PTAB

IPR2017-01715

Denso Corporation 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 relates to a multi-sensor collision avoidance system for vehicles. The system uses data from two or more sensors to provide range and location information, specifically calculating and displaying the "transverse location" of an object relative to the vehicle using two return signals.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-6, 10, 21, 22, 26, and 27 under §102(a) by Ichinose

  • Prior Art Relied Upon: Ichinose (JPA H10-20034).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ichinose discloses every element of the challenged claims. Ichinose describes a "safe driving assistance system" using ultrasonic sensors for obstacle detection. Its "data processing section" functions as the claimed "control module." Ichinose expressly teaches using multiple transmitters and receivers that are connected to the control module, transmit separate signals, and receive return signals to calculate an object's position. Petitioner contended that Ichinose’s calculation of an object's position based on multiple signals and its display of the object's location "at back or around the vehicle" meets the "transverse location" limitation of independent claims 1, 5, and 10. For dependent claims, Ichinose was argued to disclose integrated transceivers, logging of position data to determine a safe route, and detecting pedestrians (slow-moving objects) or obstacles when parking (stationary objects).

Ground 2: Anticipation of Claims 21, 22, and 26-28 under §102(b) by Hayashikura

  • Prior Art Relied Upon: Hayashikura (Patent 5,654,715).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Hayashikura, a vehicle-mounted radar system, anticipates the claims. Its "processing device" is the "control module," and its plurality of transmitter/receiver sections arrayed on the vehicle periphery meets the corresponding claim limitation. Hayashikura’s system was argued to meet all limitations of independent claim 21 by measuring return signals, detecting an object based on phase difference, calculating distance, and displaying the location and distance on a screen. For dependent claims, Petitioner argued Hayashikura teaches fusing data from its sensors to provide a 360° view (claim 22), detecting "another vehicle" which may be slow-moving (claim 26), and detecting stationary objects when reversing into a garage (claim 27).

Ground 3: Obviousness of Claims 18-20 and 24 over Yamamoto in view of Ichinose or Hayashikura

  • Prior Art Relied Upon: Yamamoto (JPA H7-35848) in view of either Ichinose (JPA H10-20034) or Hayashikura (Patent 5,654,715).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Ichinose and Hayashikura teach the base collision avoidance systems as described in the grounds above, but do not explicitly disclose a "built-in-test function" for system verification. Yamamoto was asserted to remedy this deficiency by expressly teaching an ultrasonic distance sensor circuit capable of performing "self-diagnosis." Yamamoto’s control module (CPU) sequentially commands each sensor to transmit a signal, detects the return, and verifies normal operation or determines a fault. Combining Yamamoto’s self-test with the display taught by Ichinose or Hayashikura renders claim 18 (displaying status) obvious. Claims 19-20 (receiving returns from nearby objects/road surface) were argued to be taught by Ichinose/Hayashikura.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated by market forces and design incentives (e.g., increased safety, reliability, and user-friendliness) to incorporate Yamamoto's known and desirable self-diagnosis feature into a comprehensive collision avoidance system like that of Ichinose or Hayashikura.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination because the systems are in the same technical field, are well-described, and Yamamoto discloses that its test function is applicable to general collision avoidance systems.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 21, 22, and 26-28 over the combination of Ichinose and Hayashikura. This ground argued that to the extent either reference was found to be missing a minor element, the other reference supplied it (e.g., combining Hayashikura's explicit numerical distance display with Ichinose's system).

4. Key Claim Construction Positions

  • "control module" (claims 1, 4, 10, 17, 21, 22, 24, 26-28): Petitioner proposed this term be construed as "an electronic circuit and components that implement control algorithms." This broad construction was argued as necessary to prevent improperly limiting the term to a single physical microprocessor, which would be contrary to the specification and would exclude the distributed processing systems disclosed in the prior art.
  • "location" (claim 21) and "transverse location" (claims 1, 5): Petitioner argued for different constructions based on claim differentiation and the specification. "Location" was proposed to mean a broad "positional relationship between the object and the vehicle." In contrast, "transverse location" was argued to be a narrower "crosswise positional relationship," based on the patent’s explicit definition and its addition during prosecution to overcome prior art.
  • "distance" (claim 21): Petitioner argued this term should be construed simply as "the length of the space between two points." It contended that, based on claim differentiation, the term should not be limited to require a "perpendicular" distance, as other dependent claims explicitly add that narrower limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 10, 18-22, 24, and 26-28 of Patent 6,268,803 as unpatentable.