PTAB

IPR2018-00565

Garmin International, Inc. v. LoganTree, LP

Log In

1. Case Identification

2. Patent Overview

  • Title: Electronic Motion Monitoring and Training System
  • Brief Description: The ’576 patent relates to an electronic device, system, and method for monitoring and training an individual on proper motion during physical activity. The core alleged invention is a portable device that both provides immediate feedback to the user when a movement exceeds predefined parameters and records the event data with a timestamp for subsequent analysis.

3. Grounds for Unpatentability

Ground 1: Obviousness over Stewart and Rush - Claims 1-2, 4-5, 9-10, and 12 are obvious over Stewart in view of Rush.

  • Prior Art Relied Upon: Stewart (Patent 5,978,972) and Rush (Patent 5,546,609).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stewart disclosed a portable, self-contained device for monitoring movement, such as a system in a helmet with accelerometers, a microprocessor, and memory to record acceleration data. Stewart taught detecting an event by comparing accelerometer data to a predetermined threshold (e.g., a "spearing" movement in football). However, Stewart did not explicitly disclose that these thresholds were user-definable or that the device provided real-time feedback. Rush was argued to cure these deficiencies by teaching a helmet-mounted monitor that provided audible/visual signals upon detecting a dangerous event. Crucially, Rush taught that its detection threshold was adjustable to accommodate different players and that it recorded the "time and date of each instance" of a potential injury.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Stewart and Rush to improve the functionality of Stewart's device. A POSITA would incorporate Rush's adjustable thresholds into Stewart's system to allow for customization for different users and activities. Furthermore, a POSITA would add Rush's real-time audible/visual alerts to provide immediate, actionable feedback to prevent injury, a key goal of such safety devices. Finally, adding Rush's time-stamping feature to Stewart’s data logging was a logical step to create a more comprehensive record for later analysis by coaches or medical staff.
    • Expectation of Success: The combination involved integrating well-known and compatible features. Adding an adjustable threshold, an alarm, and a timestamp to a data logging system were predictable modifications that would have resulted in an enhanced and more effective motion monitoring device.

Ground 2: Obviousness over Stewart, Rush, and Church - Claim 11 is obvious over Stewart in view of Rush and further in view of Church.

  • Prior Art Relied Upon: Stewart (Patent 5,978,972), Rush (Patent 5,546,609), and Church (Patent 5,474,083).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address claim 11, which specifically required a tactile output indicator. Petitioner asserted that the combination of Stewart and Rush taught all elements of claim 1 except for the tactile output. Church was introduced to teach this missing element, as it described a microprocessor-based system for monitoring muscle force that explicitly included a vibrational indicator to warn a user when lifting parameters were exceeded.
    • Motivation to Combine: A POSITA designing a user interface for the device of Stewart/Rush would have been motivated to include a tactile feedback option. At the time of the invention, providing feedback through multiple modalities (visual, audible, tactile) was a common design choice to enhance user awareness, particularly in sports environments where visual and auditory cues might be missed. Church demonstrated the use of such tactile feedback in a related fitness monitoring context.
    • Expectation of Success: Adding a vibration motor to provide tactile alerts was a simple, well-known, and predictable modification that would have successfully added another feedback modality to the device.

Ground 3: Obviousness over Richardson and Stewart - Claims 1, 7-8, 13-14, 56-58, 140, 144, and 146 are obvious over Richardson in view of Stewart.

  • Prior Art Relied Upon: Richardson (Patent 5,976,083) and Stewart (Patent 5,978,972).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Richardson taught a personal fitness monitor (pedometer) that disclosed most of the claimed features, including a portable device that tracks user locomotion, an accelerometer, a microprocessor, memory, a real-time clock, and user-defined operational parameters (e.g., a "cruise control alarm" for a desired speed range). Richardson's device detected when a user’s speed fell outside this range and stored step data with timestamps. The primary alleged deficiency in Richardson was that its sensor was described as measuring vertical acceleration, not "unrestrained movement in any direction" (i.e., in three dimensions). Stewart was cited to supply this feature, as it explicitly taught a system with up to nine accelerometers to measure translational and angular movement in three dimensions.
    • Motivation to Combine: A POSITA would combine the references to create a more advanced fitness monitor. To the extent the claims required 3D motion sensing, it would have been obvious to substitute Richardson's simpler accelerometer with Stewart's more comprehensive 3D motion sensor. This would advantageously allow for a more detailed analysis of an athlete's movement (e.g., a sprinter's form), which was a known objective in the art.
    • Expectation of Success: Replacing a 1D accelerometer with a multi-axis accelerometer system was a known path for improving motion tracking devices. The substitution was a predictable way to yield a device with more robust data-gathering capabilities without changing the operational principle of Richardson's monitoring and alert system.

4. Key Claim Construction Positions

  • Petitioner argued that the Patent Owner, in co-pending litigation, asserted an unduly broad interpretation of key claim limitations. Specifically, it contended the Patent Owner interpreted "monitoring movement of body parts" to cover general locomotion of a user, not just specific parts, and interpreted the "time stamp limitation" to cover general session time information rather than a specific timestamp linked to the moment the event-causing movement occurred. Petitioner presented Ground 3 (based on Richardson) as an alternative challenge that would prevail even under this broad interpretation, while also arguing Richardson met the limitations under a plain language reading.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4-5, 7-14, 56-58, 140, 144, and 146 of Patent 6,059,576 as unpatentable.