PTAB

IPR2015-00851

Google Inc v. American Navigation Systems Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: HAND-HELD GPS-MAPPING DEVICE
  • Brief Description: The ’347 patent is directed to a portable device for viewing map images corresponding to a user's location. The patent purports to address memory limitations in handheld devices by dividing a large map image into a plurality of smaller square arrays or "tiles," enabling the device to display portions of the map without loading the entire uncompressed image into memory.

3. Grounds for Unpatentability

Ground 1: Obviousness over Muller and Steiner - Claims 5-10 are obvious over Muller in view of Steiner.

  • Prior Art Relied Upon: Muller (Patent 5,839,080) and Steiner (Patent 5,528,248).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Muller disclosed a terrain awareness system for aircraft that performs the core functionalities of the ’347 patent, including using a GPS for location, an image storage unit (terrain database), a display, and a computer program to process and display the map data. Crucially, Muller taught organizing its terrain database by dividing the world into a plurality of subsquares or map files (tiles), which together represent a map image, and included header data, pointers, and compressed data for these tiles, thus teaching the limitations of independent claim 5.
    • Motivation to Combine: Steiner disclosed a "Personal Digital Location Apparatus" in a handheld PDA format for displaying a geographical location on a map. Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Muller's aircraft navigation system with Steiner's handheld PDA form factor to achieve predictable benefits. These benefits included making the system portable to easily move between vehicles, avoiding costly FAA certification for permanently installed equipment, and allowing the device to be used for other applications.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying a known technique (portability via a PDA from Steiner) to a known system (the tiled mapping system of Muller) to yield predictable results without altering the primary function of either.

Ground 2: Obviousness over Beckwith and Steiner - Claims 5-8 and 10 are obvious over Beckwith in view of Steiner.

  • Prior Art Relied Upon: Beckwith (Patent 5,140,532) and Steiner (Patent 5,528,248).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Beckwith, like Muller, disclosed a digital system for the dynamic display of terrain data for a vehicle, such as an aircraft. Beckwith’s system stored compressed terrain data in discrete blocks (tiles) and used a computer to decompress and display a moving map based on the vehicle's position. Petitioner argued Beckwith disclosed all elements of independent claim 5, including a processor, storage unit, display, and a computer program that processes tiled map data containing headers and pointers.
    • Motivation to Combine: The motivation to combine Beckwith with Steiner was identical to that in Ground 1. A POSITA would have been motivated to implement Beckwith's dynamic map display system in Steiner's handheld PDA form factor to gain the known advantages of portability, cost savings, and versatility.
    • Expectation of Success: Petitioner argued the combination would have yielded predictable results, as it involved housing a known mapping system (Beckwith) in a standard portable device (Steiner), a common practice in the mid-1990s.

Ground 3: Obviousness over Beckwith, Steiner, Fedra, and Image Format Standards - Claim 9 is obvious over Beckwith in view of Steiner, Fedra, GeoTIFF, TIFF, and JPEG.

  • Prior Art Relied Upon: Beckwith (Patent 5,140,532), Steiner (Patent 5,528,248), Fedra (a 1992 journal article), GeoTIFF (1995 specification), TIFF (1992 specification), and JPEG (1992 specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 2, specifically targeting dependent claim 9, which requires the header data to contain detailed information about the file structure (e.g., number of tiles, tile size, number of pixels, aspect ratio, and geographic interpolation parameters). Petitioner argued that while Beckwith and Steiner taught the base invention, the additional prior art showed that including such specific information in a file header was a conventional and well-known practice for digital image formats at the time. Fedra taught cell headers with geographic boundaries and resolution. The TIFF, GeoTIFF, and JPEG standards explicitly disclosed storing this type of metadata (e.g., tile offsets, pixel dimensions, tie-point tags) in file headers.
    • Motivation to Combine: A POSITA would combine the teachings of these standard image formats with the Beckwith/Steiner system to ensure data interoperability, allow for easy importation into other mapping systems, and access images more efficiently. Using established standards like TIFF and JPEG was a predictable design choice to achieve these benefits.
    • Expectation of Success: Success was expected because the combination merely involved applying conventional data formatting standards to the known mapping system of Beckwith, a routine implementation task for a POSITA.

4. Key Claim Construction Positions

  • "mounted" (claim 5): Petitioner proposed the construction "physically located in or housed in," arguing this was consistent with the specification's description of components within a device case.
  • "header data describing the size . . . of each tile" (claim 5): Petitioner proposed this means "data in a file header indicating the size of a geographic area associated with a tile," arguing the patent uses "size" to refer to geographic area.
  • "pointer" (claims 5 and 10): Petitioner proposed the construction "information identifying the location of data," consistent with the term's ordinary meaning and its use in the specification.

5. Relief Requested

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