PTAB

IPR2015-01415

Valeo North America Inc v. Magna Electronics Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: DRIVER ASSIST SYSTEM FOR VEHICLE
  • Brief Description: The ’330 patent discloses automotive driver assist systems designed to help a driver detect and avoid collisions. The systems utilize cameras and other sensors to monitor the vehicle's surroundings and provide visual and audible alerts to the driver.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lemelson, Schofield, Tokito, and Okada - Claims 8, 11-12, 16-17, 50-51, 53-54, 70-71, 73-74, and 84 are obvious over Lemelson in view of Schofield, Tokito, and Okada.

  • Prior Art Relied Upon: Lemelson (Patent 6,553,130), Schofield (Patent 5,670,935), Tokito (Patent 6,226,061), and Okada (EP 1170173).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lemelson, as the primary reference, disclosed nearly all features of the claimed driver assist system, including the use of cameras for front, side, and rear viewing, a video display, and object detection capabilities. Tokito was cited to teach a high-luminance display (over 200 candelas/sq. meter) suitable for daylight viewing, addressing a key limitation of the independent claims. Schofield was cited to explicitly teach switching an in-vehicle display to a rear-facing camera view when the vehicle's transmission is in reverse. Finally, Okada was added to teach an audible alert system where different sounds are issued corresponding to the distance to an object, fulfilling the limitation that an alert is provided as the vehicle reverses "closer and closer" to an object.
    • Motivation to Combine: A POSITA would combine these references to create a more robust and effective driver assist system. It would have been obvious to improve Lemelson’s system with a display bright enough for daylight use as taught by Tokito. Integrating Schofield’s conventional reverse-gear camera activation would be a predictable system improvement. A POSITA would also incorporate Okada’s proximity-based audible alerts into Lemelson’s warning system to provide more intuitive and useful feedback to the driver.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating well-known, conventional components (high-brightness displays, reverse-gear triggers, distance-based alarms) into an existing system architecture to achieve their predictable functions.

Ground 2: Obviousness over Lemelson, Schofield, Tokito, Okada, and Shimizu - Claims 42, 62, and 79 are obvious over the combination for Ground 1, further in view of Shimizu.

  • Prior Art Relied Upon: Lemelson (Patent 6,553,130), Schofield (Patent 5,670,935), Tokito (Patent 6,226,061), Okada (EP 1170173), and Shimizu (EP 1065642).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1. The challenged claims further required electronically generated indicia that "indicate distance to a detected object rearward of the equipped vehicle during a reversing maneuver." While Lemelson taught displaying "distance values," Petitioner introduced Shimizu to provide a more explicit teaching. Shimizu disclosed a vehicle drive-assist system that displays "distance lines" on the video feed to provide for easy recognition of distances to obstructive objects when reversing.
    • Motivation to Combine: A POSITA, seeking to enhance the utility of the visual alerts in the base combination, would be motivated to incorporate Shimizu's distance line overlay. This feature provides a direct, intuitive visual representation of distance on the display screen, which is a known and desirable improvement for parking and reversing assist systems.
    • Expectation of Success: The integration of graphical overlays onto a video display was a known technique. A POSITA would expect to successfully add Shimizu's distance line concept to the video display of the base combination with predictable results.

Ground 3: Obviousness over Lemelson, Schofield, Tokito, Kajimoto, and Millikan/He/Liu - Claims 19-21 are obvious over Lemelson, Schofield, and Tokito, further in view of Kajimoto and Millikan (claim 19), He (claim 20), and Liu (claim 21).

  • Prior Art Relied Upon: Lemelson (Patent 6,553,130), Schofield (Patent 5,670,935), Tokito (Patent 6,226,061), Kajimoto (Patent 5,920,367), Millikan (Patent 5,883,684), He (Patent 6,359,392), and Liu (Patent 6,593,011).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims reciting specific display hardware: a TFT liquid crystal display (LCD) backlit by a "plurality of white light emitting light emitting diodes." Petitioner argued Kajimoto taught a TFT LCD display for automotive use backlit by white-light LEDs. To counter an argument that Kajimoto taught only a single LED, Petitioner cited Millikan, which demonstrated that using a plurality of LEDs was a conventional design choice to ensure uniform backlighting and "prevent undesirable dark spots." For claims 20 and 21, which specified forward current ranges, Petitioner cited He and Liu as teaching the claimed operational current values for white LEDs.
    • Motivation to Combine: A POSITA designing a display for the base system would combine Kajimoto and Millikan for predictable results. If a single LED as suggested by Kajimoto was insufficient to uniformly light the display, it would have been an obvious engineering choice to use a plurality of LEDs as taught by Millikan. He and Liu simply provided guidance on conventional operating parameters for the selected components.
    • Expectation of Success: Using multiple light sources to illuminate a display was a common and well-understood practice. A POSITA would expect to successfully implement a multi-LED backlight for a TFT LCD with no undue experimentation.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds based on Turnbull (WO 01/80353) for navigation features (claims 34-38), a combination including Schaefer, Secor, and DeVries for a touch-sensitive rearview mirror display (claim 28), and a combination including Hsu and Breed for biometric seat adjustment (claims 31-33).

4. Key Claim Construction Positions

  • "at least one of (i) vvv, (ii) www, ...": Petitioner argued that, contrary to a potential conjunctive reading, the specification of the ’330 patent made clear this phrase was intended to introduce a disjunctive list of alternatives. Therefore, a teaching of any single element from the list in the prior art would be sufficient to render the claim element obvious.
  • "display intensity": Petitioner contended this term should be construed to mean "luminance." This construction was based on the patent's use of "candelas/sq. meter," the standard SI unit for luminance, which would have been understood by a POSITA at the time.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate because this petition was not the "same or substantially the same" as a previously filed petition (IPR2015-00250). Petitioner asserted that this petition presented new arguments and relied on different combinations of prior art, including several key references (Okada, Millikan, Shimizu, Turnbull, Breed) that were not cited during prosecution and were not considered in the prior IPR.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 8, 11-12, 16-17, 19-21, 28, 31-38, 42, 50-51, 53-54, 62, 70-71, 73-74, 79, and 84 of the ’330 patent as unpatentable.