Secured Mobility LLC v. Zonar Systems Inc

1. Case Identification

• Case #: IPR2015-01043
• Patent #: 6,502,030
• Filed: April 13, 2015
• Petitioner(s): Secured Mobility LLC
• Challenged Claims: 1-16

2. Patent Overview

• Title: Web Based Vehicle Tracking and User On-Board Status System
• Brief Description: The ’030 patent describes a vehicle tracking system that uses a passenger identification device to register when a passenger boards and disembarks. A vehicle information system communicates with a remote base station, which a user can access via the Internet to determine if a passenger is on board the vehicle.

3. Grounds for Unpatentability

Ground 1: Obviousness over Truett and Rossetti - Claims 1-16 are obvious over Truett in view of Rossetti.

• Prior Art Relied Upon: Truett (a 1998 conference paper titled "Bus 54—Where Are You? A School Bus Intelligent Information System") and Rossetti (a 1999 technical report titled "Field Testing and Evaluation of the Transit Integrated Monitoring System").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Truett disclosed a web-based system for monitoring the location of a school bus via GPS and making that information available to parents and administrators over the Internet. This system included a vehicle information system (on-board computer, GPS, wireless modem) and a base station network administrator (central processing facility with a web server). However, Truett only suggested rudimentary passenger tracking via video. Petitioner contended that Rossetti remedied this deficiency by disclosing a system that used smartcards (RFID tags) and an on-board reader to automatically identify and log individual passengers as they board and alight a bus, thereby monitoring their on-board status. The combination of Truett's web-based vehicle tracking with Rossetti's automated passenger identification taught all limitations of the challenged claims.
  • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references to solve a known problem. Truett addressed parental anxiety by tracking the bus, but a POSITA would recognize that parents are primarily concerned with their child's status, not just the bus's location. Rossetti provided the well-known technology to track individual passengers. Combining Rossetti's passenger tracking with Truett's web-based communication system was an obvious step to provide parents with more meaningful information (i.e., confirming their child was actually on the tracked bus), thereby better addressing the explicit goal of reducing parental panic.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating known, compatible technologies (GPS, RFID, web servers, wireless communication) for their intended purposes.

Ground 2: Obviousness over Truett, Rossetti, and MacLellan - Claims 12-16 are obvious over Truett, Rossetti, and MacLellan.

• Prior Art Relied Upon: Truett (a 1998 conference paper), Rossetti (a 1999 technical report), and MacLellan (Published European Patent Application EP 0851377).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Truett and Rossetti to specifically address limitations in claims 12 and 16 requiring the system to be configurable for tracking "cargo." While Truett and Rossetti focused on passengers, Petitioner argued MacLellan explicitly disclosed a "passenger, baggage, and cargo reconciliation system" for airports. MacLellan taught using the same type of RFID technology disclosed in Rossetti to track not only passengers but also baggage and cargo.
  • Motivation to Combine: Petitioner asserted that if a POSITA sought to extend the passenger tracking system of Truett and Rossetti to also track items, MacLellan provided an explicit roadmap. It would have been obvious to apply the known technique of using RFID tags for cargo, as taught by MacLellan, to the combined Truett/Rossetti system. This would allow the system to track valuable items like backpacks or musical instruments, a predictable and desirable enhancement.
  • Expectation of Success: The expectation of success was high, as it merely involved applying the same RFID technology from Rossetti to a different type of object (cargo), a use explicitly demonstrated as feasible by MacLellan.

Ground 3: Obviousness over Camhi and Brown - Claim 1 is obvious over Camhi in view of Brown.

• Prior Art Relied Upon: Camhi (Patent 6,762,684) and Brown (International Publication No. WO 00/46772).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground presented an alternative theory for invalidity. Petitioner argued Camhi disclosed a non-web-based system for monitoring children on a school bus, which included a vehicle information system, a passenger identification device (sensor), and communication with a central station to monitor on-board status and notify parents of drop-offs. Brown disclosed a generic web-based system using a web host to allow remote users to track the location of an individual carrying a personal location unit via the Internet. Petitioner contended that replacing Camhi’s communication link with Brown’s web-based architecture would result in the system of claim 1.
  • Motivation to Combine: A POSITA would combine the references to improve Camhi’s system. Camhi’s system used direct communication links (radio, cellular, wired), while Brown taught using a scalable web host accessible to "literally millions of individuals." A POSITA would integrate Brown’s web-based approach into Camhi's system to provide more parents and administrators with easier, lower-cost access to the tracking data.
• Additional Grounds: Petitioner asserted further obviousness challenges against claims 2-16 based on the combination of Camhi, Brown, and Schmier (Patent 6,006,159). Schmier was cited for teaching ancillary features, such as a driver computer interface with "signal buttons" for emergencies, which Petitioner argued were obvious additions to the core system disclosed by Camhi and Brown.

4. Key Claim Construction Positions

• Preamble of Claim 1: Petitioner argued the preamble phrase "A web based system for monitoring the travel of a vehicle" is not limiting because the body of the claim recites a structurally complete invention, and the preamble merely states an intended use.
• "Web Based System": Petitioner contended this term should be given its plain and ordinary meaning or construed as a "system that communicates using the World Wide Web." This position was asserted to counter a potentially narrower construction importing limitations from the specification.
• "Monitor the on-board status...": Petitioner argued this phrase should be construed simply as "receiving information indicating whether at least one identified passenger is located in the vehicle," without adding extraneous limitations related to how or when the information is received.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-16 of the ’030 patent as unpatentable.