PTAB

IPR2020-01253

Apple Inc v. NavBlazer LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Information System
  • Brief Description: The ’136 patent discloses a vehicle apparatus for providing route guidance and other pertinent travel information, such as traffic and weather conditions, to a user. The apparatus includes standard computing components, a global positioning device, and wireless communication capabilities to receive information from remote sources.

3. Grounds for Unpatentability

Ground 1: Obviousness over Obradovich - Claims 55, 62, 66, 69, 70, 77, 79, 85, 86, 88, 89, 95, 97, and 98 are obvious over Obradovich in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Obradovich (Patent 6,148,261).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Obradovich, which discloses a portable personal communication device (PCD), taught all limitations of the challenged claims. Obradovich’s PCD includes a GPS receiver for determining location, a processor for calculating travel routes based on user-selected waypoints, a display and speaker for outputting route information, and a wireless receiver for obtaining remote traffic and weather information. Petitioner contended that although Obradovich describes a portable device, it explicitly teaches integration with an automobile, and a person having ordinary skill in the art (PHOSITA) would have understood its functions apply directly to the vehicle context recited in the claims. Dependent claims relating to receiving weather information (claim 62) and hands-free operation via a microphone (claim 88) were also allegedly taught by Obradovich’s disclosure of a "Weather Map Request" function and its inclusion of a microphone for "voice activation."
    • Motivation to Combine (for §103 grounds): This ground is based primarily on a single reference, with the "combination" being the application of a POSITA's general knowledge to Obradovich's teachings. Petitioner asserted that a POSITA would have found it obvious to use the portable navigation features of Obradovich within a vehicle, as this was a primary and intended application for such devices.

Ground 2: Obviousness over Obradovich in view of Lefebvre - Claims 56, 71, 82, and 91 are obvious over Obradovich in view of Lefebvre.

  • Prior Art Relied Upon: Obradovich (Patent 6,148,261), Lefebvre (Patent 5,243,528).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring the detection of a departure from a travel route and the subsequent identification of a second travel route. Petitioner argued that while Obradovich taught route planning, it did not explicitly teach automatic rerouting upon deviation. Lefebvre was introduced to supply this missing element, as it expressly discloses an "off route" functionality that detects when a driver has strayed from a calculated route and provides "recovery options," including planning a new route from the vehicle's current position to the destination.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Lefebvre's deviation detection and route recalculation into Obradovich’s system to improve its functionality. Petitioner argued that route deviations are a common and predictable problem in navigation, and Lefebvre provided a known, desirable solution that would have been a straightforward addition to the Obradovich system.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because Obradovich already contained all the necessary hardware (GPS, processor, memory) and route-calculation software routines to implement the logic taught by Lefebvre.

Ground 3: Obviousness over Schreder - Claims 55, 56, 61, 62, 69, 70, 71, 76, 77, 82, 86, 89, 91, 94, 95, and 98 are obvious over Schreder in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Schreder (Patent 5,504,482).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Schreder as an alternative primary reference that disclosed a complete in-vehicle navigation system anticipating the ’136 patent. Schreder taught an apparatus with a GPS receiver (part of its RF navigation system) to determine vehicle location, a "route planning processor" to determine routes, and a display/speaker for outputting guidance. Critically, Schreder also disclosed a radio data system for receiving remotely broadcasted "up-to-date traffic flow information," including road construction and weather conditions, and using that information to "dynamically reroute the planned route." This, Petitioner argued, met the limitations of both the base claims and those requiring deviation detection and rerouting (e.g., claim 56).
    • Motivation to Combine (for §103 grounds): This ground asserted that Schreder alone, as understood by a POSITA, rendered the claims obvious without requiring a combination of references.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 61, 76, and 94 are obvious over Obradovich in view of Human Factors (a 1996 U.S. Dept. of Transportation publication) for teaching the receipt of road maintenance information, and that claim 88 is obvious over Schreder in view of Obradovich for teaching hands-free voice command functionality.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, asserting that the factors weighed in favor of institution.
  • Key arguments included that a stay of the parallel district court litigation was likely if the inter partes review (IPR) was instituted, the court's trial date of November 2021 was uncertain due to the COVID-19 pandemic and docket congestion, and the Board’s Final Written Decision (FWD) would likely issue before any trial.
  • Petitioner also noted that little investment had been made in the parallel litigation, as a Markman hearing had not yet occurred and invalidity contentions had not been served, minimizing any overlap or inefficiency.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 55, 56, 61, 62, 66, 69-71, 76, 77, 79, 82, 85, 86, 88, 89, 91, 94, 95, 97, and 98 of the ’136 patent as unpatentable.