PTAB

IPR2021-00503

Google LLC v. NavBlazer LLC

Log In

1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Providing Information to an Operator of a Vehicle
  • Brief Description: The ’136 patent discloses an in-vehicle apparatus for providing route guidance and other travel-related information, such as weather and traffic. The system uses a global positioning device to determine vehicle location, a processor to calculate routes, and a display or speaker to present information received wirelessly from remote sources.

3. Grounds for Unpatentability

Ground 1: Obviousness over Schreder - Claims 55-56, 60-62, 69-71, 75-77, 82, 86, 89, 91, 93-95, and 98 are obvious over Schreder in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Schreder (Patent 5,504,482).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schreder, an automobile navigation system, disclosed all elements of the base independent claims (e.g., claim 55). Schreder taught an apparatus with a GPS receiver (a global positioning device), a "route planning processor 70" for calculating travel routes, a display and speaker for outputting information, and an RF receiver (a "radio data system") for receiving remotely transmitted traffic information. For dependent claims requiring traffic forecasts (claim 60) or weather information (claim 62), Petitioner contended that a person of ordinary skill in the art (POSITA) would have known that the Radio Data System (RDS) disclosed in Schreder was commonly used to transmit such information, making its inclusion an obvious design choice.
    • Motivation to Combine (for §103 grounds): The primary motivation was to use the components of Schreder’s disclosed navigation system for their intended and well-known purposes.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in using Schreder's RDS to receive standard broadcast information like weather and traffic forecasts.

Ground 2: Obviousness over Schreder and Behr - Claims 63, 66, 78, 79, 85, 96, and 97 are obvious over Schreder in view of Behr.

  • Prior Art Relied Upon: Schreder (Patent 5,504,482) and Behr (Patent 5,808,566).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring the receipt of a "news report" (claim 63) or the receipt of travel route information from a remote computer (claim 66). While Schreder's system was self-contained, Behr taught a navigation system with a centralized remote base unit that calculated routes and provided external data, including "news, weather, and/or traffic advisory information." Behr's system was designed to overcome the "drawbacks" of self-contained systems like Schreder by offloading processing and data storage.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Behr's remote processing and third-party data integration (including news) with Schreder’s in-vehicle system to enhance its capabilities. This combination would leverage a powerful remote server for complex route calculations and provide access to a wider range of information, directly addressing the limitations of onboard systems that Behr identified.
    • Expectation of Success (for §103 grounds): Success would be expected, as combining a local client device with a remote server for data processing was a well-understood and predictable system architecture.

Ground 3: Obviousness over Schreder and Suman - Claims 64, 67, 80, 87, and 88 are obvious over Schreder in view of Suman.

  • Prior Art Relied Upon: Schreder (Patent 5,504,482) and Suman (Patent 6,028,537).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted claims requiring the display to be mounted on a dashboard or console (claim 64) and the inclusion of a microphone and voice recognition for hands-free operation (claim 67). Suman explicitly taught mounting a navigation display in an overhead console or instrument panel to improve driver visibility and safety. Suman also disclosed a microphone and voice recognition unit to enable hands-free control, specifically to reduce the driver distraction associated with keypad use.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Suman's user interface and safety features with Schreder’s navigation system to improve its ergonomics and reduce driver distraction. The placement of a display and the method of user input were well-known design considerations with a finite number of predictable solutions, and Suman provided an established, safety-oriented approach.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as integrating a display and microphone into a vehicle's console or dashboard were routine and predictable design implementations.

  • Additional Grounds: Petitioner asserted alternative obviousness challenges (Grounds 6-8) based on a different claim construction. These grounds added Hanchett (Patent 5,396,429) to the primary combinations to teach receiving traffic information from cameras and image sensors stationed along a roadway.

4. Key Claim Construction Positions

  • Petitioner addressed a claim construction dispute from related district court litigation, arguing the challenged claims were unpatentable under either party's proposed construction.
  • The key disputed term was "information regarding the travel route."
    • Patent Owner's Construction: "Data associated with or representing a determined or identified path to a destination."
    • Defendants' Construction (adopted by Petitioner for alternative grounds): "information received from cameras or devices stationed at locations on the travel route."
  • Petitioner argued its primary grounds (2-4) invalidated the claims under the Patent Owner's broader construction, while its alternative grounds (6-8) invalidated the claims under the narrower construction requiring information from stationed cameras, a feature supplied by the Hanchett reference.

5. Arguments Regarding Discretionary Denial

  • Petitioner disclosed that it was concurrently filing a second inter partes review (IPR) petition (IPR2021-00502) against different claims of the ’136 patent.
  • Petitioner argued that institution of two parallel IPR petitions was reasonable and should not be discretionarily denied because the total number of challenges could not be addressed within the word limit for a single petition. It asserted there was no overlap between the claims challenged or the grounds asserted in the two petitions.

6. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 55-56, 60-64, 66-67, 69-71, 75-80, 82, 85-89, 91, and 93-98 of the ’136 patent as unpatentable.