PTAB

IPR2018-00206

SZ DJI Technology Co Ltd v. Drone Control LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remotely controlled vehicle with intuitive control
  • Brief Description: The ’918 patent describes a system for controlling a radio-controlled (RC) vehicle, such as a drone or helicopter. The system is designed to solve the problem of non-intuitive control that occurs when the vehicle's orientation does not match the user's orientation by transforming control commands from a coordinate system based on the user's perspective to a coordinate system based on the vehicle's perspective.

3. Grounds for Unpatentability

Ground 1: Obviousness/Anticipation over Thornberg - Claims 1-6 and 11-14 are unpatentable over Thornberg

  • Prior Art Relied Upon: Thornberg (Patent 5,552,983).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thornberg taught every limitation of the independent claims. Thornberg explicitly identified the same "non-intuitive control" problem and disclosed a system with selectable reference modes, including a vehicle mode and an operator mode. In the operator mode, Thornberg’s system received roll and pitch commands from the operator’s perspective (the "first coordinate system") via a joystick. It used a navigation system (a "motion sensing module") to determine the vehicle’s heading (yaw-axis motion data) and a flight control computer (a "processing module") to transform the operator's commands into control data for the vehicle's perspective (the "second coordinate system") using the same rotation matrix transformation taught in the ’918 patent.
    • Motivation to Combine (for §103 grounds): Not applicable for the anticipation argument. For obviousness, Petitioner asserted that to the extent any minor details were not explicit, a POSITA would find it obvious to implement Thornberg's system using conventional components and methods.
    • Expectation of Success: Petitioner argued success was expected because Thornberg provided a complete, functional system with a detailed operational description.

Ground 2: Obviousness over Muramatsu alone or in view of Thornberg - Claims 1-5 and 11-13 are unpatentable over Muramatsu

  • Prior Art Relied Upon: Muramatsu (JP Patent Publication 2001-209427), optionally in view of Thornberg (Patent 5,552,983).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Muramatsu, like Thornberg, disclosed the same intuitive control solution. Muramatsu’s system used a magnetic bearing sensor on a cap worn by the operator to determine the user's viewing direction (the "first coordinate system") and another sensor on the helicopter to determine its heading (the "motion sensing module"). Command inputs from steering sticks were transmitted to the helicopter, where a processing module transformed them from the user's perspective to the helicopter’s airframe-based perspective (the "second coordinate system") to provide intuitive control. Petitioner argued that if Muramatsu's two-step transformation (user-to-earth, then earth-to-vehicle) was deemed different, it would have been obvious to combine it with Thornberg's more direct, single-step transformation to simplify the process.
    • Motivation to Combine: A POSITA would combine Muramatsu with Thornberg to simplify Muramatsu’s two-step coordinate transformation into a more computationally efficient single-step process, as taught by Thornberg, without changing the ultimate result.
    • Expectation of Success: Success was expected as this would be the application of a known, more efficient mathematical technique to an existing system.

Ground 3: Obviousness over Thornberg in view of Kotake - Claims 7 and 15 are obvious over Thornberg and Kotake

  • Prior Art Relied Upon: Thornberg (Patent 5,552,983) and Kotake (Japanese Patent Publication No. 1996-10451).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claims 7 and 15, which added the limitation of generating lift control data based on the vehicle's weight. Petitioner argued that Thornberg taught the base system for intuitive control. Kotake taught an RC helicopter used for agricultural spraying that could automatically maintain a proper altitude (i.e., hover) even as its weight changed due to the dispensing of chemicals. Kotake's automatic flight control would necessarily generate "lift control data" based on the helicopter's changing weight to achieve this result.
    • Motivation to Combine: A POSITA would combine Kotake's weight-compensating hover feature with Thornberg's vehicle to improve its functionality. This would be particularly advantageous for applications taught by Thornberg, such as delivering ordnance or supplies, where the vehicle's weight would change.
    • Expectation of Success: A POSITA would expect success in integrating this known auto-hover functionality into Thornberg’s control system to enhance its stability and performance during payload delivery missions.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Thornberg with Karem (Patent 6,584,382) for proportional yaw-velocity control and with Rivers (Application # 2005/0127242) for adding a payload launch module. Similar combinations were asserted based on Muramatsu as the primary reference.

4. Key Claim Construction Positions

  • "coordinate system . . . from a perspective of a user of the remote control device" (claims 1, 11): Petitioner proposed this term meant a "coordinate system based on the orientation of a user of the remote control device." This construction was argued to be consistent with the specification's description and figures, which show the user's commands are based on the user's orientation.
  • "coordinate system . . . from a perspective of the RC vehicle" (claims 1, 11): Petitioner proposed this term meant a "coordinate system based on the orientation of the RC vehicle." This was supported by the specification's description of the vehicle's roll, pitch, and yaw axes defining its operational frame of reference.
  • "launch[] an object" (claims 9, 17): Petitioner proposed this meant to "release an object," arguing the specification did not require propulsion and explicitly described a launch module that "selectively releases" or "dropped" objects.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-18 of the ’918 patent as unpatentable.