PTAB

IPR2020-00948

Unified Patents LLC v. Arsus LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Rollover Prevention Apparatus
  • Brief Description: The ’494 patent discloses a vehicle rollover prevention system featuring an adaptive steering range limiting device. The system is designed to prevent a driver from turning the steering wheel beyond a calculated rollover threshold, particularly at high speeds, while otherwise allowing for an unrestricted range of motion.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 8-12, and 21-22 are obvious over Dechamp in view of Hille.

  • Prior Art Relied Upon: Dechamp (WO 2007/031817) and Hille (Application # 2005/0222727).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dechamp, a steer-by-wire system, discloses the core elements of the challenged claims, including a steering input device, sensors, an actuator, and an electronic control unit (CPU). Dechamp’s system prevents rollover by calculating a maximum allowable steering angle (θmax) based on vehicle speed and limiting the steerable wheels to that angle. To the extent Dechamp does not explicitly teach sensing every parameter or responding to a critical rollover tendency threshold, Hille supplies these elements. Hille discloses a rollover protection system that uses sensors for lateral acceleration and rate of change of steering angle to determine a "rollover tendency" and sends a control signal for corrective action when that tendency reaches a critical limit.
    • Motivation to Combine: A POSITA would combine Hille’s advanced sensor suite and critical limit detection with Dechamp’s foundational speed-based system to create a more robust and responsive rollover prevention apparatus. Incorporating Hille’s sensors would allow for better prediction of imminent rollovers in varied conditions (e.g., sudden steering maneuvers) that Dechamp’s speed-only system might not fully account for, thus improving overall vehicle safety.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references operate in the same field of automotive stability control, use similar components (sensors, controllers, actuators), and Hille expressly contemplates its system could be used with steer-by-wire systems like Dechamp. The combination would involve integrating known sensor types to enhance a known control strategy, a predictable endeavor.

Ground 2: Claims 1-5, 8-12, and 21-22 are obvious over Dechamp in view of Turner.

  • Prior Art Relied Upon: Dechamp (WO 2007/031817) and Turner (Application # 2005/0087389).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Dechamp teaches the primary system of limiting steering angle based on vehicle speed. Turner complements this by disclosing a rollover controller that uses sensors to monitor vehicle body roll and lateral acceleration. When these sensors detect that a body roll value exceeds a predetermined maximum, Turner’s controller directs a steering assist motor to supplement the steering angle and prevent rollover. This maps to the claim limitations requiring an actuation signal when a sensed parameter exceeds a predetermined magnitude.
    • Motivation to Combine: A POSITA would be motivated to integrate Turner's body-roll and lateral-acceleration sensors into Dechamp's system to enhance its functionality. This would provide a more direct measurement of rollover risk, especially in dynamic situations or on uneven surfaces, adding a layer of safety beyond Dechamp's speed-based calculations. The goal would be to create a more comprehensive system that reacts to both vehicle speed and real-time vehicle dynamics.
    • Expectation of Success: Success would be expected because Turner explicitly states its system can be substituted into various steering systems, making it compatible with Dechamp’s steer-by-wire architecture. The components and control logic described in Turner were well-known, ensuring their integration into Dechamp’s system would yield the predictable result of a more robust rollover prevention system.

Ground 3: Claims 1-5, 8-12, and 21-22 are obvious over Dechamp alone.

  • Prior Art Relied Upon: Dechamp (WO 2007/031817).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Dechamp alone discloses all elements of the challenged claims. Dechamp’s system prevents rollover by limiting the steering angle based on vehicle speed, which inherently involves sensing speed (a driving parameter) and sending actuation signals from its CPU to an actuator when speed exceeds predetermined magnitudes (i.e., transitioning between different speed ranges with different steering ratios). This process allows the vehicle to be steered within a non-rollover range but prevents it from being steered beyond the rollover threshold (θmax). The system’s operation in a "very low speed range" with unrestricted steering corresponds to the claimed "first mode" or "inactive mode," while its operation in higher speed ranges with limited steering corresponds to the "second mode" or "active mode."
    • Key Aspects: Petitioner argued that any minor differences between the claim language and Dechamp’s disclosure represent routine implementation details or design choices that would have been obvious to a POSITA. For example, a POSITA would understand that to implement Dechamp's speed-dependent steering limits, the system must continuously send actuation signals as the vehicle’s speed crosses predetermined thresholds.

4. Key Claim Construction Positions

  • "a steering apparatus configured to allow a vehicle to be steered out of an SOA path but not to the extent of vehicle rollover" (claim 21): Petitioner argued this term is not a means-plus-function limitation under 35 U.S.C. §112, ¶ 6. The argument centered on the fact that other independent claims (1 and 8) recite the structure of the "steering apparatus" as including a steering input device, actuator, sensor, and electronic control unit. Petitioner contended that because the term is treated as structural in some claims, it should be treated as structural in claim 21 as well, and that a POSITA would understand "steering apparatus" to connote a definite structure in the automotive field.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-5, 8-12, and 21-22 of the ’494 patent as unpatentable.