PTAB

IPR2018-00204

SZ DJI Technology Co Ltd v. Drone Control LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Intuitive Control System for Radio-Controlled Aircraft
  • Brief Description: The ’375 patent discloses a system to solve the problem of non-intuitive control of a radio-controlled (RC) helicopter when its orientation is different from the user's. The system transforms control commands issued from the user's frame of reference into the helicopter's frame of reference, enabling the helicopter to move relative to the user's perspective regardless of its yaw orientation.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are obvious over Thornberg-983 in view of Thornberg-1995.

  • Prior Art Relied Upon: Thornberg-983 (Patent 5,552,983) and Thornberg-1995 (a 1995 paper titled "Sikorsky Aircraft's Unmanned Aerial Vehicle, Cypher...").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thornberg-983 teaches the core concept of the challenged claims: a control system that transforms commands from an operator's perspective to a vehicle's perspective to provide intuitive control. Specifically, Thornberg-983 was argued to disclose a system that receives command data (pitch/roll) in a first coordinate system (an operator-selectable frame), transforms it based on motion data (the vehicle's heading), and outputs control data for a second coordinate system (the vehicle's frame). To meet the remaining limitations of independent claim 1, Petitioner cited Thornberg-1995 for teaching "conventional" spring-centered joysticks on a hand-held controller and a command for the vehicle to transition to a hover when a joystick is released.
    • Motivation to Combine: A POSITA would combine Thornberg-1995 with Thornberg-983 because both references originate from the same inventor, address the identical technical problem of non-intuitive control, and relate to similar unmanned aerial vehicles (UAVs). Petitioner contended that incorporating the "conventional" spring-loaded joysticks from Thornberg-1995 into the system of Thornberg-983 was an obvious design choice to improve control and implement a known, advantageous auto-hover feature.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as the combination involved implementing well-understood, conventional control hardware (spring-loaded joysticks) into a known control system to achieve the predictable result of easier operation and automated hovering.

Ground 2: Claims 1-5 and 8 are obvious over Muramatsu in view of Karem and, optionally, Thornberg-983.

  • Prior Art Relied Upon: Muramatsu (JP Publication 2001-209427), Karem (Patent 6,584,382), and Thornberg-983 (Patent 5,552,983).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Muramatsu as an alternative primary reference that also discloses a complete system for intuitive helicopter control. Muramatsu was argued to teach an RC helicopter system with a remote control, sensors to detect user and helicopter orientation (providing a first coordinate system and motion data, respectively), and a processor that transforms user commands into control data for the helicopter's coordinate system. To meet the limitations concerning specific controller hardware, Petitioner cited Karem for its disclosure of spring-loaded control sticks that return to a center, "hands-off" position to command a "complete rotorcraft hover," thereby satisfying the limitations for spring-loaded interface devices and a hover command in claim 1.
    • Motivation to Combine: A POSITA would combine Karem's controls with Muramatsu's system to advance the shared goal of simplifying helicopter control for less-skilled operators. Petitioner argued that adding Karem's well-known spring-loaded hover feature to Muramatsu's intuitive control system would be an obvious improvement to enhance ease of use and safety, which are objectives of both references.
    • Expectation of Success: The combination would have a high expectation of success because it involves integrating a standard, conventional control mechanism (spring-loaded sticks for hovering) into a similar remote-control system to achieve a predictable and desired function.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against dependent claims 7-10 by combining the core teachings of Thornberg-983/Thornberg-1995 or Muramatsu/Karem with other references. These included Kotake (for lift control based on aircraft weight), Karem (for proportional yaw-velocity control), and Rivers (for a payload launch module with a parachute).

4. Key Claim Construction Positions

  • Petitioner proposed constructions for several key terms to demonstrate that the prior art met the claim limitations.
  • "wherein the control data commands the RC helicopter from the perspective of a user, independent of a yaw-orientation of the RC helicopter" (claim 1): Petitioner argued this term means that a user command for a specific movement (e.g., left or right) causes the helicopter to execute that movement from the user's viewpoint, regardless of the helicopter's own heading. This construction was central to arguing that both Thornberg-983 and Muramatsu teach the core inventive concept.
  • "substantially a hovering state" (claim 1): Petitioner construed this term to mean "a state with no movement beyond an acceptable level of tolerance." This construction allowed Petitioner to map prior art references like Thornberg-1995 and Karem, which teach commanding a vehicle to a "level attitude," maintaining "current heading," or achieving "zero horizontal or vertical velocity."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-10 of the ’375 patent as unpatentable under 35 U.S.C. §103.