PTAB

IPR2017-00819

Google Inc v. Infogation Corp

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: MOBILE NAVIGATION SYSTEM
  • Brief Description: The ’743 patent describes a distributed navigation system where a remote server calculates an optimal route and transmits it to a client device using a "non-proprietary, natural language description." The client device then uses its local mapping database to reconstruct and display the route based on this generic description.

3. Grounds for Unpatentability

Ground 1: Obviousness over Behr and Knockeart - Claim 15 is obvious over Behr in view of Knockeart.

  • Prior Art Relied Upon: Behr (International Publication No. WO 96/00373) and Knockeart (Patent 6,680,694).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Behr discloses a client-server navigation system that meets nearly all limitations of claim 15. Behr’s system features a central "base unit" (server) that calculates routes and transmits route guidance to a "mobile unit" (client) as plain text instructions, including road names and maneuvers. Petitioner asserted this constitutes a "non-proprietary, natural language description." Behr’s mobile unit contains an on-board map database and can request supplemental map data ("stripmaps") from the server to reconstruct the route. Petitioner contended that Behr may not have explicitly disclosed displaying the reconstructed route using the on-board database. To address this, Knockeart was introduced as teaching the common practice of using an in-vehicle database to display "spot maps" for key points along a route, such as maneuver points and the destination.
    • Motivation to Combine: A POSITA would combine Knockeart’s map display technique with Behr’s navigation system to achieve predictable benefits. The motivation was to enhance Behr's primarily text-based system by providing visual, map-based directions, which improves usability, especially during complex maneuvers. This combination was presented as an application of a known technique (map-based display) to a similar system (server-based navigation) to improve its functionality.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining a known map display method with a navigation system was a well-understood practice that would yield the predictable result of a more user-friendly interface without altering the fundamental operation of either system.

Ground 2: Obviousness over Fowler and Hessing - Claim 15 is obvious over Fowler in view of Hessing.

  • Prior Art Relied Upon: Fowler (Patent 6,212,474) and Hessing (Patent 6,334,089).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fowler discloses a portable, in-vehicle navigation system that teaches most limitations of claim 15. Fowler’s system generates a route as an ordered "token list," where tokens can represent character strings like street names (e.g., "TURN RIGHT ON MICHIGAN AVENUE"). Petitioner argued this tokenized format is a "non-proprietary, natural language description." Fowler’s device uses an on-board geographic database to explicate these tokens into displayable text and graphics for the user. While Fowler suggested some system components could be remote, Petitioner introduced Hessing to explicitly teach the missing client-server architecture. Hessing described the conventional practice of a vehicle-based navigation system using a wireless transceiver to communicate with a central server, which leverages its superior processing power to calculate an optimal route and transmit it to the vehicle.
    • Motivation to Combine: A POSITA would combine Hessing’s client-server architecture with Fowler’s route data processing system for several reasons. First, it would reduce the memory and processing load on the in-vehicle device by offloading route calculation to a powerful remote server. Second, it would enable more dynamic routing based on real-time data available to the central server. This was presented as a predictable implementation of Fowler’s system, especially given Fowler’s own suggestion that parts of its system could be located remotely.
    • Expectation of Success: A POSITA would expect the combination to succeed because it involved implementing a known system (Fowler) using a standard, well-established architecture (the client-server model from Hessing) to achieve known benefits, such as improved performance and reduced hardware requirements on the client device.

4. Key Claim Construction Positions

  • "a navigation server": Petitioner proposed this term means "a server that is located remotely from a navigation computer and that generates routing information." This construction was argued to be consistent with the specification's description of a client-server relationship.
  • "a non-proprietary, natural language description": Petitioner proposed this term means "generic textual terms for elements (e.g., a street name or a turn direction) of the route instructions." This construction was based on examples in the ’743 patent, such as using plain text road names and turning directions.
  • Intended Use Language: Petitioner repeatedly argued that functional, intended-use recitations within the system claim—such as "for calculating optimal routes," "for reconstructing said optimal route," and "for displaying said optimal route"—are not structural limitations entitled to patentable weight under the Broadest Reasonable Interpretation (BRI) standard applied in IPR proceedings. Petitioner contended the prior art need only disclose the structure (e.g., a server, a database, a display screen), not necessarily perform the recited function.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claim 15 of Patent 6,292,743 as unpatentable.