PTAB

IPR2020-01254

Apple Inc v. NavBlazer LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Providing Information
  • Brief Description: The ’782 patent relates to an in-vehicle apparatus for providing a user with route guidance and pertinent travel information. The apparatus uses a global positioning device to determine its location, processes route information, and communicates travel-related data such as traffic and weather conditions to the user via a display or speaker.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 7, and 8 are obvious over Schreder in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Schreder (Patent 5,504,482) and the general knowledge of a Person of Ordinary Skill in the Art (POSITA).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schreder, which was not considered during prosecution, teaches all limitations of the challenged claims. Independent claim 1 recites an apparatus with a global positioning device, a processing device for determining a travel route, a display or speaker for providing route information, and a receiver for traffic information. Petitioner asserted that Schreder discloses an automobile navigation system with these exact features: a GPS receiver for vehicle location (meeting the "global positioning device" limitation), a "route planning processor" that calculates routes to a destination (meeting the "processing device" limitation), a display and speaker for providing turn-by-turn directions (meeting the "display device or a speaker" limitation), and a radio data system that receives "up-to-date traffic flow information" (meeting the "receiver" limitation).
    • For the dependent claims, Petitioner contended Schreder’s disclosures render them obvious. Claim 2 (dynamic rerouting) was allegedly met by Schreder's teaching that its route planning processor continuously monitors the vehicle's position, detects deviations, and "dynamically reroute[s] the planned route." Claims 7 (maintenance information) and 8 (weather information) were allegedly rendered obvious because Schreder explicitly states its radio data system receives various types of traffic flow information, including "road construction" and "weather conditions," and that it provides alerts to the driver about blockages.
    • Motivation to Combine (for §103 grounds): The ground relies on combining Schreder with the general knowledge of a POSITA. Petitioner argued a POSITA would have understood that Schreder’s system, designed to provide comprehensive and up-to-date travel information, would naturally process and display all relevant received data pertinent to a user's route. This would include specific data types like road construction and weather conditions, which Schreder explicitly lists as receivable information. The motivation was to improve the utility and safety of the navigation system, a goal inherent in Schreder’s own teachings.
    • Expectation of Success (for §103 grounds): Petitioner asserted a POSITA would have had a high expectation of success because displaying received radio data messages like weather or construction alerts on a screen or through a speaker was a simple and predictable implementation using well-known techniques at the time.

4. Key Claim Construction Positions

  • Petitioner argued that the term "apparatus" should be interpreted broadly, consistent with the ’782 patent’s intrinsic record. It was contended that "apparatus" is not limited to a single, self-contained device but can encompass a system of multiple, distinct components, including those that may be remotely located. This construction was crucial for mapping the distributed components of the system described in Schreder to the single "apparatus" recited in the claims.

5. Arguments Regarding Discretionary Denial

  • Petitioner presented extensive arguments that discretionary denial under either General Plastic or Fintiv would be inappropriate.
  • Serial Petitions: Petitioner argued against denial based on serial petitioning factors, noting this was its first challenge to the ’782 patent. It distinguished its petition from a prior IPR filed by Unified Patents (the "Unified IPR"), stating it was not a party to that proceeding, had no significant relationship with Unified Patents, and was relying on entirely different prior art (Schreder, versus Obradovich in the Unified IPR). This was done to show the petition was not a duplicative or abusive "follow-on" challenge.
  • Parallel Litigation (Fintiv Factors): Petitioner argued the Fintiv factors weighed heavily in favor of institution. It contended that a district court stay was likely if IPR was instituted. Further, it argued the scheduled trial date of November 15, 2021, was uncertain due to the COVID-19 pandemic and potential delays, whereas the Board’s statutory deadline for a Final Written Decision (FWD) was firm, making it likely the FWD would issue before any trial. Petitioner also asserted that investment in the parallel litigation was minimal, as the Markman hearing had not yet occurred, and there was no overlap between the invalidity issues in the IPR and any contentions served in the district court.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1, 2, 7, and 8 of the ’782 patent as unpatentable.