PTAB

IPR2016-00045

Google Inc v. Lee Ji Soo

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1. Case Identification

2. Patent Overview

  • Title: Method and System for Providing Image Vector-Based Traffic Information
  • Brief Description: The ’518 patent discloses a method for displaying traffic information that purports to improve over conventional bitmap-based image systems. The invention aims to reduce the bandwidth required for transmission by using "image vector-based traffic information" that is sent to a user device and rendered locally.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 45 and 46 under §102 by Sone

  • Prior Art Relied Upon: Sone (Patent 5,313,200).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sone discloses every element of independent claims 45 and 46. Sone describes a "traffic congestion display system" that receives "traffic information" containing "congestion data sets." Petitioner contended this traffic information constitutes the claimed "traffic information map," and the "congestion data sets" constitute the "traffic state map." Sone’s data sets, which include coordinate pairs for the start and end of congestion, information on congestion degree (e.g., by color), and the length and direction of congestion, were argued to inherently teach a "time-variant image vector entity" comprising an "attribute-designating statement," a "shape-designating statement," and a "position-designating statement." The system displays this information superimposed on a road map, meeting the final limitations.

Ground 2: Obviousness of Claims 45 and 46 under §103 over Sone in view of Roy

  • Prior Art Relied Upon: Sone (Patent 5,313,200) and Roy (Patent 5,966,135).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative, arguing that if the "image vector entities" of the challenged claims are interpreted narrowly to require an explicit "vector-based format," the combination of Sone and Roy renders the claims obvious. Sone provides the foundational traffic display system. Roy explicitly discloses the conventional practice of transmitting "vector-based map data" (including primitives like lines defined by coordinates) to client devices for efficient map generation and viewing over a network.
    • Motivation to Combine: Petitioner asserted multiple motivations. A person of ordinary skill in the art (POSITA) would combine Roy's efficient vector-based data transmission with Sone's traffic display system to improve performance, reduce bandwidth, and enable features like seamless zooming and panning, which are advantageous for map applications. This was presented as the predictable use of a known technique (vector graphics) to improve a similar device (a map display system).
    • Expectation of Success: A POSITA would have a high expectation of success, as both references relate to map display systems, and using vector data for such systems was a well-established and reliable technique at the time.

Ground 3: Obviousness of Claims 45 and 46 under §103 over Yamada in view of Rosenquist

  • Prior Art Relied Upon: Yamada (JP Patent No. JPH 09-252260) and Rosenquist (WO 95/24029).
  • Core Argument for this Ground:
    • Prior Art Mapping: Yamada discloses a "traffic information display system" that receives traffic data from beacons and displays "vector traffic jam information" superimposed on a map. The vectors represent traffic delays and are appended to road links. This teaches the core elements of receiving and displaying vector-based traffic data. Rosenquist discloses a traffic information system with advanced user interface features, such as using a variety of colors and symbols to represent different traffic conditions (e.g., red for stationary traffic, a star symbol for an incident).
    • Motivation to Combine: A POSITA would be motivated to modify Yamada's system by incorporating the more sophisticated display features from Rosenquist. Adding distinct colors and symbols as taught by Rosenquist would make Yamada's display more intuitive and allow a user to quickly understand the nature and severity of different traffic events, thereby improving the overall utility of the system.
    • Expectation of Success: The combination involved applying known graphical user interface principles from one traffic information system to another to enhance usability. This was a straightforward design choice with a predictable and successful outcome.
  • Additional Grounds: Petitioner asserted additional anticipation challenges under 35 U.S.C. §102, arguing claims 45 and 46 are anticipated by Kakihara (Patent 5,293,163) and separately by Degawa (JP Patent No. JPH 08-7197), both of which disclose navigation systems that receive and display vector-based traffic information on a map.

4. Key Claim Construction Positions

  • "image vector entity": Petitioner proposed the construction "a data structure including at least shape and position information for a real entity." This construction, argued under the broadest reasonable interpretation standard for IPRs, is critical to the invalidity arguments. It allows prior art that describes traffic data with shape and position attributes (e.g., start/end coordinates of a jam) to meet the claim limitation, even if the reference does not explicitly use the term "image vector entity."
  • "attribute-designating statement," "shape-designating statement," and "position-designating statement": Petitioner proposed constructions for these terms as simple indications of an attribute, shape, or position for the image vector entity. This approach supports mapping prior art data structures that contain information such as congestion severity (attribute), length (shape), and location coordinates (position).

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 45 and 46 of the ’518 patent as unpatentable.