Zepp Labs Inc v. Blast Motion Inc

1. Case Identification

• Case #: IPR2016-00676
• Patent #: 8,905,855
• Filed: February 24, 2016
• Petitioner(s): Zepp Labs, Inc.
• Patent Owner(s): Blast Motion, Inc.
• Challenged Claims: 1, 3-9, 12-15, and 19

2. Patent Overview

• Title: System and Method for Utilizing Motion Capture Data
• Brief Description: The ’855 patent discloses a system for analyzing motion data captured by a portable wireless sensor element coupled to a user or piece of equipment. The system transmits the captured data to a mobile device, such as a smartphone, which runs an application to analyze, store, and display information related to the user's motion for applications in sports, healthcare, and gaming.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 5, 8, 9, 12, 13, 15, and 19 over Mahajan

• Prior Art Relied Upon: Mahajan (Application # 2006/0025229) and Lee (Patent 6,224,493), which is incorporated by reference into Mahajan.
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Mahajan teaches all elements of the challenged independent claims (1 and 19) and their dependents. Mahajan describes a motion tracking system (the "iClub") for a golf club that uses sensors, a microcontroller, memory, and a radio to capture and wirelessly transmit motion data to a mobile device (e.g., a PDA or cell phone) for analysis and display. This system maps directly to the claimed motion capture element and mobile device application. Mahajan further discloses multi-user capabilities, such as a golf instructor monitoring multiple students, which Petitioner contended meets the "monitoring user" limitations of claim 19 and the multi-user data access limitations of claim 1. Dependent claims related to storing data in a remote database (claim 5), displaying messages (claim 8), and displaying on a virtual reality display (claim 13) were also allegedly disclosed or rendered obvious by Mahajan's teachings.
  • Key Aspects: Petitioner noted that during prosecution of a related application, an International Searching Authority found similar claims to be obvious over Mahajan, supporting the position that a POSITA would find the claimed invention obvious without needing to combine references.

Ground 2: Obviousness of Claim 3 over Mahajan in view of Edis and Su

• Prior Art Relied Upon: Mahajan (Application # 2006/0025229), Edis (Application # 2010/0144414), and Su (Application # 2010/0323794).

• Core Argument for this Ground:

  • Prior Art Mapping: Claim 3 adds limitations requiring the microcontroller to detect events by comparing sensor values to thresholds, signify prospective events, and eliminate false positives to identify and save a valid event. While Mahajan implicitly suggests this functionality by distinguishing a "real swing" from a "warm up," Petitioner argued that Edis and Su provide explicit teachings. Edis discloses using specific sensor thresholds to identify and analyze different types of athletic motions (e.g., boxing punches) and expressly states its system could be used for golf. Su discloses a specific method for detecting and rejecting "false positives" in motion-based gaming by analyzing sensor data patterns within a defined time window.
  • Motivation to Combine: A POSITA would combine the specific thresholding and false-positive detection techniques of Edis and Su with the foundational system of Mahajan as an obvious implementation strategy. Doing so would provide a known and reliable method to realize Mahajan’s generalized goal of distinguishing valid athletic motions from invalid ones, improving the system’s accuracy and utility.
  • Expectation of Success: A POSITA would have a high expectation of success because all three references operate in the same technical field of microprocessor-based motion analysis for sports and gaming. Integrating the software-based event detection algorithms of Edis and Su into Mahajan's hardware system would be a straightforward application of known principles to achieve a predictable result.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including that claim 4 is obvious over Mahajan, Edis, Su, and Oleson (Application # 2009/0048044) for adding periodic or on-request data transmission; claim 6 is obvious over Mahajan, Oleson, and Gobush (Application # 2005/0272516) for adding the storage of demographic and equipment data; and claims 7 and 14 are obvious over Mahajan and Dugan (Application # 2008/0085778) for adding the comparison of motion data against historical or other users' data and transmission via text message.

4. Key Claim Construction Positions

• "said data": Petitioner argued this term is indefinite because its antecedent is unclear throughout the claims. However, if the Board were to construe the term, Petitioner proposed it should be interpreted as "data that comprises sensor values" to maintain consistency with the specification.
• "virtual reality display": Petitioner proposed construing this term based on its plain meaning and the specification to mean a display that enables a user to interact with a simulated environment that renders visual simulations of the user's physical movements.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1, 3-9, 12-15, and 19 of the ’855 patent as unpatentable.