PTAB

IPR2016-00887

Apple Inc v. Ji Soo Lee

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Providing Image-Based Traffic Information
  • Brief Description: The ’518 patent describes methods for efficiently transmitting and displaying image-based traffic information on a user device. The system transmits traffic data as compact "image vector entities" composed of attribute, shape, and position data, which are then used to render traffic conditions cumulatively over a basic map, avoiding the need to transmit large bitmap images.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fujitsu and Ichiura - Claims 45 and 46 are obvious over Fujitsu in view of Ichiura.

  • Prior Art Relied Upon: Fujitsu (a June 1995 article from the Fujitsu Ten Technical Journal) and Ichiura (Patent 5,734,780).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Fujitsu and Ichiura teaches every element of the challenged claims. Fujitsu, a 1995 article, discloses an in-vehicle system that receives and displays graphical traffic information as part of the Japanese Vehicle Information and Communication System (VICS). Fujitsu's system receives two types of vector-based data: time-invariant "underlying-picture data" for maps (the claimed "basic map") and time-variant "superposed" congestion data (the claimed "traffic state map"). The system then displays the congestion data cumulatively over the map, meeting the core method steps of claim 45.

    • Petitioner asserted that Fujitsu's "data blocks" for congestion graphics are equivalent to the claimed "time-variant image vector entities." These data blocks contain commands specifying drawing colors (the "attribute-designating statement"), graphic types like lines and circles (the "shape-designating statement"), and display locations determined by coordinates (the "position-designating statement"). Ichiura, which describes the broadcast signal format used by the VICS system in Fujitsu, discloses the hierarchical data structure that maps directly to the claimed "traffic information map" and "traffic state map." In Ichiura, a plurality of "data blocks" (image vector entities) form a "data group" (traffic state map), which is combined with a header to form a "program of graphic information" (traffic information map). Claim 46, a program storage device claim, was argued to be obvious for the same reasons, as Fujitsu explicitly discloses a microprocessor and ROM storing program instructions to perform the claimed method.

    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine the teachings of Fujitsu and Ichiura because they describe two complementary parts of the very same, pre-existing VICS system. Fujitsu describes the vehicle-based receiver and display, while Ichiura describes the specific data format of the FM multiplex broadcast signal that the receiver processes. A POSITA seeking to understand the VICS system would have naturally looked to both references to see how the transmitted data structure (Ichiura) was utilized by the end-user device (Fujitsu).

    • Expectation of Success: A POSITA would have had a high expectation of success because the references were not being combined to create a new system but were merely being used to understand the operation of a single, existing system. The predictable result was the efficient transmission and display of graphical traffic information, which was the known purpose of the VICS system they both describe.

4. Key Claim Construction Positions

Petitioner argued that the claim terms should be given their broadest reasonable construction and proposed the following interpretations based on the specification:

  • "image vector entity": Petitioner asserted that the claim language itself provides sufficient context, defining the term as a format of information that includes attribute, shape, and position designating statements.
  • "attribute-designating statement": Based on examples in the ’518 patent, Petitioner argued this term would at least encompass a statement designating a color.
  • "shape-designating statement": Based on the specification’s examples, Petitioner argued this term would at least encompass a statement designating a graphic type, such as a "line."
  • "position-designating statement": Based on the specification, Petitioner argued this term would at least encompass "one or more position coordinates" used to define the location of the vector.

5. Arguments Regarding Discretionary Denial

Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. The petition acknowledged a separate, previously filed inter partes review (IPR) against the ’518 patent (IPR2016-00045) but distinguished its petition on several grounds. Petitioner asserted that it was not a real party-in-interest in the earlier proceeding and that this petition relied on different prior art combinations, different arguments regarding the art, and new expert declaration testimony. Therefore, Petitioner argued, the instant petition presented new questions of patentability that had not been previously considered by the Patent Office.

6. Relief Requested

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