PTAB

IPR2016-01559

Parrot SA v. QFO Labs Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Homeostatic Flying Hovercraft
  • Brief Description: The ’532 patent discloses a miniature, battery-powered, multi-thruster flying hovercraft. The invention features a "homeostatic" control system with a three-axis sensor to enable self-stabilization and a remote controller that uses its own two-axis orientation to control the hovercraft's movement.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 7-12, 14-19, and 21-23 are obvious over Louvel in view of Thomas and Jimenez.

  • Prior Art Relied Upon: Louvel (Application # 2002/0104921), Thomas (Patent 5,128,671), and Jimenez (Application # 2002/0106966).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary components of the challenged claims were disclosed across the combined references. Louvel taught a remote-controlled, four-thruster flying saucer with a "closed-loop" (homeostatic) control system that uses three attitude sensors to maintain stable flight. However, Louvel’s controller was connected by a physical cable. Jimenez disclosed a radio-controlled (RC) toy with an RF transmitter in the remote and an RF receiver in the vehicle, teaching the wireless communication link missing from Louvel. Thomas disclosed a handheld, free-standing controller with two sets of three-axis accelerometers to sense its own orientation and control an "output device," explicitly including an aircraft, such that the aircraft's flight path mimics the controller's motion.
    • Motivation to Combine: A POSITA would combine Louvel with Jimenez to replace the cumbersome physical cable with a known wireless RF link, a predictable improvement for a remote-controlled toy to increase range and reduce weight. A POSITA would further incorporate the controller from Thomas as a user-friendly and intuitive alternative to Louvel’s handle-based controller. Thomas expressly taught its motion-sensing controller could replace conventional aircraft controls, making it a simple substitution of one known input device for another to improve operability.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved implementing known wireless technology and substituting a known type of advanced controller into an existing aircraft platform, yielding only predictable results.

Ground 2: Claims 1, 5, 8, 12, 14, 15, 19, and 21 are obvious over Gordon in view of Thomas.

  • Prior Art Relied Upon: Gordon (a 1993 article titled "Rotorcraft Aerial Robot – Challenges and Solutions") and Thomas (Patent 5,128,671).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Gordon, an article describing a Georgia Tech autonomous helicopter, taught most key claim limitations. Gordon disclosed a remotely controlled aerial vehicle with an on-board "flight control system" to stabilize flight and track commands, constituting a homeostatic system. This system used a "six sensor suite" including linear accelerometers to detect a gravity vector for attitude determination. The vehicle was controlled via a standard RC transmitter. As in Ground 1, Thomas supplied the missing element: a handheld controller that uses its own sensed motion to direct the aircraft.
    • Motivation to Combine: The motivation to combine Gordon and Thomas was analogous to the motivation for combining Louvel and Thomas. Both Gordon and Thomas operate in the narrow field of controlling unmanned aircraft. A POSITA would combine the teachings to replace Gordon’s conventional RC transmitter with the more advanced and user-friendly motion-sensing controller from Thomas. This combination represented a routine design choice to enhance the user interface, which Thomas explicitly suggested for controlling aircraft like helicopters.
    • Expectation of Success: A POSITA would expect this combination to work predictably. Integrating the signal output from the Thomas controller into the Gordon flight system was a straightforward engineering task, as Gordon’s system was already designed to receive external commands from a remote pilot.

  • Additional Grounds: Petitioner asserted additional obviousness challenges. One ground added Yavnai (Patent 6,588,701) to the Louvel/Thomas/Jimenez combination, arguing Yavnai’s explicit teaching of ducted fans for aerodynamic efficiency and safety rendered claims requiring ducts obvious. Other grounds added Gabai (Application # 2001/0021669) to both the Louvel and Gordon combinations, arguing Gabai’s disclosure of sending software updates to a toy via an internet connection made claims requiring this feature obvious.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of the ’532 patent as unpatentable.