PTAB

IPR2017-01709

Denso Corp v. Collision Avoidance Technologies Inc

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1. Case Identification

2. Patent Overview

  • Title: System and Method of Avoiding Collisions
  • Brief Description: The ’803 patent discloses a multi-sensor collision avoidance system for vehicles. The system uses data from two or more ultrasonic sensors to calculate and display range and location information, particularly the "transverse location" of an object relative to the vehicle.

3. Grounds for Unpatentability

Ground 1: Anticipation over Kikuta - Claims 1-3, 5, 6, 9, 21, and 25-27 are anticipated by Kikuta under 35 U.S.C. §102(b).

  • Prior Art Relied Upon: Kikuta (JPU S60-41878).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kikuta, a vehicle rearward confirmation device, discloses every element of the challenged claims. Kikuta’s system uses two ultrasonic transmission/reception devices (mapping to the claimed first and second sensors) and a "computing unit" (mapping to the claimed control module) to measure the reflection time of signals. Based on these measurements, Kikuta calculates and displays the "accurate position" of an obstacle on a grid display, which Petitioner asserted is equivalent to calculating and displaying the claimed "transverse location." Petitioner further argued that Kikuta’s integrated "transmission/reception device" meets the "single transceiver" limitation of dependent claims 2 and 3. For method claims, Kikuta’s intended use for avoiding collisions while reversing inherently involves placing the system proximate to an object and performing the claimed sensing and calculating steps.
    • Key Aspects: This ground asserted that a single, earlier prior art reference, not considered during prosecution, taught the core inventive concept of using two sensors to determine the crosswise position of an object.

Ground 2: Anticipation over Nakajima - Claims 21, 22, and 25-28 are anticipated by Nakajima under 35 U.S.C. §102(b).

  • Prior Art Relied Upon: Nakajima (JPA H7-92265).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Nakajima discloses an obstacle detecting apparatus that satisfies all limitations of the challenged claims, particularly those requiring 360-degree coverage. Nakajima’s system uses a "microcomputer" (control module) connected to a plurality of ultrasonic transmitters and receivers placed around a vehicle to detect the distance and orientation of obstacles. It explicitly teaches fusing data from these sensors to provide a 360° view on a display, directly mapping to the limitation in claim 22. Nakajima also discloses calculating an obstacle's "coordinate" based on signals from multiple sensors to determine its position, including its perpendicular distance, which Petitioner argued meets the triangulation requirement of claim 25. The system’s ability to detect other vehicles inherently anticipates detecting stationary or slow-moving objects as required by claims 26 and 27.

Ground 3: Obviousness over Kikuta in view of Nakajima - Claims 4, 7, 8, 21, and 22 are obvious over Kikuta in view of Nakajima under 35 U.S.C. §103.

  • Prior Art Relied Upon: Kikuta (JPU S60-41878), Nakajima (JPA H7-92265).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that to the extent Kikuta alone does not teach every element, combining it with Nakajima renders the claims obvious. Kikuta provided the basic two-sensor system for determining transverse location. Nakajima supplied additional, known features, such as logging the object's location (claim 4), providing a 360° detection range (claim 22), and using a more advanced display that divides a line into zones and uses light-emitting diodes to indicate object direction (claims 7 and 8).
    • Motivation to Combine: A POSITA would combine the teachings of Kikuta and Nakajima, as both references are in the same field of ultrasonic vehicle sensor systems and address the same problem. Petitioner asserted that market forces and design incentives would have motivated a POSITA to incorporate Nakajima’s superior 360° detection and more intuitive display into a system like Kikuta’s to create a more comprehensive and commercially desirable product.
    • Expectation of Success: A POSITA would have had a high expectation of success in making this combination. The integration involved applying known sensor technology (from Nakajima) to additional sides of a vehicle, a predictable extension of the systems disclosed in both references.

  • Additional Grounds: Petitioner asserted additional challenges, including that claim 17 is anticipated by Yamamoto (JPA H7-35848) and that claims 18-20 and 24 are obvious over Yamamoto in view of Kikuta or Nakajima. These grounds focused on Yamamoto’s disclosure of a multi-sensor system with a self-diagnosing, built-in-test function, which Petitioner argued was a known and desirable feature for such safety systems.

4. Key Claim Construction Positions

  • "control module": Petitioner proposed this term be construed as "an electronic circuit and components that implement control algorithms." This broad construction was argued to be consistent with the specification’s various embodiments and was intended to prevent the Patent Owner from narrowly interpreting the term to a specific physical structure, like a single microprocessor.
  • "location" and "transverse location": Petitioner argued for different constructions based on claim differentiation. "Location" (claim 21) should be interpreted broadly as a "positional relationship between the object and the vehicle." In contrast, "transverse location" (claims 1 and 5) should be construed more narrowly as the "crosswise positional relationship between the object and the vehicle," consistent with the term’s specific definition in the patent and its addition during prosecution to overcome prior art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 17-22, and 24-28 of the ’803 patent as unpatentable.