Ford Motor Company v. Carrum Technologies, LLC, which is wholly owned by Pratima Instruments, LLC (a Delaware limited liability company)

1. Case Identification

• Case #: IPR2020-00056
• Patent #: 7,512,475
• Filed: October 23, 2019
• Petitioner(s): Ford Motor Company
• Patent Owner(s): Carrum Technologies, LLC
• Challenged Claims: 1-12

2. Patent Overview

• Title: Automatic Lateral Acceleration Limiting and Non Threat Target Rejection
• Brief Description: The ’475 patent discloses methods and systems for an adaptive cruise control (ACC) system that improves vehicle control in turns. The system uses lateral acceleration data to detect when a vehicle is turning, preemptively reduces speed to manage lateral forces, and filters out non-threatening objects to avoid unnecessary braking.

3. Grounds for Unpatentability

Ground 1: Obviousness over Winner and Fukada - Claims 1-3 and 5 are obvious over Winner in view of Fukada.

• Prior Art Relied Upon: Winner (Application # 2002/0165657) and Fukada (Patent 5,627,756).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Winner discloses all elements of independent claim 1 except for using a change in lateral acceleration to determine when the vehicle is in a turn. Winner teaches an ACC system that controls vehicle speed, including in curves, and can predict a vehicle's path. However, the ’475 patent itself identifies a known problem with prior art ACC systems like Winner’s: they may maintain a set speed in turns, causing excessive lateral acceleration and potential loss of control. Fukada was argued to supply the missing elements, as it explicitly teaches a turn behavior control device that detects a change in lateral acceleration to determine that a vehicle is in a turn and reduces vehicle speed to prevent loss of control. Dependent claims 2, 3, and 5 were argued to be obvious for adding further known techniques from Fukada, such as measuring vehicle speed and yaw rate (claim 2) or reducing speed if lateral acceleration exceeds a limit (claim 5).
  • Motivation to Combine: A POSITA, starting with Winner's ACC system and recognizing its stated problem of poor performance in turns, would have been motivated to look for solutions. Fukada directly addresses this exact problem by teaching the use of lateral acceleration changes to detect turns and control vehicle behavior. A POSITA would combine Fukada’s turn-detection and control method with Winner’s ACC system to improve its safety and performance in curves.
  • Expectation of Success: The combination would have been a predictable implementation of known technologies to solve a known problem. Fukada provides a clear method for measuring lateral acceleration and using that data to control the vehicle, and integrating this functionality into Winner's ACC system would have been straightforward for a POSITA with an expectation of achieving the desired improved turn control.

Ground 2: Obviousness over Winner, Fukada, and Schmitt - Claim 4 is obvious over Winner in view of Fukada and Schmitt.

• Prior Art Relied Upon: Winner (Application # 2002/0165657), Fukada (Patent 5,627,756), and Schmitt (Patent 6,456,924).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on Ground 1 for the elements of independent claim 1. Dependent claim 4 adds the limitation of "determining the vehicle's position within the turn." Petitioner argued that while Winner and Fukada teach detecting that a turn is occurring, Schmitt explicitly discloses determining a vehicle’s position within the turn. Schmitt teaches a traction control system that ascertains curve entry and exit by monitoring changes in lateral acceleration. Specifically, Schmitt discloses that a "cornering event exists when [lateral acceleration] exceeds a limiting value" and "a curve entry is recognized when the change of [lateral acceleration] exceeds a predefined limiting value," which amounts to determining the vehicle’s position within the turn.
  • Motivation to Combine: A POSITA seeking to enhance the combined Winner/Fukada system would have been motivated to incorporate Schmitt’s teachings. By not only detecting a turn (from Fukada) but also determining the specific position within it (e.g., entry, mid-curve, exit, per Schmitt), the ACC system could provide more nuanced and effective speed control. This would be a logical and desirable improvement.

Ground 3: Obviousness over Winner, Fukada, and Khodabhai - Claims 10-12 are obvious over Winner in view of Fukada and Khodabhai.

• Prior Art Relied Upon: Winner (Application # 2002/0165657), Fukada (Patent 5,627,756), and Khodabhai (Patent 5,959,569).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds on the combination of Winner and Fukada for the base method of independent claim 6 (which is similar to claim 1 but adds object monitoring). Dependent claims 10-12 add specific steps for detecting an object, including measuring object range, range rate, and angle, and determining the vehicle’s path radius of curvature. Petitioner argued that Khodabhai teaches these specific object-detection techniques. Khodabhai discloses a vehicle collision avoidance system that determines if an obstacle is in the host vehicle's path by measuring the object’s range, range rate, and azimuth angle, and by calculating the vehicle's radius of curvature to project the path.
  • Motivation to Combine: A POSITA implementing the ACC system of Winner/Fukada, which already includes object detection, would be motivated to use more robust and accurate techniques for this purpose. Khodabhai provides a detailed, known method for calculating a vehicle's curved path and determining if an object lies within it. A POSITA would combine Khodabhai’s advanced object and path determination logic to improve the reliability of the ACC system and better distinguish between in-path threats and out-of-path non-threats, a key goal of the ’475 patent.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claims 6, 7, 8, and 9 based on combinations of Winner, Fukada, and Schmitt, which relied on the same core arguments and prior art teachings as detailed in the grounds above but applied to different claim sets.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) or General Plastic factors would be inappropriate. The petition asserted that Ford had not previously filed any petition challenging the ’475 patent, so factors weighing against follow-on petitions do not apply. The petition was filed in coordination with pending IPRs by another petitioner (BMW) against the same patent, and Ford stated its intent to seek joinder to conserve PTAB and party resources. It argued that because this petition tracks a pending BMW petition (IPR2019-00927), there was no delay, and institution would promote the efficient resolution of disputes, consistent with the goals of the America Invents Act.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’475 patent as unpatentable under 35 U.S.C. §103.