PTAB

IPR2017-02144

Yamaha Golf-Car Company v. Club Car, LLC

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1. Case Identification

2. Patent Overview

  • Title: METHOD AND SYSTEM FOR GOLF CART CONTROL
  • Brief Description: The ’569 patent describes a method and system for controlling golf cart movement on a course to prevent or reduce damage. The system uses a limited access controller that compares a cart's GPS-determined position against a map of predefined limited access areas and can inhibit or override driver commands—for example, by limiting speed, shutting down the motor, or disabling a gear—if a violation is detected.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claim 11 - Claim 11 is anticipated by the ’918 Publication under pre-AIA 35 U.S.C. §102(e).

  • Prior Art Relied Upon: ’918 Publication (Application # 2006/0052918).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the ’918 Publication discloses every limitation of claim 11 and its antecedent claims 6 and 10. The ’918 Publication describes a control system for a golf cart that uses a GPS receiver to monitor the cart's position against a virtual map with restricted areas. It further discloses a controller that restricts motor operation in response to the cart's position relative to a restricted area. Specifically for the limitations of claim 11, Petitioner argued the ’918 Publication teaches "disabling golf cart movement towards the predetermined area" and "disabling golf cart movement except in a reverse direction" by explicitly disclosing deterrence modes that include disabling forward operation.

Ground 2: Obviousness of Claims 12 and 17-19 - Claims 12 and 17-19 are obvious over the ’918 Publication under 35 U.S.C. §103.

  • Prior Art Relied Upon: ’918 Publication (Application # 2006/0052918).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that the additional limitations in claims 12 and 17-19 are either expressly taught by the ’918 Publication or would have been obvious modifications of its system.
      • For claim 12, which adds "displaying an emergency override" and "selecting the emergency override," Petitioner argued that the ’918 Publication explicitly discloses that each vehicle will have an emergency override. A POSITA would have understood that for a user to "activate" the override, it must be displayed.
      • For system claim 17, which requires a "driver interface unit... operable to communicate an alarm to a base station of a controller limiting the performance of a driver command," Petitioner asserted that the ’918 Publication discloses sending an alarm signal to the base station upon a violation.
      • For claim 18, which adds a base station operable to communicate an "authorization" to the cart, Petitioner pointed to the ’918 Publication's disclosure that an operator can manually or automatically reset cart operation after a trespass, which constitutes an authorization.
      • For claim 19, which links the authorization to a "payment of a green fee," Petitioner argued that the ’918 Publication discloses controlling cart operational status based on a golfer having "paid the privilege to play," making the explicit link an obvious design choice.
    • Motivation to Combine: While this is a single-reference ground, Petitioner argued that a POSITA would be motivated to make the claimed modifications to the system of the ’918 Publication. For claim 17, the motivation was to provide course personnel with more complete information (not just the violation, but also the remedial action). For claim 19, the motivation was to automate the payment and authorization process to improve operational efficiency.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success because the ’918 Publication already taught all the necessary underlying components and functionalities, and the proposed modifications represented predictable design choices.

4. Key Claim Construction Positions

  • “Golf Cart” (Claims 11 and 17): Petitioner proposed the construction “a motorized, wheeled vehicle intended for use on a golf course.” This construction is argued to be broader than just a "player cart" and includes vehicles like beverage carts and mowers, consistent with the patent’s specification, which refers to "different types of golf carts" and aims to prevent damage from any such vehicle.
  • “Driver” (Claims 17 and 18): Petitioner proposed the construction “an individual who inputs movement-related commands to a golf cart.” This construction is based on the patent's description of a system that restricts movement "in response to driver inputs."

5. Key Technical Contentions (Beyond Claim Construction)

  • Challenged Claims Are Not Entitled to Provisional Priority Date: A central contention of the petition was that the challenged claims are not entitled to the January 17, 2003, priority date of the [’894](https://ai-lab.exparte.com/case/ptab/IPR2017-00001/doc/1004) Provisional application. Petitioner argued that the ’894 Provisional fails to provide adequate written description support under §112 for key limitations.
    • For claim 11, the ’894 Provisional allegedly provides no disclosure for "disabling golf cart movement except in a reverse direction"; instead, it mentions that reverse will be disabled.
    • For claim 12, the ’894 Provisional allegedly fails to disclose "displaying an emergency override" or "selecting the emergency override," and its passing mention of an "Emergency Function?" was argued to be a mere wished-for feature.
  • ’918 Publication as Valid Prior Art: By successfully challenging the priority claim, Petitioner asserted that the effective priority date of the challenged claims is no earlier than January 9, 2004. This would make the ’918 Publication, with a filing date of March 18, 2003, valid prior art under pre-AIA §102(e).

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 11, 12, and 17-19 of Patent 7,480,569 as unpatentable.