PTAB

IPR2021-00324

Platform Science Inc v. XRS Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Techniques for Shipping and Fleet Management
  • Brief Description: The ’934 patent discloses techniques for communicating fleet vehicle information. The system includes a data acquisition device mounted in a vehicle that communicates via a short-range wireless link to a portable mobile device, which in turn communicates via a long-range wireless link with a remote network device or control center.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8-17, and 19-23 are obvious over Nehowig in view of Skeen and Waite.

  • Prior Art Relied Upon: Nehowig (Application # 2012/0194679), Skeen (Application # 2005/0096809), and Waite (Application # 2012/0072109).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Nehowig disclosed the foundational system claimed in the ’934 patent: a portable, in-cab computing device that wirelessly communicates with a vehicle-mounted onboard computer (OBC) to manage fleet operations. Nehowig’s portable device serves as the user interface for the OBC and can be removed from the vehicle. Petitioner argued that Skeen supplied a missing detail in Nehowig by teaching an onboard diagnostic module that automatically detects and adapts to various communication protocols (e.g., SAE J1850, ISO 9141) used by different vehicle engine control modules (ECMs). This functionality directly maps to the ’934 patent’s limitation of "automatically adapt[ing] to a detected type of communication protocol." Finally, Petitioner contended that Waite taught integrating a sophisticated navigation and trip scheduling application into such a system. Waite's system processes vehicle data, driver information, and communications to generate and display a "transport schedule," which aligns with the trip scheduling limitations of the challenged claims.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references for predictable results. A POSITA implementing Nehowig's system, which mentions various diagnostic connections (e.g., J1708, OBDII), would be motivated to consult a reference like Skeen to solve the known problem of handling the different communication protocols used by various vehicle manufacturers. The combination was presented as a simple substitution of Skeen’s known multi-protocol interface for Nehowig’s less-detailed diagnostic connection. Further, because Nehowig described its in-cab device as an "open platform" for third-party custom applications, a POSITA would be motivated to integrate Waite’s scheduling module to add valuable, commercially desirable features like regulatory compliance management (e.g., hours-of-service) and route optimization.
    • Expectation of Success: Petitioner asserted that combining these known elements would yield predictable results. Integrating Skeen's multi-protocol solution into Nehowig’s OBC would predictably result in a more versatile OBC. Likewise, adding Waite’s scheduling software as an application on Nehowig’s open-platform portable device would predictably enhance its functionality without changing the fundamental operation of either system.

4. Key Claim Construction Positions

Petitioner argued that the means-plus-function limitations in claims 16 and 19 required construction based on the ’934 patent’s specification. These constructions were central to mapping the prior art.

  • “means for wirelessly receiving” [16A]: Petitioner proposed the function is "wirelessly receiving vehicle data from a data acquisition device mounted inside a vehicle when in close proximity to the data acquisition device." The corresponding structure identified in the specification was a "short-range wireless communication transceiver."
  • “means for accepting inputs” [16B]: Petitioner identified the function as "accepting inputs of driver communications from the driver" and the corresponding structure as a "user interface."
  • “means for processing” [16D]: Petitioner identified the function as "processing, into a trip schedule, at least one of: vehicle data, driver information, and driver communications." The corresponding structure was a "processor executing software that generates the trip schedule."
  • “means for presenting” [16E]: Petitioner identified the function as "presenting, in real-time, the trip schedule and the driver communications to the driver" and the corresponding structure as a "display device."

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-6, 8-17, and 19-23 of the ’934 patent as unpatentable under 35 U.S.C. §103.