PTAB

IPR2017-00361

Unified Patents Inc v. Shipping Transit LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Automatically Providing Vehicle Status Information
  • Brief Description: The ’207 patent relates to systems for monitoring and reporting vehicle status. The technology’s asserted novelty is using a remote user's caller identification information (caller ID) to automatically identify an associated vehicle and transmit its status information, thereby eliminating the need for the user to manually provide identifying information to the system.

3. Grounds for Unpatentability

Ground 1: Obviousness over Peterson - Claims 1-15 are obvious over Peterson

  • Prior Art Relied Upon: Peterson (Patent 5,845,227).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Peterson discloses every element of the challenged claims. Peterson teaches a system for vehicle tracking and management centered around a central computer that communicates with GPS-equipped vehicles. Crucially, this central computer is configured to recognize a user’s caller ID or internet connection to provide location information and other services. Petitioner contended this system inherently includes a database for storing user and location data, a communication interface, and a system manager (the central computer) that performs the functions recited in independent claims 1, 5, and 10, including using caller ID to automatically retrieve and report vehicle status.
    • Motivation to Combine (for §103 grounds): This ground was asserted as a single-reference obviousness challenge. Petitioner argued that to the extent Peterson does not explicitly label its storage component a "database," it would have been obvious to a person of ordinary skill in the art (POSA) to use a standard database with Peterson’s central computer for storing and managing vehicle tracking information.
    • Expectation of Success (for §103 grounds): Implementing a known database structure within Peterson's computer-based tracking system would have yielded predictable and successful results.

Ground 2: Obviousness over Smith in view of Janky - Claims 1-15 are obvious over Smith in view of Janky

  • Prior Art Relied Upon: Smith (Patent 6,430,496) and Janky (Patent 5,794,174).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Smith discloses a comprehensive automated dispatch and monitoring system for transportation services (e.g., taxis), which includes a database server for storing vehicle status, an Automatic Vehicle Locator (AVL) system, and communication interfaces. While Smith’s system can receive service requests by telephone, Petitioner argued it does not explicitly teach using caller ID to automatically retrieve status. Janky was alleged to supply this missing element, as it describes a system that automatically provides a vehicle's location in response to a telephone request, explicitly teaching that each telephone is "uniquely addressable" and each user is "uniquely identifiable," thereby linking a specific caller to a specific vehicle.
    • Motivation to Combine (for §103 grounds): A POSA would combine Janky with Smith to improve Smith’s system. Both patents address the same field of vehicle location and dispatch. Adding Janky's functionality would automate the customer identification and vehicle lookup process in Smith’s dispatch system, replacing manual call-taker input with a more efficient, fully automated query-and-response system, which was an obvious improvement.
    • Expectation of Success (for §103 grounds): Combining the known, straightforward functionality of caller ID-based vehicle identification (Janky) with an existing automated dispatch system (Smith) involved well-understood technologies and would have led to the predictable result of an enhanced, more automated system.

Ground 3: Obviousness over Trask in view of Janky - Claims 1-15 are obvious over Trask in view of Janky

  • Prior Art Relied Upon: Trask (Patent 5,945,919) and Janky (Patent 5,794,174).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Trask discloses a "dispatcher free vehicle allocation" system that tracks vehicle positions and uses an Automatic Number Identification/Automatic Location Identification (ANI/ALI) system to determine a caller's geographic location for dispatch purposes. Trask thus provides a sophisticated vehicle tracking and dispatch system that uses caller ID. Janky was again used to supply the specific teaching of using the caller's unique phone number not just to find the caller, but to automatically retrieve and transmit the status of the vehicle associated with that caller.
    • Motivation to Combine (for §103 grounds): A POSA would combine Janky's teachings with Trask's system for the same reasons as with Smith: to increase automation and efficiency. By incorporating Janky’s method of linking a caller directly to their associated vehicle, Trask’s dispatcher-free system could be improved to handle automated status requests without any human (e.g., driver) intervention, a clear and desirable goal in the art.
    • Expectation of Success (for §103 grounds): The integration was based on conventional telecommunication and computer processing techniques, and a POSA would have had a high expectation of successfully implementing Janky’s functionality into Trask’s dispatch system.

4. Key Claim Construction Positions

  • Petitioner contended that several "means for..." phrases in claims 5 and 8 are means-plus-function limitations governed by pre-AIA 35 U.S.C. §112, ¶6, as they lacked sufficiently definite structure.
  • Petitioner proposed constructions for these terms by first identifying the claimed function (e.g., "maintaining status information associated with a vehicle") and then identifying the corresponding structure disclosed in the ’207 patent’s specification (e.g., "Base station 15... configured to store information... [and] a general-purpose computer having a database 72"). This interpretation was central to Petitioner's arguments, as the prior art references disclose similar computer-based structures performing the recited functions.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-15 of the ’207 patent as unpatentable.