PTAB

IPR2014-00220

Valeo GmbH v. Magna Electronics Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Vision System for a Vehicle Including Image Processor
  • Brief Description: The ’565 patent is directed to a multi-camera vision system for motor vehicles. The system uses at least two vehicle-mounted image capture devices with overlapping fields of view, an image processor that synthesizes the captured image portions into a single composite image without duplication, and an in-vehicle display for the driver.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nissan - Claims 1-3, 5-9, 11-15, 25-26, 28-29, 41-44, 46-47, and 49 are obvious over Nissan.

  • Prior Art Relied Upon: Nissan (Japanese Publication No. JP3099952).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nissan alone renders the majority of the challenged claims obvious. Nissan disclosed a vehicle surroundings monitoring system with a plurality of cameras, an image processor capable of image synthesis, and a display. Petitioner contended that Nissan’s disclosed perspective transformation, which converts images into a single coordinate system to be combined, inherently performs the geometric alignment necessary to remove duplication from overlapping image areas. This, Petitioner argued, meets the key limitations of creating a "composite image" "without duplication of image information." Nissan also disclosed displaying the synthesized image on a single monitor viewable by occupants, satisfying the display limitations of independent claim 1.
    • Key Aspects: Petitioner emphasized that many of the dependent claims recite features also explicitly disclosed or made obvious by Nissan, such as cameras on opposite sides of the vehicle, night-vision capability (infrared cameras), and dynamic adjustment of the field of view based on vehicle speed.

Ground 2: Obviousness over Nissan and Wang - Claims 4, 17, and 27 are obvious over Nissan in view of Wang.

  • Prior Art Relied Upon: Nissan (Japanese Publication No. JP3099952) and Wang (an 1991 IEEE publication titled "CMOS Video Cameras").
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses dependent claims requiring the image capture devices to comprise CMOS imaging arrays. Petitioner argued that while Nissan provided the complete base vision system, it broadly stated that any suitable camera could be employed. Wang was presented as evidence that using CMOS pixelated arrays for capturing video sequences was well-known in the art prior to 1995.
    • Motivation to Combine: A POSITA would combine Nissan and Wang because it would have been a simple and predictable substitution of one known image sensor type (CMOS, taught by Wang) for another in the system taught by Nissan. Given Nissan’s disclosure that any suitable camera could be used, a POSITA would have naturally looked to known and available camera technologies like CMOS.
    • Expectation of Success: A POSITA would have had a high expectation of success in making this substitution, as CMOS sensors were a known and functional equivalent for other types of image sensors used in video applications at the time.

Ground 3: Obviousness over Nissan and Aishin - Claims 16, 30-31, 40, 45, and 48 are obvious over Nissan in view of Aishin.

  • Prior Art Relied Upon: Nissan (Japanese Publication No. JP3099952) and Aishin (Japanese Publication No. JP A64-14700).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground challenges claims that add an electronically generated graphic overlay to the composite image to enhance the driver's ability to maneuver, particularly rearwardly. Nissan provided the base multi-camera composite image system. Aishin disclosed a display system for a vehicle that superimposes an image of a predicted vehicle path onto the projected camera image, providing additional information to the driver during maneuvers.
    • Motivation to Combine: A POSITA would combine Nissan’s vision system with Aishin’s graphic overlay to improve the safety and functionality of the system. Providing predictive path information, as taught by Aishin, was a known method for aiding drivers during difficult maneuvers like reversing, making it a desirable and logical enhancement for the visual display system of Nissan.
    • Expectation of Success: Success would have been expected, as superimposing computer-generated graphics onto a video display was a well-understood and implemented technology.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combining Nissan with Bendell (Patent 4,532,550) to teach variable exposure cameras; combining Nissan with Aishin and Wang to add CMOS sensors to the graphic overlay system; and combining Nissan with Aishin and Niles (Japanese Publication No. 59-114139) to add dynamically adjustable distance indicia to the graphic overlay.

4. Key Claim Construction Positions

  • "composite image": Petitioner argued this term, added during prosecution, should be construed to mean "a single, combined image." This construction was based on arguments made to the examiner and disclosures in the specification.
  • "without duplication of image information": Petitioner argued this phrase, also added during prosecution to achieve allowance, should be construed to mean that "there is minimal multiple exposure in the composite image." Petitioner asserted this narrower construction was supported by the prosecution history and was critical to overcoming prior art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-49 of the ’565 patent as unpatentable.