ’905 patent specification, which describes using "flag bits" to identify various hazard conditions and potential police stakeout locations, supporting a broad definition beyond a specific data structure.
"Rejectable Signal": As this term was not explicitly defined in the ’905 patent, Petitioner proposed a broad construction to include "any signals that may be rejected based on the location with which they are associated." This interpretation was grounded in a passage from the patent’s summary section describing the invention as being capable of rejecting signals from any given location, which is critical for mapping prior art that suppresses alerts for known false alarm sources.

Petitioner requested institution of an inter partes review and cancellation of claims 1-6, 11-12, 15-18, 22-33, 36-39, 41-72, and 74-85 of the ’905 patent as unpatentable.