PTAB

IPR2017-00457

Daimler AG v. Stragent LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System, Method and Computer Program Product For Sharing Information In a Distributed Framework
  • Brief Description: The ’843 patent discloses software for sharing information between at least two heterogeneous networks (e.g., CAN, FlexRay, or LIN) in a distributed system. The architecture uses middleware that processes network-specific messages and stores the extracted data in a common, real-time "bulletin board" shared memory for access by different processes.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 47-51 are obvious over Posadas, Stewart, and Wense

  • Prior Art Relied Upon: Posadas (a May 2000 conference proceeding), Stewart (a July 1992 conference proceeding), and Wense (a 2001 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Posadas, discloses the core architecture of the challenged claims. Posadas described a real-time communication system for an autonomous robot that used two different networks (a CAN bus and an Ethernet bus) to share sensor data through a common "blackboard" shared memory. Petitioner contended this system met the limitations of two interfaces for two networks sharing data in real-time via a shared storage resource. For limitations related to memory access arbitration, Petitioner cited Stewart, which taught a real-time distributed system using a "spin-lock" mechanism to manage access to a shared global memory. This included determining memory availability, re-requesting access until a "polling time" threshold was met, and sending a time-out error notification. To meet the claim limitation requiring specific network types, Petitioner cited Wense, which taught that LIN and FlexRay networks were well-known and commonly used with CAN networks in distributed automotive systems.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Posadas with Stewart because both relate to real-time distributed control systems using shared memory. Adding Stewart’s well-known memory arbitration logic to Posadas’s system was argued to be a simple, predictable solution to prevent data corruption from concurrent memory access. A POSITA would also combine the resulting system with Wense because Posadas’s architecture was open to other network types ("and so on"). Wense demonstrated that LIN and FlexRay were known, suitable, and predictable choices for use in multi-network systems alongside CAN, making their integration a simple design choice.
    • Expectation of Success: The combination was asserted to be predictable. Integrating Stewart’s memory management would predictably solve concurrency issues, and substituting or adding Wense’s networks into Posadas’s flexible framework would predictably expand its compatibility without unexpected results.

Ground 2: Claims 1 and 47-51 are obvious over Miesterfeld, Stewart, and Wense

  • Prior Art Relied Upon: Miesterfeld (Patent 6,141,710), Stewart, and Wense.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Miesterfeld, disclosed a data sharing gateway in a vehicle for exchanging data between two different networks (an ITS data bus and a VDB bus) using a shared memory. Miesterfeld taught that the ITS bus could be a CAN network and disclosed a mechanism for determining memory availability before writing data. This met the core limitations of an apparatus with two interfaces and a shared memory. As in Ground 1, Petitioner relied on Stewart to teach the specific memory arbitration limitations not found in Miesterfeld, such as retrying a memory request if unavailable, determining if a threshold has been reached, and sending a notification upon timeout. Miesterfeld taught its second network was a J1850 network, which is not a claimed network type. Petitioner therefore relied on Wense to teach substituting the J1850 network with a LIN or FlexRay network.
    • Motivation to Combine: Petitioner argued a POSITA would combine Miesterfeld and Stewart because both references address real-time distributed control systems with shared memory architectures. Incorporating Stewart’s well-understood memory arbitration techniques into Miesterfeld’s system was presented as an obvious way to improve memory access control. A POSITA would have been motivated to replace Miesterfeld’s J1850 network with the networks taught by Wense because Miesterfeld expressly stated that other industry standards could be used. Wense showed that LIN was a well-known, cost-effective, and technically comparable alternative to the J1850 network in automotive systems, making the substitution an obvious design choice.
    • Expectation of Success: Petitioner contended the combination would have yielded predictable results. Adding Stewart's memory arbitration logic would predictably enhance Miesterfeld's system, and substituting the J1850 network with a LIN network as taught by Wense would predictably result in a functional, and potentially more cost-effective, system.

4. Key Claim Construction Positions

  • Petitioner argued that for the purposes of the IPR, the term "real-time" required construction.
  • Based on an explicit definition in the ’843 patent's specification, Petitioner proposed that "real-time" should be construed to mean: "any response time that may be measured in milli- or microseconds, and/or is less than one second." This construction was central to arguing that the prior art systems, which operated within these timeframes, met the real-time limitations of the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1 and 47-51 of Patent 8,566,843 as unpatentable.