PTAB

IPR2017-00565

Unified Patents Inc v. Societa Italiana per Lo Sviluppo Dell'EletTronica Spa

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems for Guiding Vehicles
  • Brief Description: The ’580 patent describes a system for centrally controlling vehicle traffic on a road network. The system requires each participating vehicle to have an identifier, log into a central data network, and report its position and speed, enabling a traffic information center to provide dynamic, optimized route guidance based on a comprehensive view of traffic conditions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gazis, Oates, and Anagnostopoulos - Claims 1-8 and 10-11 are obvious over Gazis in view of Oates and Anagnostopoulos.

  • Prior Art Relied Upon: Gazis (Patent 5,610,821), Oates (UK Patent Application 2,288,892), and Anagnostopoulos (WO 1993/05492).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gazis taught the foundational system claimed in the ’580 patent: a centralized Traffic Management Center (TMC) that performs holistic, optimal route planning. Gazis disclosed that its system receives data from in-vehicle units and that each vehicle computer is assigned an IP address, effectively serving as an identifier for logging into the network. Petitioner asserted that Oates supplemented this by teaching a fleet management system where vehicles report detailed parameters—such as engine and chassis numbers, speed, and position—to a remote data analyzer for performance monitoring. Finally, Anagnostopoulos was cited for teaching a routing system where a central authority ("Traffic Police") can re-route vehicles based on unique identifiers, including vehicle type (e.g., truck, ambulance) and license plate number, to manage traffic. The combination of these references, Petitioner contended, disclosed all limitations of independent claim 1, including a central traffic control system where vehicles log in with an identity and report data for dynamic guidance.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references to improve upon Gazis's system. Gazis already suggested optimizing routes based on criteria beyond travel time, such as minimizing pollution or fuel consumption. To achieve such advanced optimization, a POSITA would require more detailed vehicle data than a simple IP address. It would have been obvious to incorporate the detailed vehicle-specific data taught by Oates (e.g., engine specs) and the vehicle-type identification used for routing by Anagnostopoulos to enable the Gazis system to make more sophisticated, vehicle-aware routing decisions.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Integrating known types of vehicle data collection (from Oates and Anagnostopoulos) into a known centralized routing algorithm (from Gazis) was a predictable application of existing technologies to achieve a known goal.

Ground 2: Obviousness over Gazis, Oates, Anagnostopoulos, and Mertens - Claims 9, 12, and 13 are obvious over the combination of Gazis, Oates, Anagnostopoulos, and Mertens.

  • Prior Art Relied Upon: Gazis (Patent 5,610,821), Oates (UK Patent Application 2,288,892), Anagnostopoulos (WO 1993/05492), and Mertens (Patent 5,767,505).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the payment-related limitations of claims 9, 12, and 13. Petitioner asserted that Mertens taught a GPS-based system for automatically determining and paying road tolls. In Mertens, an in-vehicle device tracked a vehicle's position to calculate toll charges, which were then transmitted to a central point for payment and invoicing. This central point could bill a vehicle owner and collect payment from a bank. Petitioner argued that this disclosure directly mapped to the challenged claims' requirements for using a vehicle's identity for services (i.e., toll payment) and having a central system record and invoice those payments.
    • Motivation to Combine: A POSITA developing a comprehensive traffic management system, as taught by the primary combination, would find it a logical and desirable extension to incorporate an automated tolling function. Mertens provided a well-understood method for centralized, automated toll collection. Integrating Mertens's payment functionality into the traffic control system of Gazis/Oates/Anagnostopoulos would create a more robust and commercially valuable system, for example, by allowing a fleet management system to handle both routing and toll payments seamlessly.
    • Expectation of Success: The integration was asserted to be straightforward and predictable. Both the base traffic management system and Mertens's tolling system relied on the same core principles of vehicle identification, position tracking, and communication with a central server. Adding a payment module based on this existing data framework would have been a routine design choice for a POSITA.

4. Key Claim Construction Positions

Petitioner argued that several claim terms should be construed as means-plus-function limitations under pre-AIA 35 U.S.C. §112, ¶ 6, which was critical to its invalidity analysis.

  • "means for identification": Petitioner proposed this term be construed as an in-vehicle device that identifies the vehicle using data such as an IP address, registration number, or vehicle type, as disclosed in the specification.
  • "means for road information": This term was construed as an in-vehicle device containing road information, such as a digital map or stored road network data.
  • "means for transmission of information...": Petitioner construed this as a "Mobile Communications Unit" within the vehicle, as shown and described in the specification's figures.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’580 patent as unpatentable.