PTAB

IPR2017-01337

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 that uses multiple sensors to detect objects. The system is designed to calculate and display not only the distance to an object but also its "transverse location"—its offset to the left or right of the vehicle's centerline.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 9 over Naruse and Ramer

  • Prior Art Relied Upon: Naruse (Patent 4,674,073) and Ramer (Patent 5,877,849).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Naruse taught a complete vehicle object detection system with multiple ultrasonic transmitters and receivers arranged on a vehicle to calculate and display the distance to and location of an object. However, Naruse used a time-of-flight calculation. Ramer was introduced because it explicitly taught calculating the perpendicular distance to an object using triangulation based on signals from one transmitter and two receivers, factoring in the spacing between the sensors. The combination allegedly taught all steps of method claim 9, including calculating the distance as a function of sensor spacing, perpendicular distance, and the first and second return signals.
    • Motivation to Combine: A POSITA would combine Ramer’s superior range calculation method (triangulation) with Naruse’s established system architecture. The motivation was to improve the accuracy of Naruse’s time-of-flight calculation and to use a method with potentially lower computational overhead, as Ramer’s method relied on trigonometric relationships and lookup tables.
    • Expectation of Success: Combining these known object detection techniques was predictable, as both references were directed to solving the same problem of determining an object's distance from a vehicle.

Ground 2: Obviousness of Claims 10 and 21 over Naruse and Lemelson

  • Prior Art Relied Upon: Naruse (Patent 4,674,073) and Lemelson (Patent 6,553,130).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Naruse disclosed the core collision avoidance system of claims 10 and 21, including a control module, a plurality of transmitting and receiving devices, and circuitry to measure return signals and calculate a transverse location. The argument for Naruse’s disclosure of these elements was similar to Ground 1. Lemelson was added to teach the limitation in claim 10[g] requiring an "interface between the control module and an on-board computer information system." Lemelson was cited for its disclosure of a central microprocessor that receives signals from various sensors (including object detection systems) and integrates them with other vehicle systems.
    • Motivation to Combine: A POSITA would be motivated to integrate Naruse's object detection system with a central vehicle computer, as taught by Lemelson, to allow the object detection data to be shared with other vehicle systems. This was a well-known practice at the time, enabling functions like driver warnings or logging location data.
    • Expectation of Success: Integrating a sensor system with a central computer was a common and predictable design choice in vehicle electronics, ensuring the combination would have worked as expected.

Ground 3: Obviousness of Claims 21 and 22 over Gauthier and Hayashikura

  • Prior Art Relied Upon: Gauthier (Patent 5,303,205) and Hayashikura (Patent 5,654,715).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented Gauthier as an alternative primary reference. Gauthier taught a collision avoidance system using separate sensor arrays (e.g., one on the rear, one on the side of a truck) that report to separate displays, thereby indicating the location of an object. This met the base limitations of claim 21. Hayashikura was added to explicitly teach the claim 22 limitation of detecting objects "within a 360° view surrounding the vehicle." Hayashikura disclosed arranging sensors along the entire periphery of a vehicle to permit obstacle detection over a full 360° range.
    • Motivation to Combine: A POSITA would combine Hayashikura’s 360° sensor arrangement with Gauthier’s multi-array system to achieve more comprehensive object detection coverage. Gauthier itself acknowledged that more sensor channels could be added to expand the detection zone, making the modification taught by Hayashikura a simple and logical extension to improve safety.
    • Expectation of Success: Both references addressed vehicle object detection, and combining their respective teachings on sensor arrays and placement was straightforward for a POSITA seeking to create a more robust system.

  • Additional Grounds: Petitioner asserted that claims 17-20 are obvious over Naruse in view of Cherry (Patent 5,235,315) to add a well-known built-in-test function. Petitioner also asserted that claim 24 is obvious over Gauthier in view of Cherry for the same reason.

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 to be supported by the specification, which showed the module interacting with numerous external subsystems, rather than being limited to a single physical microprocessor.
  • "transverse location": Petitioner argued this term, coined by the applicant, 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 the object's position relative to the vehicle's center on a bar graph.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 9, 10, 17-22, and 24 of the ’803 patent as unpatentable under 35 U.S.C. §103.