PTAB

IPR2015-00829

Toyota Motor Corp v. Innovative Display Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Emitting Panel Assemblies for Use in Automotive Applications and the Like
  • Brief Description: The ’956 patent describes a light emitting assembly for vehicle illumination. The assembly uses one or more light-emitting diodes (LEDs) to inject light into an edge of a light guide, which then uses deformities on its surface to extract and emit the light. A transparent substrate overlies the light guide to provide an exterior vehicle portion.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4-6, 9, and 31 are anticipated by Decker under §102(b).

  • Prior Art Relied Upon: Decker (German Unexamined Patent Specification No. DE 41 29 094 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Decker, which discloses a signal lamp for motor vehicles, teaches every limitation of the challenged claims. Decker’s assembly includes light guide elements (L) with LEDs at one end, which corresponds to the claimed light guide and LEDs. The light guides have an input surface for the LED, opposite sides, and conduct light for emission. Decker’s use of prisms (P) on one side of the light guide to reflect light out the opposite side was mapped to the claimed "light extracting deformities." The prisms constitute depressions and raised surfaces (claim 6). Decker's transparent end plate (A) was argued to be the claimed transparent substrate that overlies the light guides, is positioned against them (claim 4), covers them (claim 5), provides protection (claim 31), and forms an exterior vehicle portion. Finally, Decker's disclosure of LEDs arranged on a common printed circuit board was asserted to meet the "attached to a circuit" limitation (claim 9).

Ground 2: Claims 1, 4-6, 9, and 31 are obvious over Tsuboi in view of Asai, further in view of Gage and Lister.

  • Prior Art Relied Upon: Tsuboi (Japanese Laid Open Utility Model No. JPS57-60171), Asai (Japanese Laid Open Utility Model No. S61-153201), Gage (Optoelectronics/Fiber-Optics Applications Manual, 2d ed. 1981), and Lister (LEDs for exterior lighting, Automotive Engineer, Oct./Nov. 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Tsuboi discloses a vehicle lamp with most claimed features but uses a bulb light source instead of an LED. Tsuboi teaches a light guide plate with an input surface, deformities (serrated steps or prisms) to extract light, and an overlying transparent lens that forms an exterior vehicle surface. Asai, from the same company (Koito), was cited for its disclosure of an LED embedded in the edge of a similar wraparound lens (light guide) for vehicle lighting. Petitioner argued it would have been obvious to replace Tsuboi’s bulb with Asai’s more efficient and durable LED light source.
    • Motivation to Combine: A POSITA would combine Tsuboi and Asai because they are from the same field and company and address the same problem of providing uniform illumination in a vehicle lamp. A POSITA would look to subsequent publications like Asai to find improvements for the system in Tsuboi. Gage and Lister provided additional motivation by teaching the known benefits of LEDs in automotive applications, such as lower heat, increased reliability, and the ability to be directly coupled to a panel to reduce light loss (Fresnel loss), which would have been a predictable improvement.
    • Expectation of Success: Success was expected because it involved substituting a known, improved light source (LED) for an older one (bulb) in a known system to achieve predictable benefits taught by the art.

Ground 3: Claim 4 is obvious over Decker in view of Arima.

  • Prior Art Relied Upon: Decker (German Unexamined Patent Specification No. DE 41 29 094 A1) and Arima (Japanese Laid Open Unexamined Utility Model No. JPS62-201407).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addressed the limitation of claim 4 that the substrate is "positioned against" the light guide, in the event Decker was found not to explicitly teach direct physical contact. Petitioner argued Decker discloses all other features. Arima was introduced because it teaches positioning a light guide directly against a lens/substrate, showing various methods of affixing the two components in physical contact.
    • Motivation to Combine: A POSITA would combine Decker with Arima because Decker teaches advantages of flat and space-saving designs. Placing the substrate directly against the light guide, as taught by Arima, is an obvious way to achieve the flattest, most space-saving configuration. Both references relate to vehicle lighting systems using edge-lit panels, making the combination straightforward.
    • Expectation of Success: The combination involved applying a known technique (direct contact mounting from Arima) to a similar device (Decker's lamp) to achieve a predictable result (a more compact assembly).
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 4 over Decker in view of Tsuboi, relying on Tsuboi's teaching of welding or integrally forming the light guide and lens to satisfy the "positioned against" limitation.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the petition was not duplicative of other pending IPRs challenging the ’956 patent (IPR2015-00575 and IPR2015-00798). The petition was distinguished from IPR-00575 by relying on different primary prior art references. It was distinguished from IPR-00798, which also used Decker, by asserting a different statutory ground (anticipation under §102 instead of only obviousness) and by introducing different secondary references (Arima and Tsuboi) to address specific claim limitations.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 4-6, 9, and 31 of Patent 6,886,956 as unpatentable.