PTAB

IPR2018-00255

Quanergy Systems Inc v. Velodyne Lidar Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: High Definition LiDAR System
  • Brief Description: The ’558 patent describes a LiDAR-based three-dimensional (3-D) point cloud measuring system. The system utilizes a plurality of laser emitters and avalanche photodiode detectors mounted on a support structure that rotates at high speed to capture distance measurements across a 360-degree field of view, primarily for applications like autonomous vehicle navigation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mizuno - Claims 1-4, 8, and 9 are obvious over Mizuno

  • Prior Art Relied Upon: Mizuno (Japanese Patent Publication No. H3-6407).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mizuno discloses all elements of the challenged claims. Mizuno describes a device for 3-D shape measurement using four laser measurement devices fixed to a rotating plate that spins at high speeds (3,000-5,000 RPM), satisfying the limitations of a support structure, a plurality of emitters, and a rotary component rotating at over 200 RPM. While Mizuno discloses generic "position sensors and image sensors" for detecting reflected laser light, Petitioner contended it would have been obvious for a person of ordinary skill in the art (POSITA) to implement these sensors using avalanche photodiode detectors (APDs).
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. The motivation argument centered on a POSITA's design choice, asserting that APDs were one of a finite number of known, suitable photodetectors for LiDAR applications at the time. Their well-known advantages, including fast response times, high accuracy, compact size, and superior performance in low-light conditions, would have made them an obvious choice to implement in Mizuno's system to achieve its stated goal of high-resolution 3-D imaging.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in using APDs, a standard component for LiDAR systems, to perform the light detection function described in Mizuno.

Ground 2: Obviousness over Mizuno in view of Kilpelä - Claims 1-4, 8, and 9 are obvious over Mizuno in view of Kilpelä

  • Prior Art Relied Upon: Mizuno (Japanese Patent Publication No. H3-6407) and Kilpelä (“Precise pulsed time-of-flight laser range finder for industrial distance measurements,” Review of Scientific Instruments, Apr. 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presents an alternative to Ground 1. Petitioner argued that Mizuno provides the foundational rotating LiDAR system with multiple emitters. Kilpelä, which describes a laser range finder for industrial uses, explicitly teaches the use of an APD-based receiver to detect reflected laser pulses for 3-D imaging. The combination of Mizuno's rotating multi-sensor platform with Kilpelä's specific teaching of an APD detector renders the claims obvious. For dependent claims, Mizuno’s disclosure of a slip ring for power and data transmission was argued to meet the limitations for a rotary power coupling (claim 2) and a communication component (claim 9).
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references because both relate to LiDAR-based systems for precise 3-D imaging in industrial environments. When seeking to implement the generic sensors in Mizuno, a POSITA would naturally consult art like Kilpelä for specific, high-performance components. Kilpelä’s explicit teaching that APDs are superior to other photodiodes for achieving high gain and precision provides a strong and direct motivation to incorporate an APD into Mizuno’s system to improve its performance.
    • Expectation of Success (for §103 grounds): Success was predictable, as incorporating a known type of detector (APD) from Kilpelä into a system requiring a detector (Mizuno) is a straightforward engineering task. The components are compatible and their combination would predictably result in a functional 3-D imaging system.

4. Key Claim Construction Positions

  • Petitioner stated that for the purposes of the IPR, the broadest reasonable interpretation of the claim terms should encompass, at a minimum, the constructions adopted by the U.S. District Court for the Northern District of California in parallel litigation. Key constructions included:
    • "plurality of laser emitters": Construed as "two or more light sources that generate laser beams, or a single light source that generates a single laser beam that is sub-divided into two or more smaller beams." This construction was important for arguing that Mizuno's system, with its four distinct laser measurement devices, met the limitation.
    • "communication component" (claim 9): Interpreted as a means-plus-function term governed by 35 U.S.C. §112 ¶6, with the function of "allowing transmission of signals generated by the [APDs] to an external component." The corresponding structure was identified as a "rotary coupling device" or similar. This construction was central to mapping the claim to Mizuno's disclosure of a slip ring or rotary transformer for transmitting measurement signals.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 8, and 9 of Patent 7,969,558 as unpatentable under 35 U.S.C. §103.