Unified Patents LLC v. NavBlazer LLC

1. Case Identification

• Case #: IPR2020-00983
• Patent #: 9,885,782
• Filed: May 29, 2020
• Petitioner(s): Unified Patents, LLC
• Patent Owner(s): NavBlazer, LLC
• Challenged Claims: 1-5, 7-8, 10-19, 21-23, and 25

2. Patent Overview

• Title: Vehicle Navigation and Information System
• Brief Description: The ’782 patent describes a vehicle apparatus that determines and displays a travel route. The system provides the vehicle operator with useful information regarding the route, such as traffic conditions, which can be received from remote sources like video cameras via a network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Obradovich - Claims 1, 7-8, 10-12, and 15-17 are obvious over Obradovich.

• Prior Art Relied Upon: Obradovich (Patent 6,275,231).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Obradovich discloses a vehicle control and management system that meets all limitations of the challenged independent claims. Obradovich’s system includes a GPS-based navigation subsystem, a processor, and a display to determine a route and provide route-related information. It further teaches obtaining traffic and weather information from an online service via a wireless connection (the claimed receiver) and presenting it on a display or through an audio system. For claims requiring a camera, Petitioner contended that Obradovich’s disclosure of running video files of traffic downloaded from the internet renders it obvious that the system would include cameras to source those files.
  • Motivation to Combine (for §103 grounds): This ground is based on a single reference.
  • Expectation of Success (for §103 grounds): Petitioner asserted that a person of ordinary skill in the art (POSITA) would have readily recognized that Obradovich’s system performed the functions of the challenged claims.

Ground 2: Obviousness over Obradovich and Lappenbusch - Claims 1, 3-5, 7-8, 10-13, 15-18, 21-22, and 25 are obvious over Obradovich in view of Lappenbusch.

• Prior Art Relied Upon: Obradovich (Patent 6,275,231) and Lappenbusch (Patent 5,982,298).
• Core Argument for this Ground:
  • Prior Art Mapping: Obradovich was asserted to provide the base navigation system that determines a route and displays traffic conditions. Lappenbusch was introduced to teach an interactive traffic display system that uses the internet to access and display recent images or short video clips from remote cameras positioned along road segments. Petitioner argued that combining these references teaches an apparatus that receives video traffic information regarding a travel route from remote cameras over a network and provides it to the user, as recited in the claims.
  • Motivation to Combine: A POSITA would combine the references because they are in the same field and provide complementary disclosures. While Obradovich mentioned downloading video traffic files, Petitioner argued it lacked implementation details. A POSITA would look to Lappenbusch for its explicit teachings on how to obtain video from remote cameras and make it accessible via the internet for display in a vehicle.
  • Expectation of Success: The combination was presented as a predictable integration of known elements to achieve a known result. Both systems were designed to provide drivers with useful route information, ensuring a high expectation of success.

Ground 3: Obviousness over Obradovich and Hanchett - Claims 1, 3-5, 7-8, 10-13, 15-18, 21-23, and 25 are obvious over Obradovich in view of Hanchett.

• Prior Art Relied Upon: Obradovich (Patent 6,275,231) and Hanchett (Patent 5,396,429).

• Core Argument for this Ground:

  • Prior Art Mapping: Similar to Ground 2, Obradovich provided the base navigation system. Hanchett was asserted to teach a traffic condition information system that uses a TV receiver in a mobile unit to receive and display video images from remote cameras monitoring a roadway. This combination, Petitioner argued, discloses a system that receives video traffic information via a broadcast receiver and displays it, satisfying the claim limitations using a non-internet-based communication method.
  • Motivation to Combine: A POSITA in the 1998 timeframe would have recognized the bandwidth and availability limitations of the internet and been motivated to use more established broadcast technologies like television, as taught by Hanchett. Obradovich’s system was disclosed as being capable of receiving TV programs, making the integration of Hanchett’s TV-based traffic video system a logical and advantageous modification.
  • Expectation of Success: Petitioner argued for a high expectation of success because both systems involve in-vehicle units designed to receive and display video, making the combination of Hanchett’s traffic video feed into Obradovich's multimedia system straightforward.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations adding Morimoto (Patent 6,018,697) to teach automatically detecting a route departure and determining a second travel route. Further combinations added Bouve (Patent 5,648,769) to explicitly teach providing information about road construction as a form of maintenance information.

4. Key Claim Construction Positions

• Petitioner argued that no special claim construction was necessary. Key terms such as "information regarding the travel route" and "traffic information or information regarding a traffic condition" should be given their plain and ordinary meaning. Petitioner contended that a POSITA would understand these terms to be inclusive of the examples provided in the ’782 patent’s specification, and that the cited prior art discloses identical examples of such information.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) would be improper. Although the primary reference, Obradovich, was cited in a multi-page Information Disclosure Statement during the prosecution of the parent application, it was never substantively discussed on the record or applied in a rejection by the examiner. Therefore, Petitioner asserted that the examiner did not meaningfully consider the reference in a manner that would warrant denial of the petition.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-5, 7-8, 10-19, 21-23, and 25 of Patent 9,885,782 as unpatentable.