PTAB

IPR2018-00208

SZ DJI Technology Co Ltd v. Drone Control LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Use with a Radio Controlled Aircraft
  • Brief Description: The ’913 patent describes a method for controlling a radio-controlled (RC) aircraft to address the problem of non-intuitive control when the aircraft's orientation differs from the user's. The system transforms control commands issued from a user's perspective into control data in the aircraft's own coordinate system, allowing the aircraft's movements to correspond to the user's commands regardless of the aircraft's yaw orientation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Thornberg and Karem - Claims 1, 3-6, 8-11, and 13-15 are obvious over Thornberg in view of Karem.

  • Prior Art Relied Upon: Thornberg (Patent 5,552,983) and Karem (Patent 6,584,382).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thornberg taught the core invention: a system for remotely operating a vehicle that solves the non-intuitive control problem by transforming user commands from an "operator frame of reference" into the vehicle's frame of reference using a conventional rotation matrix. Thornberg disclosed a remote control with a joystick for pitch/roll commands, an RF transmitter, and a navigation system on the vehicle to determine its heading (yaw-axis motion data). This combination, Petitioner asserted, met most limitations of independent claims 1, 6, and 11. Karem was introduced to teach the "hovering state" limitation, disclosing a remote control with spring-loaded sticks that, when returned to their center position, command a rotorcraft to a complete hover with zero horizontal and vertical velocity.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Karem's well-known hovering functionality with Thornberg's control system. Thornberg suggested its system could be used for tasks like inspection and surveillance, which often require hovering. Therefore, a POSITA would be motivated to add Karem’s precise hover control to a Thornberg-type vehicle to better perform these known applications.
    • Expectation of Success: The combination involved implementing a known feature (hover control) into an existing system for its expected benefit. Both references used conventional remote control technology, ensuring a POSITA would have a high expectation of success in integrating Karem's hover command logic into Thornberg's control panel.

Ground 2: Obviousness over Thornberg, Karem, and Rivers - Claims 2, 7, and 12 are obvious over Thornberg in view of Karem and Rivers.

  • Prior Art Relied Upon: Thornberg (Patent 5,552,983), Karem (Patent 6,584,382), and Rivers (Application # 2005/0127242).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Thornberg/Karem combination from Ground 1 to address dependent claims 2, 7, and 12, which added the limitation of "launching an object" in response to launch data. Petitioner argued that Rivers disclosed a payload dispensing system for a UAV that releases a payload (e.g., a sensor) in response to a command from a ground control station. This command constitutes the claimed "launch data," and the release of the payload meets the "launching an object" limitation.
    • Motivation to Combine: A POSITA would be motivated to add the payload dispensing system of Rivers to the vehicle of Thornberg. Thornberg explicitly stated that UAVs were known for delivering ordnance or supply materials. Rivers provided a known, off-the-shelf system for accomplishing this exact function. Combining Rivers’ payload system with Thornberg's vehicle was therefore a simple and obvious design choice to achieve a known goal.
    • Expectation of Success: Integrating a payload release mechanism as taught by Rivers into a UAV as taught by Thornberg was a straightforward application of known technologies for their intended purposes, leading to a high expectation of success.

Ground 3: Obviousness over Muramatsu and Karem - Claims 1 and 3-5 are obvious over Muramatsu in view of Karem and, optionally, Thornberg.

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

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Muramatsu as an alternative primary reference that also taught the core concept of transforming user steering inputs from the operator's perspective into the helicopter's perspective to provide intuitive control. Muramatsu’s system determined the user's orientation and the helicopter's orientation (yaw) and used a rotation matrix to transform the commands. Petitioner argued Muramatsu taught every element of claim 1 except the hovering limitation, for which Karem was cited for the same reasons as in Ground 1.
    • Motivation to Combine: The motivation was identical to that in Ground 1. Muramatsu disclosed using its helicopter for agricultural chemical application, a task that would be facilitated by the precise hovering capability taught by Karem. A POSITA would therefore modify Muramatsu’s remote control to send a hover command when the sticks were released, as taught by Karem. Thornberg was cited optionally to teach simplifying Muramatsu's two-step coordinate transformation into a more efficient single step.
    • Expectation of Success: As with the Thornberg/Karem combination, integrating Karem's conventional hover control into Muramatsu's system was a predictable design modification with a high expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for all claims (1-15) based on various permutations of Muramatsu, Karem, Thornberg, and Rivers, which relied on the same core teachings and motivations outlined above.

4. Key Claim Construction Positions

  • "coordinate system ... from a perspective of the RC aircraft" / "...of the remote control device": Petitioner argued these terms meant a coordinate system based on the orientation of the respective object (the aircraft or the remote control). This was central to showing that the prior art transformed commands between two orientation-based frames of reference.
  • "a hovering state": Petitioner proposed this term meant "a state with no movement beyond an acceptable level of tolerance." This construction allowed Karem's disclosure of a "complete rotorcraft hover" with zero horizontal and vertical velocity to meet the claim limitation.
  • "launching an object": Petitioner argued this meant "releasing an object," noting that the patent specification did not require propulsion. This construction allowed the payload "dispensing" and "dropping" taught in Rivers to satisfy the limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-15 of the ’913 patent as unpatentable under 35 U.S.C. §103.