PTAB

IPR2017-01336

RPX Corp v. Collision Avoidance Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Collision Avoidance System
  • Brief Description: The ’803 patent discloses a collision avoidance system for vehicles. The system uses a plurality of transmitters and receivers to detect objects, a control module to calculate an object's distance and "transverse location" (its left-right position relative to the vehicle's centerline), and a display to communicate this information to a driver.

3. Grounds for Unpatentability

Ground 1: Obviousness over Naruse - Claims 1-5, 7, 8, and 21 are obvious over Naruse

  • Prior Art Relied Upon: Naruse (Patent 4,674,073).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Naruse, a single prior art reference not considered during original examination, discloses all elements of these claims. Naruse teaches a vehicle object detection system with a control module (CPU and associated circuitry), multiple ultrasonic transmitters and receivers, and a display. The control module performs sequential detection subroutines, measuring signals from each sensor pair and storing results in memory registers, mapping directly to the ’803 patent's measurement and calculation limitations. Critically, Naruse's system determines object location by identifying which sensor in its horizontal array is closest to an object, which Petitioner contended is functionally identical to calculating the claimed "transverse location." Naruse also discloses a nearly identical LED bar graph display to indicate this left-right location.
    • Key Aspects: The core of this ground is that the allegedly novel feature of the ’803 patent—calculating and displaying a "transverse location"—was already taught by Naruse.

Ground 2: Obviousness over Naruse and Gauthier - Claims 2 and 3 are obvious over Naruse in view of Gauthier

  • Prior Art Relied Upon: Naruse (Patent 4,674,073), Gauthier (Patent 5,303,205).
  • Core Argument for this Ground: For the additional limitation in claims 2 and 3 requiring the integration of a transmitter and receiver into a single transceiver, Gauthier provides the missing element.
    • Prior Art Mapping: Naruse teaches using pairs of ultrasonic transmitters and receivers but also suggests a single detector (transmitter and receiver) may be used at each location. Gauthier explicitly discloses using integrated transceivers for a vehicle obstruction detection system.
    • Motivation to Combine: A POSITA would combine Gauthier's use of transceivers with Naruse's system because both patents address the same problem of vehicle object detection. Using an integrated transceiver was a known design choice to achieve system simplification, portability, and leverage market availability of single-unit components. The fact that Gauthier specifically cites Naruse as relevant prior art provides strong evidence that a POSITA would have looked to these references together.
    • Expectation of Success: Combining a standard transceiver into Naruse's system was a predictable modification that would have yielded the expected benefits without altering the system's core function.

Ground 3: Obviousness over Naruse and Hayashikura - Claims 22 and 28 are obvious over Naruse in view of Hayashikura

  • Prior Art Relied Upon: Naruse (Patent 4,674,073), Hayashikura (Patent 5,654,715).
  • Core Argument for this Ground: For the limitations of fusing sensor data to detect objects in a 360° view and providing a single picture of all objects, Hayashikura supplies the teachings.
    • Prior Art Mapping: Naruse teaches fusing data from multiple sensors arranged on the rear of a vehicle and suggests placement on other sides. Hayashikura explicitly teaches providing sensors along the entire periphery of a vehicle to achieve a 360° detection range and displaying all detected objects in a "single picture" on a screen.
    • Motivation to Combine: A POSITA would be motivated to extend the coverage of Naruse's multi-sensor system to the full 360° taught by Hayashikura to create a more comprehensive and safer system, a primary goal in the field of collision avoidance. The decision of how many sensors to add to expand coverage was a simple design choice, and the advantages of full coverage were well understood.
    • Expectation of Success: Adding more sensors to Naruse's system to achieve the 360° coverage taught by Hayashikura would have been straightforward with a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Naruse with Tagami (Patent 4,349,823) for specific display features, with Cherry (Patent 5,235,315) for a built-in-test function, and with Ramer (Patent 5,877,849) for triangulation methods to calculate perpendicular distance.

4. Key Claim Construction Positions

  • "control module": Petitioner proposed this term be construed as "a processor or microcontroller and accompanying components or circuitry." This broad construction was argued as critical to prevent an improper narrowing of the claim to a single physical unit. Such a construction allows the claim to read on prior art like Naruse, where control functions (e.g., driving circuits, decision circuits, CPU) are performed by multiple, interconnected components rather than a single microprocessor.
  • "transverse location": Petitioner argued that since the patentee acted as its own lexicographer, the term should be construed as "the offset to either the left or right of a longitudinal center line." This construction was based on the specification's description of displaying an object's position on a left-to-right bar graph. This interpretation was central to Petitioner's argument that Naruse's method of identifying the closest sensor in a horizontal array inherently determines and displays this same information.
  • "fuses data": Petitioner proposed the construction "resolves distance and location information from the data of multiple sensors." This was based on the patent's description of a "Data Fusion Algorithm" and was necessary to show that Naruse's process of comparing data from its twelve sensor pairs to determine the minimum distance and location met this limitation.

5. Relief Requested

  • Petitioner requests that the Board institute an inter partes review and cancel claims 1-8, 21, 22, 24, 25, and 28 of the ’803 patent as unpatentable under 35 U.S.C. § 103.