PTAB
IPR2021-00504
Google LLC v. NavBlazer LLC
1. Case Identification
- Case #: IPR2021-00504
- Patent #: 9,885,782
- Filed: February 5, 2021
- Petitioner(s): Google LLC
- Patent Owner(s): NavBlazer, LLC
- Challenged Claims: 1-2, 5-12, 14-17, and 19
2. Patent Overview
- Title: Apparatus and Method for Providing Information to a User in a Vehicle
- Brief Description: The ’782 patent discloses an in-vehicle apparatus for providing route guidance and other pertinent travel information, such as traffic, weather, and maintenance services. The apparatus uses a global positioning device, a processing device, and a display or speaker to communicate information to the user and can connect wirelessly to external computers to obtain updated information.
3. Grounds for Unpatentability
Ground 1: Obviousness over Schreder and PHOSITA Knowledge - Claims 1-2, 6-8, and 14 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, which describes an automobile navigation system, discloses all limitations of independent claim 1. Schreder’s system includes a GPS receiver (global positioning device), a "route planning processor 70" that calculates routes using vehicle location and destination data (processing device), a display and speaker for providing route information, and a radio data system (RDS) that functions as a receiver for "up-to-date traffic flow information." For dependent claims, Petitioner asserted that Schreder’s processor continuously monitors for deviations and dynamically reroutes (claim 2), and its RDS was known to receive traffic forecasts (claim 6), road construction information (claim 7), and weather conditions (claim 8), all of which would be obvious to a POSITA to implement.
- Motivation to Combine (for §103 grounds): The motivation for incorporating general knowledge was based on implementing known technologies for their intended and recognized purposes. For example, a POSITA would have understood that an RDS, as disclosed in Schreder, was commonly used to receive not just traffic data but also traffic and weather forecasts as part of its standard functionality.
- Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success as it involved applying conventional knowledge about existing radio data systems to the navigation system taught by Schreder.
Ground 2: Obviousness over Schreder and Van Ryzin - Claims 15 and 19 are obvious over Schreder in view of Van Ryzin.
- Prior Art Relied Upon: Schreder (Patent 5,504,482) and Van Ryzin (Patent 5,844,505).
- Core Argument for this Ground:
- Prior Art Mapping: This ground targets independent claim 15, which adds a "camera for obtaining a photograph, a picture, or an image" of a road or traffic. Petitioner argued that while Schreder discloses an "electro-optical obstacles detection system," Van Ryzin explicitly teaches an automobile navigation system incorporating a "wide angle CCD camera" to image areas in front of the vehicle. Van Ryzin uses the camera to recognize road signs (e.g., speed limits, road construction) and determine the vehicle's location. The remaining limitations of claim 15 (GPS, processor, display, receiver) were argued to be taught by Schreder, as established in Ground 1. Dependent claim 19, which adds automatic rerouting, was also met by Schreder's dynamic rerouting feature.
- Motivation to Combine (for §103 grounds): A POSITA would combine Van Ryzin’s camera with Schreder’s navigation system to improve safety and functionality. Adding the ability to recognize local conditions like road construction and speed limits, as taught by Van Ryzin, would directly further the stated safety objectives of Schreder's system.
- Expectation of Success (for §103 grounds): Success was predictable because both references are in the same field of interactive navigation systems, and integrating a camera for environmental awareness was a known method for enhancing such systems.
Ground 3: Obviousness over Schreder and Hanchett - Claim 5 is obvious over Schreder in view of Hanchett.
Prior Art Relied Upon: Schreder (Patent 5,504,482) and Hanchett (Patent 5,396,429).
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses claim 5, which depends on claim 1 and adds the feature of providing a "video preview of the travel route or a picture or image along the travel route." Petitioner asserted Schreder meets the base claim limitations but does not expressly disclose a video preview. Hanchett was argued to cure this deficiency by teaching a "traffic condition information system" that uses a network of cameras to provide a "sequential presentation of video images that simulates traveling the roadway" so a user can "preview the traffic conditions."
- Motivation to Combine (for §103 grounds): A POSITA would be motivated to add Hanchett's video preview capability to Schreder's system to solve the common problem of providing users with more useful and detailed traffic information. This combination would leverage Schreder's route guidance with Hanchett's real-time visual data to allow drivers to make better-informed route choices.
- Expectation of Success (for §103 grounds): The combination was a predictable integration of two complementary information types (route guidance and visual traffic data) within the known framework of an in-vehicle navigation system.
Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Schreder with Behr (Patent 5,808,566) for receiving news reports and remote route calculation, and with Suman (Patent 6,028,537) for display mounting on a dashboard and hands-free voice control. Further grounds were presented applying these same combinations under an alternative claim construction.
4. Key Claim Construction Positions
- Petitioner argued that the challenged claims are unpatentable under two competing claim construction proposals from a related district court litigation.
- For terms like "information regarding the travel route" and "maintenance information," the Patent Owner proposed a broad construction ("Data associated with...a determined or identified path"). In contrast, the Defendants in the parallel litigation proposed a narrower construction requiring the information be "received from cameras or devices stationed at locations on the travel route."
- Petitioner contended its primary grounds (1-6) render the claims obvious under the Patent Owner's broader construction. It presented alternative grounds (7-11), adding Hanchett (which teaches stationed cameras) to each primary combination, to demonstrate unpatentability even under the narrower proposed construction.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 5-12, 14-17, and 19 of the ’782 patent as unpatentable.