PTAB

IPR2015-00849

Google Inc v. American Navigation Systems Inc

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1. Case Identification

2. Patent Overview

  • Title: HAND-HELD GPS-MAPPING DEVICE
  • Brief Description: The ’347 patent discloses a portable navigation device that processes and stores map image data. The purported improvement involves dividing a large map image into smaller square arrays, or "tiles," to allow the device to display portions of the map without loading the entire decompressed image into its limited memory.

3. Grounds for Unpatentability

Ground 1: Obviousness over DeLorme and Fedra - Claims 5, 8, and 10 are obvious over DeLorme in view of Fedra.

  • Prior Art Relied Upon: DeLorme (Patent 5,848,373) and Fedra ("Hybrid Geographical Information Systems," EARSeL Advances in Remote Sensing, 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DeLorme disclosed all structural elements of independent claim 5. DeLorme taught a portable computer-aided map location system (CAMLS), such as a PDA, with a GPS receiver that displays a user's location on a map. Crucially, DeLorme’s system displayed this map as a "generalized display of grid quadrangles," which Petitioner asserted is equivalent to the ’347 patent’s "plurality of tile data." Petitioner contended that DeLorme also taught a data structure with header information and pointers ("links"). To the extent DeLorme's header was found not to explicitly describe the size of each tile, Petitioner asserted Fedra supplied this teaching. Fedra, a publication on geographical information systems (GIS), disclosed storing map data in "Grid cell files" where each tile's header includes its "size and position," including "geographic boundaries" and a "compress indicator."
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine DeLorme and Fedra for several reasons. A POSITA would have sought to improve the data compatibility of DeLorme's system for use with other GIS applications, as suggested by Fedra. Including explicit size and location data in the tile header, as taught by Fedra, was a known technique to improve data portability and would have yielded the predictable result of a more robust and interoperable mapping system.
    • Expectation of Success: The combination was presented as a straightforward application of a known data structuring technique (Fedra's detailed headers) to a known type of system (DeLorme's tiled mapping device) to achieve the predictable benefits of improved data management.

Ground 2: Obviousness over DeLorme, Fedra, and Beckwith - Claims 6 and 7 are obvious over DeLorme in view of Fedra and Beckwith.

  • Prior Art Relied Upon: DeLorme (Patent 5,848,373), Fedra, and Beckwith (Patent 5,140,532).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address dependent claims 6 and 7, which require a "peripheral routine" for decompressing adjacent tiles and a "projection routine" for decompressing tiles in the user's path of movement. Petitioner argued that DeLorme disclosed these features by teaching "obvious buffering techniques" that involve pre-loading data for "adjacent grid quadrangles." To further support this, Petitioner introduced Beckwith, which disclosed a dynamic visual map for an aircraft. Beckwith’s system explicitly tracked the aircraft's movement and determined which new "blocks of data" (tiles) were required based on heading and position, pre-loading them from storage to ensure a valid display.
    • Motivation to Combine: A POSITA would combine Beckwith’s predictive loading with the DeLorme/Fedra system to improve performance. This would allow for quicker, more seamless map updates as a user moves, a well-known goal in digital mapping systems. The combination was merely applying a known method for improving dynamic map displays to yield the predictable result of smoother navigation.

Ground 4: Obviousness over Israni and Fedra - Claims 5, 8, and 10 are obvious over Israni in view of Fedra.

  • Prior Art Relied Upon: Israni (Patent 5,968,109) and Fedra.

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative primary reference for invalidating the independent claim. Petitioner argued that Israni disclosed a complete computer-based navigation system where geographic data is organized into smaller groupings called "parcels" (tiles) to solve the same data storage problem addressed by the ’347 patent. Israni taught storing these parcels in a compressed format and decompressing them as needed. Petitioner asserted Israni also disclosed header data and pointers ("keys") that describe the parcel and are used to navigate within it. As in Ground 1, Fedra was cited as a secondary reference to cure any potential deficiency in Israni's disclosure of header data that explicitly describes both the size and geographical location of each tile.
    • Motivation to Combine: The motivation was identical to that in Ground 1: a POSITA would have been motivated to incorporate Fedra’s explicit header data structure into Israni’s system to improve integration with other systems and enhance data portability, which were known goals in the field of GIS.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations based on DeLorme and Israni that added Muller (Patent 5,839,080), TIFF, and JPEG specifications to explicitly teach header data elements required by claim 9 (e.g., number of tiles, number of pixels, aspect ratio). The petition also included parallel grounds using Israni as the primary reference in combination with Beckwith to challenge claims 6 and 7.

4. Key Claim Construction Positions

  • "header data describing the size . . . of each tile" (claim 5): Petitioner proposed this be construed as "data in a file header indicating the size of a geographic area associated with a tile." This construction was argued to be consistent with the specification's use of "size" to refer to geographic area.
  • "pointer" (claims 5 and 10): Petitioner proposed this term be construed as "information identifying the location of data." This broad construction was argued to be consistent with its ordinary meaning and the patent's specification.
  • Preamble (claim 5): Petitioner argued that under the broadest reasonable interpretation standard, the preamble reciting a "device for personal, portable mapping and navigation" is not a limitation but merely states an intended use.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 5-10 of the ’347 patent as unpatentable.