PTAB

IPR2017-00245

Enforcement Video LLC v. Evicam Intl Inc

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1. Case Identification

2. Patent Overview

  • Title: Device and Method for Permanently and Securely Storing Incident Information
  • Brief Description: The ’013 patent discloses a system for capturing and storing data from a vehicle incident recording system. The system is designed to securely transfer this data to a remote location where it is processed into an integrated, verified, and indexed database for permanent storage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Joao in view of Odle and Freeman

Claims 1, 4, 8-12, 17-18, 27-28, 34-35, 45, 52, 58, and 60-61 are obvious over Joao in view of Odle and Freeman.

  • Prior Art Relied Upon: Joao (5,917,405), Odle (5,491,511), and Freeman (5,579,239).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Joao, the primary reference, discloses the core elements of the challenged claims, including an interconnected vehicle security system with video recording, data storage, remote access, and the use of access codes. However, Joao was alleged to have deficiencies that are remedied by Odle and Freeman. Specifically, Petitioner asserted that Freeman teaches the claimed "transfer device" by disclosing a portable personal computer with means for temporary data storage and video compression. Further, Petitioner contended that Odle teaches the claimed "means for generating an integrated, indexed database" by disclosing a system that stores digital records of transactions in a predefined database format and uses an index file to correlate video and digital data.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Joao with Freeman to satisfy Joao’s stated goal of achieving smaller size and greater portability, as Freeman’s portable computer is more compact than Joao's system components. Adding Freeman's compression capabilities would also predictably reduce video transmission times. A POSITA would have been motivated to combine Joao with Odle to create a comprehensive and searchable central database for vehicle monitoring, as organizing disparate data from Joao’s system into an indexed database as taught by Odle is a commonsense approach to improving data accessibility.
    • Expectation of Success: Petitioner asserted that combining these known elements—a vehicle security system (Joao), a portable data transfer unit (Freeman), and standard database indexing techniques (Odle)—involved predictable applications of existing technology and would have yielded the claimed system with a reasonable expectation of success.

Ground 2: Obviousness over Mackey

Claims 1, 4, 8-12, 17-18, 27-28, 34-35, 45, 52, 58, and 60-61 are obvious over Mackey.

  • Prior Art Relied Upon: Mackey (6,141,611).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Mackey, as a single reference, discloses all limitations of the challenged claims. Mackey describes a vehicular incident data system comprising an on-board mobile accident camera that captures and stores video data. This data is transferred, either via a hard-wired bus to a local personal computer or wirelessly to a central database server, which constitutes the claimed remote system and integrated database. Petitioner argued Mackey teaches a "transfer device" in the form of either a portable personal computer or a remote terminal, both capable of downloading data. Security is achieved through data encryption and the use of a "proper authorization code" to access the database. Finally, Mackey’s system indexes the data by applying a time/date stamp and a vehicle identification code to each record before it is stored in the central database.
    • Motivation to Combine: This ground is based on a single reference. However, Petitioner argued that to the extent Mackey did not explicitly require an authorization code for the local personal computer, it would have been obvious for a POSITA to do so. The motivation would be to maintain consistent security across all data access points, as Mackey already required a code for the remote terminal.
    • Expectation of Success: Petitioner argued that applying known security measures like authorization codes consistently across a system and using standard computer components for data transfer and storage were routine and predictable design choices for a POSITA.

4. Key Claim Construction Positions

  • "Transfer device": Petitioner noted that the patentee acted as its own lexicographer, defining this term in the specification as a portable computer system with input means, a transceiver for downloading and transmitting information, and means for temporary storage and compression. Petitioner’s arguments relied on this specific definition.
  • "Integrated, indexed database": Petitioner proposed this term be construed as "a compilation of recording system information that is searchable by at least one parameter," based on disclosures in the ’013 patent.
  • Limitations as Printed Matter: Petitioner argued that limitations in claims 8, 9, 17, 34, 60, and 61, which recite the informational content of the stored data (e.g., "vehicle dynamic information" or a specific "Vehicle Identification Number"), should be given no patentable weight. Petitioner contended these limitations represent non-functional printed matter without a new and unobvious functional relationship to the underlying database structure.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1, 4, 8-12, 17-18, 27-28, 34-35, 45, 52, 58, and 60-61 of the ’013 patent as unpatentable.