PTAB

IPR2017-01355

Unified Patents Inc v. Collision Avoidance Technologies Inc

Key Events

Petition

petition Intelligence

Title: Collision Avoidance System
Brief Description: The ’803 patent discloses a vehicle collision avoidance system that uses a plurality of sensors connected to a control module. The system detects objects around the vehicle, calculates the distance to and location of the objects, and displays this information to the driver. While some claims in the patent specify calculating "transverse location" or "perpendicular distance," the challenged independent claim 21 is broader, reciting only the calculation and display of "distance" and "location."

Prior Art Relied Upon: Hayashikura (Patent 5,654,715).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Hayashikura discloses every element of the challenged claims. Hayashikura teaches a vehicle monitoring system using multiple radar devices (a plurality of transmitting and receiving devices) positioned around a vehicle's periphery to provide 360° detection. It further discloses a processing device (a control module) that measures return signals to detect objects, calculates both the distance to and location of those objects, and displays this information on a screen. For dependent claims, Hayashikura’s system was alleged to fuse data from its sensors to create a comprehensive 360° view (claim 22) and to inherently detect slow-moving (claim 26) or stationary (claim 27) objects, such as those encountered when changing lanes or parking.

Prior Art Relied Upon: Hayashikura (Patent 5,654,715) and Cherry (Patent 5,235,315).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that Hayashikura teaches the base collision avoidance system of claim 21, while Cherry teaches the additional "built-in-test function" recited in claim 24. Cherry discloses a self-test operation for a vehicle object-detection system where a controller commands a transmitter to emit a signal and verifies system readiness by detecting a return signal, such as a reflection from the ground.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Cherry's self-test functionality with Hayashikura's system to enhance safety and reliability. The combination would provide the known benefit of verifying system operation and filtering out erroneous signals from small ground irregularities, thereby improving the system's focus on genuine obstacles.
- Expectation of Success: A POSITA would have a high expectation of success, as incorporating self-test routines into automotive electronic systems was a common and well-understood practice. The modification would primarily involve software changes to Hayashikura's processing device, which was within the ordinary skill in the art.

Prior Art Relied Upon: JP 265 (Japanese Publication JPH07-092265).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that JP 265, an alternative primary reference, also discloses all elements of the challenged claims. JP 265 describes a vehicle obstacle detection system using ultrasonic oscillators placed around a car's periphery for 360° coverage. A microcomputer (control module) calculates the distance and direction (location) to obstacles based on ultrasound transmission and reception times, and a display panel shows this information. For dependent claims, JP 265’s microcomputer fuses data by using multiple reception times in its calculations (claim 22) and is capable of triangulation to calculate an actual perpendicular distance (claim 25).

Prior Art Relied Upon: JP 265 (Japanese Publication JPH07-092265) and Cherry (Patent 5,235,315).
Core Argument for this Ground:
- Prior Art Mapping: This ground used JP 265 as the base system and combined it with Cherry's teaching of a "built-in-test function," similar to the argument in Ground II.
- Motivation to Combine: The motivation was identical to Ground II: to add the known benefits of a self-test function for increased system reliability and improved signal filtering to the collision avoidance system of JP 265. Petitioner noted that JP 265's disclosure of sequential sensor activation would align well with implementing a sequential self-test as taught by Cherry.
- Expectation of Success: A POSITA would have expected success in this combination, as both JP 265 and Cherry utilize ultrasonic sensor technology, making the integration of Cherry's self-test logic into JP 265's microcomputer a straightforward task requiring only routine software modifications.

"location": Petitioner proposed construing this term as a "positional relationship between the object and the vehicle." This construction is broad enough to encompass the directional indicators taught by the prior art, which may not explicitly calculate a "transverse" location.
"distance": Petitioner proposed this term to mean "a numerical description of how far the object is from the vehicle." This avoids the narrower "perpendicular distance" limitation found in other claims of the ’803 patent, thereby broadening the scope of claim 21 to cover the general distance calculations in the prior art.
"fuses": Petitioner proposed construing this term to mean "combine." This interpretation supports the argument that prior art systems which combine data from multiple sensors to create a comprehensive view meet the limitation of claim 22.

Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 21, 22, and 24-28 of the ’803 patent as unpatentable under 35 U.S.C. §103.