PTAB

IPR2021-00325

Platform Science Inc v. XRS Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Fleet Vehicle Management
  • Brief Description: The ’575 patent discloses a system for managing fleet vehicles by recording vehicle and driver data. The system comprises a fixed electronic onboard recorder (EOBR) unit mounted in the vehicle, which communicates wirelessly with a separate portable mobile device that generates hours-of-service reports and other information.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 10-14, 17-20, 23, and 24 are obvious over the combination of Nehowig, the DOT Regulations, and Fedorchuk.

  • Prior Art Relied Upon: Nehowig (Application # 2012/0194679), Fedorchuk (Patent 8,788,139), and DOT Regulations (75 Fed. Reg. 17207, Apr. 5, 2010).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nehowig disclosed the core architecture of the claimed system: an onboard computing device (OBC) mounted in a vehicle that wirelessly communicates with a portable, in-cab computing device. This portable device uses the data from the OBC to generate driver logs. However, Nehowig did not detail how its OBC connects to various vehicle types. Fedorchuk was argued to supply this missing element by teaching a multi-protocol vehicle diagnostic interface that can automatically detect and adapt to various communication protocols (e.g., J1708, CAN, OBDII) used by different vehicle engine control modules (ECMs). Petitioner contended this combination disclosed the claimed "control circuitry configured to detect one or more protocols and automatically adapt." The DOT Regulations were asserted to provide the legal and functional requirements for EOBRs, such as the mandate to record specific "hours of service information," which the combined system would be designed to meet.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Fedorchuk's multi-protocol interface with Nehowig's OBC as a simple substitution of a known element to improve a known device. This would predictably solve the problem of making Nehowig's system compatible with a wider range of vehicles and OEMs, a known industry need. A POSITA would have been motivated to integrate the requirements of the DOT Regulations because Nehowig's system is explicitly for "DOT reporting/compliance," and any such commercial product would need to comply with federal mandates to be marketable.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because the combination involved applying known technologies for their intended purposes. Fedorchuk's interface was designed to connect to vehicle diagnostic ports and onboard computers like Nehowig's, and implementing regulatory requirements via software was a routine task.

Ground 2: Claims 8-9, 15-16, and 21-22 are obvious over the combination of Nehowig, the DOT Regulations, Fedorchuk, and McClellan.

  • Prior Art Relied Upon: Nehowig (Application # 2012/0194679), Fedorchuk (Patent 8,788,139), DOT Regulations (75 Fed. Reg. 17207, Apr. 5, 2010), and McClellan (Application # 2008/0252487).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 by adding McClellan to address dependent claims requiring specific sensors. Petitioner argued that while Nehowig disclosed that its OBC could include various sensors, it did not specify which types. McClellan was argued to remedy this by expressly disclosing a vehicle monitoring system that includes an accelerometer for detecting vehicle movement and monitoring driver performance (mapping to claims 8, 15, and 21) and a GPS receiver for location tracking (mapping to claims 9, 16, and 22). McClellan further taught that these components are preferably mounted within the housing of the onboard unit.
    • Motivation to Combine: A POSITA seeking to implement Nehowig's disclosed but undetailed "driver behavior reporting" feature would have been motivated to look to references like McClellan, which taught using an accelerometer for that exact purpose. Combining McClellan's teachings would provide data to assess driver performance and improve the accuracy of Hours of Service (HOS) logs. Furthermore, a POSITA would have been motivated to integrate the GPS receiver and accelerometer inside the OBC's housing, as taught by McClellan, to improve the system's reliability, protect components from shock and vibration, reduce installation costs, and create a more "plug-and-play" device.
    • Expectation of Success: Petitioner contended that integrating common, well-known components like GPS receivers and accelerometers into an electronic housing was a routine design choice for a POSITA. The combination would yield predictable results, enhancing the functionality of the primary system without altering its fundamental operation.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of Patent 10,255,575 as unpatentable.