PTAB

IPR2021-00502

Google LLC v. NavBlazer LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Providing Route Guidance and Other Information to a User in a Vehicle
  • Brief Description: The ’136 patent describes an apparatus for providing information to a user in a vehicle, including route guidance, traffic conditions, weather, and maintenance services. The system involves a vehicle-based apparatus communicating wirelessly with an external central processing computer to obtain and display travel-related information.

3. Grounds for Unpatentability

Ground 1: Obviousness over Behr and Schreder - Claims 23, 24, 35-44, 48, and 51-54 are obvious over Behr in view of Schreder.

  • Prior Art Relied Upon: Behr (Patent 5,808,566) and Schreder (Patent 5,504,482).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Behr discloses the core apparatus of independent claims 23 and 48: a centralized base unit that receives a route request from a mobile unit in a vehicle, calculates a travel route, and transmits a message containing route information back to the mobile unit. Behr teaches a client-server architecture where a powerful base unit performs heavy processing, solving the drawbacks of self-contained vehicle systems that require large onboard data storage. However, Petitioner contended that Behr only discloses detecting a deviation from a planned route to trigger an alarm, not to automatically recalculate a new route. To supply this missing element, Petitioner asserted that Schreder, which describes an in-vehicle navigation system, explicitly teaches continuously monitoring a vehicle's position, detecting deviations from a planned route, and "dynamically rerout[ing] the planned route" in response.
    • Motivation to Combine: Petitioner argued a POSITA would combine Schreder's dynamic rerouting functionality with Behr's superior centralized system architecture. Behr itself teaches the drawbacks of self-contained systems like Schreder's. Therefore, a POSITA would have been motivated to implement Schreder’s known and desirable rerouting feature within Behr's more efficient centralized processing model to enhance its capabilities. The combination would provide users with the benefit of automatic rerouting without requiring extensive processing power and data storage within the vehicle itself.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as both references are in the same field of vehicle navigation and involve standard route calculation and position monitoring techniques. Implementing Schreder’s rerouting logic on Behr’s centralized server would be a straightforward application of known principles.

Ground 5: Obviousness over Behr, Schreder, and Hanchett - Claims 23, 24, 35-44, 48, and 51-54 are obvious over Behr in view of Schreder and further in view of Hanchett.

  • Prior Art Relied Upon: Behr (Patent 5,808,566), Schreder (Patent 5,504,482), and Hanchett (Patent 5,396,429).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses an alternative claim construction for terms like "information regarding the travel route," which requires the information to be "received from cameras or devices stationed at locations on the travel route." Petitioner asserted that while Behr and Schreder provide the foundational navigation system, they do not explicitly disclose receiving information from cameras stationed along a route. Hanchett was introduced to teach this specific limitation. Hanchett describes a traffic condition information system using a "plurality of monitor stations placed at intervals along a roadway," where each station includes an "image sensor for sensing visual images of the traffic" that are then transmitted to mobile user units.
    • Motivation to Combine: A POSITA would be motivated to add Hanchett’s capability of receiving real-time visual information from stationed cameras to the combined Behr/Schreder system. This addition would leverage existing sensor infrastructure to provide users with more accurate and useful travel information, such as live video previews of traffic conditions, directly enhancing the utility of the navigation system. This would allow users to "evaluate the information in light of his or her particular situation" and "make route choices" based on actual visual data, a clear improvement over systems relying solely on map and abstract traffic data.
    • Expectation of Success: Integrating a data feed from a camera network like Hanchett's into a navigation system like Behr's would be predictable. The base unit in Behr is already designed to integrate data from third-party sources, making the inclusion of Hanchett’s visual traffic data a straightforward enhancement.

  • Additional Grounds: Petitioner noted that Grounds 2-4 and 6-8 are included in a separate, concurrently filed IPR petition (IPR2021-00503) challenging other claims of the ’136 patent.

4. Key Claim Construction Positions

  • Petitioner argued that the challenged claims are unpatentable under either the Patent Owner’s proposed claim constructions or an alternative set of constructions proffered by defendants in related district court litigation.
  • "information regarding the travel route":
    • Patent Owner's Construction: "Data associated with or representing a determined or identified path to a destination."
    • Defendants' Construction: "information received from cameras or devices stationed at locations on the travel route."
  • Petitioner structured its invalidity arguments to succeed under either interpretation, using Ground 1 to address the Patent Owner's broader construction and Ground 5 (which adds Hanchett) to specifically address the Defendants' narrower "cameras or devices" construction.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial by explaining the necessity of filing a parallel IPR petition (IPR2021-00503). It was asserted that the ’136 patent contains 98 claims, and the total number of challenged claims across both petitions could not be reasonably addressed within a single petition’s word limit. Furthermore, the petitions challenge different claim sets, are directed to different embodiments, and rely on different combinations of prior art, thereby avoiding overlap and presenting distinct unpatentability challenges that warrant separate consideration.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 23, 24, 35-44, 48, and 51-54 of the ’136 patent as unpatentable under 35 U.S.C. §103.