PTAB

IPR2019-00903

BMW Of North America LLC v. Carrum Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automatic Lateral Acceleration Limiting and Non Threat Target Rejection
  • Brief Description: The ’475 patent discloses methods for an adaptive cruise control (ACC) system designed to reduce vehicle speed during a turn. The system determines that the vehicle is turning based on a detected change in its lateral acceleration, and in response, reduces speed to prevent excessive lateral forces while simultaneously projecting the vehicle's path to reject non-threatening targets.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 4, 5 over Brochure, Schmitt, and AAPA

  • Prior Art Relied Upon: BMW Brochure, Schmitt (Patent 6,456,924), and Applicant Admitted Prior Art (AAPA).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the BMW Brochure discloses a sophisticated ACC system that uses a lateral acceleration sensor to project a vehicle’s path through a curve and can reduce speed for objects detected within that path. However, the Brochure does not explicitly teach reducing speed simply because the vehicle is in a turn. Petitioner asserted that Schmitt, which teaches a traction control system, supplies this missing element by disclosing a method to ascertain curve entry and exit by monitoring changes in lateral acceleration and applying brakes to improve vehicle stability when a limit is exceeded.
    • Motivation to Combine: The motivation was rooted in the AAPA, wherein the ’475 patent’s specification explicitly acknowledges a known problem in the art: prior art ACC systems that maintain a set speed in turns can cause excessive lateral acceleration and potential loss of control. Petitioner contended a person of ordinary skill in the art (POSITA), faced with this known problem, would combine Schmitt’s method of using lateral acceleration changes to trigger braking with the Brochure's ACC system to directly solve this well-documented safety issue.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved integrating known vehicle stability principles (from Schmitt) into a known ACC system (from the Brochure) to solve a known problem, with all components operating in their expected manner.

Ground 2: Obviousness of Claims 6, 8, 9 over Brochure and Schmitt

  • Prior Art Relied Upon: BMW Brochure and Schmitt (Patent 6,456,924).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted independent claim 6 and its dependents using a theory similar to Ground 1. Petitioner argued the Brochure discloses the core elements of claim 6: operating a vehicle in an ACC mode, using a lateral acceleration sensor, determining the vehicle path based on changes in lateral acceleration, and monitoring for objects. The primary missing element was reducing vehicle speed based on the determination that the vehicle is in a turn. As in Ground 1, Schmitt was argued to supply this teaching by disclosing a system that reduces vehicle speed (via braking or engine control) in response to detecting a turn based on changes in lateral acceleration.
    • Motivation to Combine: The motivation was to improve the safety and performance of the Brochure's ACC system. A POSITA would incorporate Schmitt's known stability control logic to prevent the Brochure’s system from maintaining a potentially unsafe speed through a curve, thereby creating a more robust and safer ACC system.

Ground 3: Obviousness of Claims 10-12 over Brochure, Schmitt, and Khodabhai

  • Prior Art Relied Upon: BMW Brochure, Schmitt (Patent 6,456,924), and Khodabhai (Patent 5,959,569).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination for claim 6 to address the additional limitations of dependent claims 10-12, which recite specific steps for object detection. These steps include measuring an object’s range, range rate, and angle, and determining a vehicle path radius of curvature. Petitioner asserted that Khodabhai explicitly teaches a vehicle collision avoidance system that performs these exact steps to determine whether an obstacle lies in the path of a host vehicle, particularly along a curved path.
    • Motivation to Combine: A POSITA seeking to enhance the object detection and path-projection capabilities of the base Brochure/Schmitt system would have been motivated to look to known, more sophisticated systems like Khodabhai. Incorporating Khodabhai's detailed object-sensing and path-calculation methods would predictably improve the system's ability to accurately identify in-path threats during a turn, a scenario where basic radar alone is often insufficient.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 2, 3, and 7 over the primary art combinations further in view of Ishizu (Application # 2001/0044691). Ishizu was used to teach calculating lateral acceleration from vehicle speed and yaw rate data to improve the accuracy and confidence of the system’s turn detection capabilities.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of Patent 7,512,475 as unpatentable under 35 U.S.C. §103.