Yamaha Golf-Car Company v. Club Car, LLC

1. Case Identification

• Patent #: 7,239,965
• Filed: September 20, 2017
• Petitioner(s): Yamaha Golf-Car Company
• Patent Owner(s): Club Car, LLC
• Challenged Claims: 4-5, 10, 14-15, 19-20, 27, 29-30

2. Patent Overview

• Title: Method and System for Golf Cart Control
• Brief Description: The ’965 patent discloses a method and system for controlling golf cart movement on a course to prevent damage. The system uses a GPS-equipped cart with a limited access controller that compares the cart’s real-time position against a predefined map of limited access areas and can inhibit or override driver inputs to prevent violations.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 4-5, 14, 19, and 27 under §102

• Prior Art Relied Upon: The ’918 Publication (Application # 2006/0052918).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that the ’918 publication discloses every element of the challenged claims. The reference describes a comprehensive golf cart control system featuring a GPS receiver, an on-board controller, and a motor, all designed for use on a golf course. The ’918 publication allegedly teaches a system where a controller, interfaced with a GPS and a limited access map, is operable to override a driver command to prevent the cart from entering a restricted area. Specifically, it discloses interrupting motor operation and applying brakes when the cart is on a course that will intersect a restricted area, satisfying the limitations of overriding an "accelerator input" along a "vector." The reference further discloses that restricted areas include greens and hazards (claim 5), projecting a path based on course and speed (claim 14), disabling only forward motion (claim 19), and using a base station to manage access rules for multiple carts (claim 27).

Ground 2: Obviousness of Claims 10, 15, 20, and 29-30 under §103

• Prior Art Relied Upon: The ’918 Publication (Application # 2006/0052918).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that even if not directly anticipated, the remaining challenged claims would have been obvious over the ’918 publication. For claims 10 and 29, which require a "pass code" or "authorization code," Petitioner contended that the ’918 publication already teaches an "acknowledgement" and "reset" process for violations. Using a passcode to effect this acknowledgement was argued to be an obvious modification. For claim 15, which adds "polling the golf cart motor" and "analyzing the change in GPS position," Petitioner asserted these are obvious and routine methods for implementing the ’918 publication’s disclosed function of calculating a buffer zone based on vehicle "speed" and "course." For claim 20, which requires "displaying an emergency override," Petitioner argued it would be obvious to display the disclosed override function on the cart's user interface to allow a user to activate it.
  • Motivation to Combine: For these single-reference grounds, the motivation was to implement the known features of the ’918 publication using conventional, common-sense techniques. For example, a POSITA would be motivated to use a passcode for an acknowledgement process to ensure the driver actually read and understood a system warning, thereby improving the system's effectiveness.
  • Expectation of Success: Petitioner contended a person of ordinary skill in the art (POSITA) would have had a high expectation of success because the proposed modifications involve applying well-known, predictable solutions (passcodes, motor polling for speed, displaying user options) to the system described in the ’918 publication.

4. Key Claim Construction Positions

• “Golf Cart” (Claims 4, 10, 14, 15, 19, 20, 27, and 29): Petitioner proposed the construction “a motorized, wheeled vehicle intended for use on a golf course.” This broad construction is argued to be consistent with the specification, which mentions various vehicles like mowers and beverage carts, and aligns with the patent’s stated purpose of preventing damage from any such vehicle, not just traditional player carts.
• “Velocity” (Claims 14 and 15): Petitioner proposed the construction “a measure of speed and direction.” This term is distinguished from “speed” (rate without direction), which is also used in the patent. This distinction is asserted to be critical for claims that require projecting a path or vector, an action that inherently requires directional information.

5. Key Technical Contentions (Beyond Claim Construction)

• Priority Date of Challenged Claims: A central pillar of the petition is the argument that the challenged claims are not entitled to the priority date of the January 17, 2003, filed Provisional Application No. 60/440,894. Petitioner asserted that essential claim limitations—including “vector,” “override,” “accelerator input,” “pass code,” and “estimating velocity”—lack adequate written description support in the provisional application. Consequently, Petitioner argued the challenged claims are only entitled to the January 9, 2004, filing date of the non-provisional application. This later priority date is crucial for establishing the ’918 publication (which has a March 18, 2003, application filing date) as valid prior art under the pre-AIA §102(e) and §103 statutory bars.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 4-5, 10, 14-15, 19-20, 27, and 29-30 of the ’965 patent as unpatentable.