PTAB

IPR2021-01353

Ford Motor Co v. Safe Driving Technologies LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: System for Controlling the User Interfaces of Telematics Devices
  • Brief Description: The ’709 patent discloses a vehicle telematics system that controls device user interfaces to reduce driver distraction. The system automatically switches between different modes of operation, disabling or limiting certain features based on sensor inputs like vehicle speed or transmission information received from a vehicle data bus.

3. Grounds for Unpatentability

Ground 1: Obviousness over Krueger and Gelvin - Claims 1-4 and 15 are obvious over Krueger in view of Gelvin and the general knowledge of a POSITA.

  • Prior Art Relied Upon: Krueger (Patent 7,711,355) and Gelvin (Patent 7,484,008).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Krueger taught a telematics system with all major elements of the challenged claims, including a "first mode" of operation and a "reduced distractions mode" that is automatically triggered when vehicle speed exceeds a predetermined threshold (e.g., 130 km/h). In the reduced mode, Krueger disabled features like the car radio and telephone functions. However, Krueger disclosed connecting its components (phone, radio, sensors) to a decision unit via dedicated wires. Petitioner asserted that Gelvin supplied the missing limitation of a vehicle "bus" for interconnecting these components.
    • Motivation to Combine (for §103 grounds): Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Gelvin’s vehicle data bus with Krueger's system to achieve predictable benefits. At the time of the invention, data buses were ubiquitous in the automotive industry. A POSITA would be motivated to replace Krueger's complex dedicated wiring with Gelvin's bus to reduce wiring, cost, and complexity, and to create a standardized environment for communication between vehicle components.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success, as integrating components onto a standard vehicle data bus was a well-known and common practice for improving vehicle electronic systems.

Ground 2: Obviousness over Trauner and Gelvin - Claims 1-3, 5-7, and 14 are obvious over Trauner in view of Gelvin and the general knowledge of a POSITA.

  • Prior Art Relied Upon: Trauner (Application # 2002/0070852) and Gelvin (Patent 7,484,008).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Trauner disclosed a vehicle safety system that switched between a full operation mode (when stopped) and a reduced distractions mode (when in motion). This switch was triggered by vehicle movement or transmission state information from a vehicle motion sensor, which disabled display and keyboard inputs. Like Krueger, Trauner’s components were described as being connected to a central microcomputer, presumably via wires. Petitioner again relied on Gelvin to teach the use of a vehicle data bus to interconnect the components disclosed in Trauner.
    • Motivation to Combine (for §103 grounds): The motivation was identical to Ground 1. A POSITA would have been motivated to apply Gelvin's common data bus technology to Trauner's system to gain the predictable advantages of reduced wiring, cost, and standardized communication protocols.
    • Expectation of Success (for §103 grounds): Success was expected because combining sensors and a microcomputer on a vehicle bus was a standard and predictable design choice.

Ground 3: Obviousness over Tan and Gelvin - Claims 15-16 are obvious over Tan in view of Gelvin and the general knowledge of a POSITA.

  • Prior Art Relied Upon: Tan (Patent 6,574,531) and Gelvin (Patent 7,484,008).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tan disclosed a vehicle computer system with multiple operating modes based on whether the vehicle is in motion. Tan taught switching from a "full functionality version" of a screen to a "limited functionality version" (e.g., with abbreviated or truncated information) when motion is detected. Claim 15 requires three distinct modes, which Petitioner mapped to Tan's full functionality screen (first mode), limited functionality screen (second mode), and a "common screen" that appears when the limited screen is unavailable (third mode). As with the other grounds, Petitioner argued Gelvin supplied the vehicle bus for connecting the sensors and computer system in Tan.
    • Motivation to Combine (for §103 grounds): The rationale for combining Tan with Gelvin mirrored that of the previous grounds: implementing a standard vehicle data bus was an obvious and beneficial modification to improve the connectivity and efficiency of the system described in Tan.
    • Expectation of Success (for §103 grounds): A POSITA would have expected predictable results from integrating Tan's motion-based display system with a standard vehicle bus as taught by Gelvin.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, noting that the trial in the parallel district court litigation was scheduled for February 2023, more than 18 months after the filing of the IPR petition. Petitioner stated its intent to move to stay the litigation post-institution to conserve judicial and party resources.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-7 and 14-16 of the ’709 patent as unpatentable.