PTAB

IPR2017-01715

Denso Corp v. Collision Avoidance Technologies Inc

Key Events

Petition

petition

Title: SYSTEM AND METHOD OF AVOIDING COLLISIONS
Brief Description: The ’803 patent discloses a multi-sensor collision avoidance system for vehicles. The system combines data from two or more sensors to calculate and display the "transverse location" of an object relative to the vehicle, defined as whether the object is directly behind, to the side, or far enough left or right to not be a collision risk.

Prior Art Relied Upon: Ichinose (Japanese Unexamined Patent Application Publication No. H10-20034).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Ichinose, which describes a safe driving assistance system, discloses every element of the challenged claims. Ichinose teaches a system with a "data processing section" (control module) connected to multiple ultrasonic transmitters and receivers. This system measures multiple return signals to calculate and display the position (i.e., transverse location) of an obstacle. Petitioner asserted that Ichinose's disclosure of displaying the "position and the shape of the obstacle... along with the top view thereof" inherently includes a display means for the transverse location. Dependent claims, such as integrating transmitters and receivers into a single transceiver (claims 2, 3) and logging the object's location (claim 4), were also alleged to be disclosed.

Prior Art Relied Upon: Hayashikura (Patent 5,654,715).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Hayashikura discloses a vehicle-surroundings monitoring apparatus that meets all limitations of claims 21, 22, and 26-28. Hayashikura's system uses a plurality of radar-based transmitter and receiver sections around the vehicle's periphery to detect obstacles. Its "processing device" (control module) calculates distance and location based on return signals and displays the information, including providing a 360° view by fusing data from the sensors (claim 22). Petitioner also argued Hayashikura discloses detecting slow-moving or stationary objects, such as another vehicle or objects encountered when parking in a garage (claims 26, 27).

Prior Art Relied Upon: Ichinose (JPA H10-20034) and Hayashikura (Patent 5,654,715).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that to the extent either reference alone does not teach every limitation, their combination renders the claims obvious. For example, a person of ordinary skill in the art (POSITA) would be motivated to incorporate Hayashikura’s explicit teaching of 360° detection and numerical distance display into Ichinose's system to create a more comprehensive and user-friendly product. Conversely, a POSITA would find it obvious to use Ichinose’s specific configuration of multiple transmitter/receiver sets to calculate location and distance to improve the Hayashikura system.
- Motivation to Combine: Both references are in the same technical field of vehicle distance sensors, originate from Japanese inventors, and address the same problem of vehicle safety. Petitioner asserted that market forces and design incentives to create improved, more comprehensive safety systems would have motivated a POSITA to combine their respective features.
- Expectation of Success: A POSITA would have a reasonable expectation of success in combining the systems because they are closely related, well-described, and involve predictable electronic and sensor technologies.

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: This ground focused on claims requiring a "built-in-test function" for system verification (claim 24) and a display module indicating status (claims 18-20). Petitioner argued that Yamamoto explicitly teaches an ultrasonic distance sensor circuit capable of performing self-diagnosis by sequentially commanding each sensor to transmit a signal and detecting the return for system verification. Combining Yamamoto's self-test function with the collision avoidance systems of Ichinose or Hayashikura would result in the claimed invention.
- Motivation to Combine: A POSITA would have been motivated by market forces and design incentives (e.g., increased safety, reliability, and user trust) to add a known self-diagnosis feature like that in Yamamoto to an existing collision avoidance system. Petitioner noted that the built-in-test function was added during prosecution to overcome a rejection.
- Expectation of Success: Success would be expected because Yamamoto teaches that its test function is applicable to general collision avoidance systems, and integrating such a function into the sensor systems of Ichinose or Hayashikura would be a straightforward application of known principles.

"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 supported by the specification and necessary to avoid improperly limiting the term to a single microcontroller, as the patent describes a distributed system.
"distance" (claim 21): Petitioner argued for "the length of the space between two points." This construction was intended to be broad and not limited by modifiers like "perpendicular," which appear in other, non-asserted claims, invoking the doctrine of claim differentiation.
"location" vs. "transverse location": Petitioner proposed construing "location" broadly as a "positional relationship between the object and the vehicle," while "transverse location" should be construed more narrowly as a "crosswise positional relationship." This distinction was central to arguments that prior art disclosing general location also met the narrower "transverse location" limitation.

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