PTAB

IPR2020-01535

Lyft Inc v. Quartz Auto Technologies LLC

Key Events

Petition

petition Intelligence

Title: Method for Providing User Location Information for a Personal Information Management Program
Brief Description: The ’085 patent relates to a method using location tracking technologies and calendaring applications to determine a user's speed and location. The system provides user location histories and/or scheduled events for selected time intervals.

Prior Art Relied Upon: Dashefsky (Patent 6,098,048).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Dashefsky discloses a vehicle tracking system that generates and analyzes "time-annotated vehicle-location data." This system processes position coordinates and time information to determine a vehicle's speed and predefined activities, such as speeding, by comparing the vehicle's speed to known speed limits. This data, which includes starting points, destination coordinates, and speed, is collected by an in-vehicle wireless device and processed at a central station.
- Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSA) would find it obvious to apply Dashefsky’s data collection and analysis techniques within a personal information management (PIM) program. PIM programs were a well-known approach for storing computerized records of personal activities, and using Dashefsky to automate the collection of data for what were essentially electronic travel diaries would have been an obvious improvement over manual methods.
- Expectation of Success: A POSA would have expected success in this implementation due to the predictability of combining these known techniques.

Prior Art Relied Upon: Dashefsky (Patent 6,098,048), Hamrick (Patent 6,356,841).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds on Dashefsky by adding Hamrick to more explicitly teach certain claim elements. Petitioner asserted that Hamrick discloses a GPS-based management system for tracking remote units from a central office. Hamrick’s system processes GPS data against predetermined parameters like speed limits, idle times, and location boundaries to monitor vehicle and driver activity. It generates various customizable reports, such as daily route histories, which function as a PIM program.
- Motivation to Combine: Petitioner argued a POSITA would combine Dashefsky and Hamrick because both references are in the same field of endeavor (vehicle location tracking) and address the same problem of centrally collecting and analyzing GPS data from multiple vehicles. A POSITA would have found it obvious to implement Hamrick's more advanced online PIM and reporting features (e.g., exception tracking, location boundaries) with Dashefsky's underlying data collection methods to create a more robust and feature-rich system.
- Expectation of Success: The combination involved implementing known location and reporting technologies to perform their intended functions, which would have yielded predictable benefits.

Prior Art Relied Upon: Dashefsky (Patent 6,098,048), Hamrick (Patent 6,356,841), Ratschunas (WO 2001/004577).
Core Argument for this Ground:
- Prior Art Mapping: Building on the Dashefsky/Hamrick combination, this ground adds Ratschunas to teach receiving location boundary and description information from a transmitter. Ratschunas discloses systems for determining a user's location via cellular radio networks, where a mobile device determines its position by measuring timing delays of signals from network base stations. These base stations function as transmitters of location-related information.
- Motivation to Combine: A POSITA would combine Ratschunas's cellular-based location technology with the GPS-based systems of Dashefsky and Hamrick to improve the system's robustness. Using cellular networks for location data would provide a fallback when GPS is unavailable or inaccurate (e.g., indoors or in urban canyons), a well-known technique to improve location-determining abilities.

Prior Art Relied Upon: Dashefsky (Patent 6,098,048), Hamrick (Patent 6,356,841), Bird (Patent 6,526,341).
Core Argument for this Ground:
- Prior Art Mapping: This ground modifies the Dashefsky/Hamrick combination by adding Bird to teach that the initiator requesting the information can be the wireless device itself. Bird discloses an in-vehicle Mobile Communication Terminal (MCT) with input and output devices that allows a vehicle operator to directly request, generate, and view driver activity logs on the device's display.
- Motivation to Combine: A POSITA would have been motivated to incorporate Bird's in-vehicle reporting capabilities into the Dashefsky/Hamrick system to provide drivers and technicians with direct, in-field access to their own data. This would predictably increase efficiency, reduce server load, and allow for on-site compliance checks or productivity reviews without relying solely on a central office.

"a rate of change in distance per unit of time": Petitioner argued that, for the purposes of this inter partes review (IPR), it adopted the Patent Owner's apparent interpretation from parallel litigation that this term refers to a determination of speed. This construction was central to Petitioner's argument that Dashefsky, which explicitly discloses calculating vehicle speed, meets this key limitation of the independent claims.

Petitioner argued that discretionary denial would be inappropriate.
Fintiv Factors: Petitioner contended that denial based on the parallel district court proceeding was not warranted because the litigation was in its early stages. The trial date was projected for January 2022 or later, well after a Final Written Decision (FWD) would issue, and significant investments in discovery and claim construction had not yet occurred.
General Plastic and §325(d): Petitioner asserted this was its first IPR against the ’085 patent. It argued the cited prior art was not cumulative to art used in a separate IPR filed by an unrelated party (IPR2020-01118). Furthermore, because the key prior art references (Dashefsky, Hamrick, etc.) were never presented to or considered by the USPTO during the original prosecution, denial under §325(d) would be improper.

Petitioner requests institution of IPR and cancellation of claims 1-23 of Patent 7,370,085 as unpatentable.