PTAB

IPR2015-00697

Under Armour Inc v. adidas AG

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1. Case Identification

2. Patent Overview

  • Title: Personal Data Collection System
  • Brief Description: The 7,905,815 patent discloses a modular personal data collection system that uses multiple, individual, portable device modules worn or carried by a user. These modules, such as media recorders and personal data sensors, collect various types of data that can be stored, tagged, and wirelessly transmitted to a remote base station for analysis and storage.

3. Grounds for Unpatentability

Ground 1: Claims 1-15 are obvious over Mault in view of Guck.

  • Prior Art Relied Upon: Mault (Patent 6,513,532) and Guck (Patent 5,864,870).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mault disclosed nearly all elements of the challenged claims. Mault taught a wearable activity monitoring system (e.g., wristwatch or belt-mounted) that functioned as both a "personal data collection device" (collecting heart rate, position, acceleration) and a "media recording device" (recording audio/video of food consumption). This data was stored in a wearable memory device and could be downloaded to a home PC (the "base station") via a communication transceiver. Mault also taught tagging collected data, such as annotating food consumption entries with location data from GPS. Petitioner contended that the only limitations Mault did not explicitly disclose were storing data in a "database" and converting it to a "common file format." To remedy this, Petitioner asserted that Guck, which taught a system for storing and retrieving files from clients in an object database and converting files to common formats (e.g., JPEG), supplied these missing elements.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Mault and Guck to improve the functionality of Mault's system. Both patents related to managing data collected from remote devices at a central location. A POSITA would have recognized that using a database, as taught by Guck, was a well-known and efficient method to store, organize, and link the various tagged data points collected by the Mault system. Similarly, converting data to a common file format was a predictable solution to ensure that data downloaded from the Mault device could be easily viewed and manipulated on a standard home PC.
    • Expectation of Success: The combination involved applying conventional data storage (database) and management (common file formats) techniques from Guck to the known type of data collection system in Mault, leading to a high expectation of success.

Ground 2: Claims 1-15 are obvious over Newell in view of Guck.

  • Prior Art Relied Upon: Newell (Patent 6,466,232) and Guck (Patent 5,864,870).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Newell disclosed a modular personal data collection system with various body-worn components that met the limitations of claim 1. Newell’s system included "body-worn user sensor devices" (e.g., for heart rate, EKG, location, speed) and "body-worn user input devices" (e.g., microphone, digital cameras) that communicated with a "body-mounted computer" containing storage. This body-mounted system, in turn, communicated wirelessly with a non-portable computer (the "base station"). Petitioner highlighted that Newell’s system created a "Model of User Condition" table that explicitly tagged various collected data points (e.g., location, heart rate, speed) with the current time and user ID, thus teaching the tagging limitation. As in Ground 1, Petitioner relied on Guck to supply the "database" and "common file format" limitations not explicitly taught by Newell.
    • Motivation to Combine: The motivation to combine Newell and Guck was similar to that for Mault and Guck. Newell’s system collected and organized large amounts of personal data into tables. Petitioner argued a POSITA would have been motivated to use a database structure, as taught by Guck, as an efficient and conventional way to implement the underlying storage for Newell's data tables and to facilitate the linking of tagged data. The motivation to use common file formats was to ensure the data transmitted from the wearable system was compatible with various base stations or other computer systems, a common problem with a predictable solution.
    • Expectation of Success: Integrating Guck's known database and file conversion methods into Newell's data collection framework was presented as a straightforward application of known technologies to achieve predictable results.

4. Key Claim Construction Positions

  • "collected data" (claims 1, 15): Petitioner argued this term should be interpreted to mean data collected by either the personal data collection device or the media recording device. This construction was central to showing that references like Mault met the limitation of allowing a user to "tag collected data with other collected data" (e.g., tagging a media file with location data).
  • "at least two of the devices are separately worn or carried" (claims 1, 15): Petitioner proposed this meant that at least two of the four claimed device types (personal data collection, media recording, storage, communication) are physically distinct and separate when worn by the user, not merely different software functions in a single housing. This was used to map onto prior art systems showing, for example, a separate heart rate strap and a main recording unit.
  • "common file format" (claim 13): Petitioner argued this term meant any standard, non-proprietary file format that permits easy use and access, such as HTML or JPEG. This construction was critical for asserting that Guck’s teachings on file conversion were applicable.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-15 of Patent 7,905,815 as unpatentable.