Unified Patents LLC v. Carrum Technologies LLC

1. Case Identification

• Case #: IPR2019-00481
• Patent #: 7,925,416
• Filed: December 31, 2018
• Petitioner(s): Unified Patents Inc.
• Patent Owner(s): Carrum Technologies, LLC
• Challenged Claims: 1, 2, 7, 9-11

2. Patent Overview

• Title: Vehicle Adaptive Cruise Control in a Turn
• Brief Description: The ’416 patent discloses a system and method for an adaptive cruise control (ACC) system that reduces vehicle speed in a turn based on the vehicle's position within that turn. The system also includes logic to ignore objects detected during the turn that are determined not to be in the vehicle's path, thereby preventing unnecessary braking.

3. Grounds for Unpatentability

Ground 1: Claims 10-11 are obvious over Harada in view of Russell and Mazda.

• Prior Art Relied Upon: Harada (Patent 5,508,929), Russell (Patent 6,675,094), and Mazda (Japanese Patent Application 0536000A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Harada disclosed the core elements of a vehicle control system, including a controller that reduces vehicle speed based on its position in a turn (determined by comparing intended and estimated target positions) and a lateral acceleration sensor. While Harada did not explicitly teach an ACC system or object detection, Petitioner asserted Russell supplied these missing elements, disclosing a standard ACC system with a forward-looking radar sensor for detecting obstacles. For the final limitation, Petitioner contended that Mazda taught the logic of ignoring an object for braking purposes if the vehicle is in a turn and the object is outside the vehicle's predicted path, a feature designed to prevent erroneous braking.
  • Motivation to Combine: A POSITA would combine Harada's vehicle stability control with Russell's object-detecting ACC to create a more robust safety system that accounts for both vehicle dynamics (e.g., lateral slip) and external obstacles. A POSITA would further incorporate Mazda's logic to solve the well-known problem of ACC systems incorrectly braking for objects (like guardrails or cars in other lanes) that are not in the vehicle's actual path while cornering, thereby improving system reliability and performance.
  • Expectation of Success: Petitioner asserted that combining these known elements would have been predictable. Integrating an ACC system (Russell) into a vehicle control unit (Harada) and adding software logic to refine braking decisions (Mazda) were all within the common practices of automotive engineering at the time.

Ground 2: Claims 1, 2, 7, and 9 are obvious over Russell in view of Fukada and Mazda.

• Prior Art Relied Upon: Russell (Patent 6,675,094), Fukada (Patent 5,627,756), and Mazda (Japanese Patent Application 0536000A).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground used Russell as the primary reference, arguing it taught a method of ACC with object detection and vehicle path determination during a turn. Petitioner argued Fukada taught the specific method of "determining when the vehicle is in a turn based on a detected change in the vehicle lateral acceleration." Fukada's system presumes turn behavior by integrating the deviation between measured lateral acceleration (Gy) and expected lateral acceleration (Vr), which inherently relies on changes in sensor data over time. As in Ground 1, Mazda was cited for teaching the step of ignoring an object for braking purposes if it is determined not to be in the vehicle's path during a turn.
  • Motivation to Combine: A POSITA would be motivated to enhance Russell's ACC system with Fukada's turn detection method. Fukada's technique, which explicitly uses changes in lateral acceleration, offered a more precise way to determine that a vehicle has entered a turn, providing a better trigger for the turn-specific path prediction and object-assessment logic in Russell. Again, adding Mazda’s logic would be a straightforward improvement to prevent false braking activations in curves, a known deficiency in the art that Mazda was designed to solve.
  • Expectation of Success: Petitioner contended a POSITA would have had a reasonable expectation of success because integrating Fukada's sensor processing logic into Russell's system was a matter of combining complementary automotive control technologies. The inputs required by Fukada (lateral acceleration, vehicle speed, yaw rate) were standard parameters already used or readily available in advanced ACC systems like Russell's.

4. Key Claim Construction Positions

• "at least one lateral acceleration sensor...operative to detect a change in the vehicle lateral acceleration" (Claim 10): Petitioner argued that any sensor capable of measuring lateral acceleration is inherently capable of detecting a change in that acceleration. Petitioner supported this position by citing the patent's specification and the Patent Owner's own infringement contentions in district court litigation, where the Patent Owner asserted this inherent capability. This construction allowed Petitioner to argue that Harada’s disclosure of a standard lateral acceleration sensor met the claim limitation.
• "means for generating an object range signal...and an object angle signal..." (Claim 11): Petitioner proposed this term is governed by 35 U.S.C. §112, ¶6 as a means-plus-function limitation. The claimed functions are generating range and angle signals. Petitioner identified the corresponding structure in the ’416 patent's specification as "any object detecting sensor known in the art," including radar, LIDAR, ultrasonic sensors, and cameras. This construction enabled mapping Russell’s forward-looking radar directly onto this limitation.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was inappropriate. Although Fukada was cited during prosecution of the parent ’475 patent, Petitioner asserted it was used to reject different claims based on a different teaching (filtering acceleration data) than what is argued in this petition. Petitioner contended there was no substantive overlap between the arguments made during prosecution and the invalidity grounds presented, as the Examiner was never presented with the specific combinations and motivations asserted in the petition.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 7, and 9-11 of the ’416 patent as unpatentable.