PTAB

IPR2018-00256

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 and method. The system includes a plurality of laser emitters and detectors mounted on a structure that rotates at high speed to collect distance measurements.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 19 over Mizuno and Kilpelä

  • Prior Art Relied Upon: Mizuno (Japanese Patent Publication No. H3-6407) and Kilpelä (Review of Scientific Instruments, Apr. 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mizuno disclosed a device for measuring the 3-D shape of an object that meets the core limitations of independent claim 19. Mizuno’s device includes four laser measurement units on a rotating plate that spins at 3,000-5,000 RPM, satisfying the claim’s "rotary component" rotating at over 200 RPM. Petitioner contended that Mizuno’s system, which generates a 3-D image from collected distance data, constitutes the claimed "lidar system" that generates a "3-D point cloud." While Mizuno generically disclosed "position sensors," Petitioner asserted it was obvious to implement this with avalanche photodiode (APD) detectors as taught by Kilpelä, which describes a high-precision, pulsed time-of-flight laser range finder using an APD-based receiver.
    • Motivation to Combine: A POSITA would combine Mizuno and Kilpelä because both relate to high-precision 3-D laser measurement in industrial settings. Petitioner argued a POSITA would look to a reference like Kilpelä to identify specific, high-performance components (e.g., APDs) to implement the functional but less-detailed system of Mizuno. The superior accuracy and gain of Kilpelä's APDs would have been a known way to improve the performance of Mizuno’s system.
    • Expectation of Success: Petitioner asserted a high expectation of success, as APDs were a well-known and suitable detector type for LiDAR systems, making their integration into Mizuno’s framework predictable.

Ground 2: Obviousness of Claims 16 and 23 over Mizuno, Kilpelä, and Suzuki

  • Prior Art Relied Upon: Mizuno (Japanese Patent Publication No. H3-6407), Kilpelä (Review of Scientific Instruments, Apr. 2001), and Suzuki (Japanese Patent Publication No. JP2006-177843).
  • Core Argument for this Ground:
    • Prior Art Mapping: These claims add a processor that causes the laser emitters to emit pulses at a reduced power level if a detector senses a return signal above a threshold. Petitioner mapped the base rotating LiDAR system to the combination of Mizuno and Kilpelä. Petitioner then argued that Suzuki taught the claimed power-control feature. Suzuki described a laser-reflection-based system that uses feedback control to reduce the amount of emitted light if the detected reflected light is larger than a predetermined amount, thereby preventing detector saturation and improving measurement accuracy.
    • Motivation to Combine: Petitioner argued that a primary purpose of Mizuno's system was to accurately measure surface imperfections. These imperfections can cause large variations in reflected light intensity, leading to the exact detector saturation problem that Suzuki solves. A POSITA seeking to improve the accuracy and stability of Mizuno's system would have been motivated to incorporate Suzuki's well-known feedback control solution.
    • Expectation of Success: Success would be expected, as combining a known feedback control mechanism to solve a known problem of signal saturation in a similar light-based measurement system is a predictable design choice for a skilled artisan.

Ground 3: Obviousness of Claims 17, 18, 24, and 25 over Mizuno, Kilpelä, and the ANSI Standard

  • Prior Art Relied Upon: Mizuno (Japanese Patent Publication No. H3-6407), Kilpelä (Review of Scientific Instruments, Apr. 2001), and the ANSI Standard (Z136.1-2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: These dependent claims require a processor configured to prevent the laser emitters from firing when the rotary component is not rotating or is rotating below a threshold speed. Petitioner again used the Mizuno and Kilpelä combination for the base LiDAR system. Petitioner argued the ANSI Standard for the safe use of lasers explicitly taught the claimed safety feature, stating that scanning devices must incorporate a means to prevent laser emission upon a scan failure or change in scan velocity to avoid hazardous exposure.
    • Motivation to Combine: A POSITA implementing a rotating laser system like Mizuno's would have been motivated by standard industry practice and safety concerns to consult and adhere to safety standards like the ANSI Standard. The standard directly addresses the danger posed by a slowing or stopped scanning laser, making its implementation an obvious and necessary design consideration for any such product.
    • Expectation of Success: High, as implementing a safety interlock based on rotational speed is a straightforward task for a POSITA, easily accomplished by coding the system's microcomputer.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Mizuno alone, Mizuno in view of Suzuki, and Mizuno in view of the ANSI Standard, which relied on similar arguments that a POSITA would have found it obvious to implement well-known components and features to realize the functions described in Mizuno.

4. Key Claim Construction Positions

  • Petitioner asserted that the broadest reasonable interpretation of the claim terms should, at a minimum, encompass the constructions adopted by the N.D. Cal. in a related litigation.
  • "rotary component": Construed as a means-plus-function term with the function of rotating the emitters and detectors at a speed of at least 200 RPM. Petitioner identified corresponding structures from the specification, including a "brushed motor" and "spin motor."
  • "plurality of laser emitters": Construed to include "two or more light sources" or "a single light source that generates a single laser beam that is sub-divided." This construction was important for applying prior art that may use a single, subdivided laser source.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 16-19 and 23-25 of Patent 7,969,558 as unpatentable under 35 U.S.C. §103.