PTAB

IPR2020-00345

DJI Technology Inc v. Remote Imaging Solutions LLC

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1. Case Identification

2. Patent Overview

  • Title: Controlling an Unmanned Vehicle with a Smart Phone
  • Brief Description: The ’230 patent relates to a computerized method for controlling an unmanned vehicle (UV), such as an iRobot PackBot, using a smart phone. The technology involves establishing wireless communication between the phone and the UV to display video streams and vehicle controls on the phone's touchscreen for remote operation.

3. Grounds for Unpatentability

Ground 1: Claims 14, 15, 17, and 18 are obvious over Lenser in view of the USF References.

  • Prior Art Relied Upon: Lenser (Application # 2008/0027591) and the USF References (a collection of materials including a publicly available video and abstract describing a University of South Florida project).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lenser disclosed all major elements of the challenged claims except for the use of a "smart phone" as the operator control unit (OCU). Lenser taught a sophisticated OCU for controlling single or multiple unmanned ground vehicles (UGVs), displaying video feeds, vehicle status, and touch-screen controls. Lenser suggested that its OCU could be a lightweight, mobile device with processing power, such as a tablet PC. The USF References allegedly cured this deficiency by explicitly demonstrating an iPhone application that controlled an iRobot PackBot—the same type of UGV discussed in Lenser. The USF application displayed live streaming video and on-screen directional buttons, effectively implementing Lenser’s OCU functionality on a smart phone.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine the teachings to improve Lenser’s system. Lenser’s preference for a lightweight, mobile OCU with a small form factor would have motivated a POSITA to look beyond tablet PCs to even more portable devices like the iPhone, which was well-known by the priority date. The USF References confirmed the iPhone’s advantages for robot control, describing it as a "huge advantage for man-packable and man-portable robots" and removing the need for operators to carry "large, heavy consoles." The combination was presented as a simple substitution of one known element (Lenser's tablet OCU) for another (USF's iPhone OCU) to achieve predictable results.
    • Expectation of Success: Petitioner claimed a POSITA would have had a high expectation of success. The iPhone possessed the necessary hardware (touchscreen, processor, Wi-Fi transceiver) to implement Lenser's software, and the USF References provided a working proof-of-concept, demonstrating that controlling a UGV with an iPhone was feasible and ready for further improvement.

Ground 2: Claims 7-10, 12, and 13 are obvious over Lenser and the USF References in view of Phillips.

  • Prior Art Relied Upon: Lenser (Application # 2008/0027591), the USF References, and Phillips (Application # 2008/0027590).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Lenser/USF combination as the base smart phone controller and added Phillips to teach claim-specific features. Phillips, an iRobot application filed the same day as Lenser, disclosed additional functionalities for a UGV OCU. These included providing a control to store a video frame as a picture (claim 7), a control to zoom cameras on the vehicle in or out (claim 8), and controls to command the vehicle into one or more "predetermined poses" (claim 9). Phillips also taught displaying a geographic map with controls (claim 10) and receiving information to move a robotic arm (claim 13).
    • Motivation to Combine: A POSITA would have been motivated to integrate Phillips’s features to enhance the Lenser/USF controller. Adding camera zoom and snapshot capabilities would improve reconnaissance, while predefined poses would simplify vehicle operation in hazardous environments, reducing the need for extensive operator training. Phillips taught that different poses offered distinct advantages, such as greater stability ("bumpy driving pose") or speed ("flat driving pose"). The combination was framed as using a known technique (Phillips’s features) to improve a similar device (the Lenser/USF controller) in a predictable way. The common origin (iRobot) and similar system architecture of Lenser and Phillips further supported this motivation.
    • Expectation of Success: Success was expected because the combination merely involved software modifications to add well-known UGV features to the base controller. The fact that iRobot’s commercial PackBot product already incorporated these features prior to the ’230 patent's critical date demonstrated their feasibility and compatibility.

Ground 3: Claims 1, 3, 4, and 6 are obvious over Lenser and the USF References in view of Miyazawa.

  • Prior Art Relied Upon: Lenser (Application # 2008/0027591), the USF References, and Miyazawa (Japanese Application # 2004-64418).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed the "RF transmitter" limitations of claim 1, which require the smart phone to transmit requests via a cable to an external RF transmitter, which then communicates with the UV. While Lenser and USF relied on a single integrated wireless link (e.g., Wi-Fi), Miyazawa taught a system where a mobile phone connected via a cable to a separate controller with an RF transmitter. This architecture was used to send low-rate control signals, while high-bandwidth video signals were sent separately, for example over a cellular network.
    • Motivation to Combine: Petitioner argued that Lenser itself identified a problem that Miyazawa solved. Lenser noted that high-rate video can burden a communication system, suggesting the video could be turned off to save bandwidth. A POSITA would recognize that for dangerous missions, turning off video is not a viable solution, and that video transmission could create latency in critical control signals. Miyazawa provided an elegant solution by separating the communication paths, using a dedicated, reliable, low-rate RF link for control signals to prevent interference from the high-rate video feed. A POSITA would have been motivated to combine these teachings to create a more robust and reliable control system.
    • Expectation of Success: High. The combination involved applying a known technique (separating communication channels for control and video) to a known device (the Lenser/USF controller) to achieve the predictable result of improved control reliability. Connecting peripherals to a smart phone via a cable was a well-understood practice.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Jamieson (Application # 2009/0037024) to teach dynamic communication protocol switching for controlling heterogeneous vehicles, and Nielsen (Patent 8,355,818) to teach displaying a vector arrow indicating a heading for the vehicle to reach a specified location.

4. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-18 of the ’230 patent as unpatentable.