PTAB

IPR2021-01446

Ford Motor Co v. Safe Driving Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Controlling Telematic Device User Interfaces in Vehicles
  • Brief Description: The ’170 patent discloses methods for controlling a telematic device in a vehicle by sensing the device's movement. Based on a comparison of this movement to a threshold, the system alters the device’s outputs—for example, by preventing an output in its original format and providing it in a different format to reduce driver distraction.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 6, 10, 12-15, and 20 are obvious over Arnold.

  • Prior Art Relied Upon: Arnold (International Publication No. WO 98/43192A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Arnold, which discloses a "travel guide system," meets all limitations of the independent claims. Arnold’s system senses vehicle speed using a GPS receiver (sensing movement of the telematic device) and compares it to a predetermined speed (a threshold). When the speed is above the threshold, Arnold’s system blanks the visual display screen, thus preventing the visual output (original format). Concurrently, Arnold provides the information via a speech synthesizer in an audio format (a different format). When the speed falls below the threshold, the visual display is restored, permitting the output in its original format. Petitioner contended that Arnold’s disclosure of a user inputting a password to set the speed threshold met the "input accessible" limitation.
    • Motivation to Combine (for §103 grounds): This ground was asserted against Arnold alone in view of the knowledge of a person of ordinary skill in the art (POSITA). Petitioner argued that implementing Arnold's disclosed system was straightforward and that any minor variations, such as converting a textual display to an iconic one (claim 15), were well-known design choices for reducing driver cognitive load.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in implementing Arnold’s system, as it used conventional components like GPS receivers, processors, and speech synthesizers to achieve its safety-oriented goals.

Ground 2: Claims 1-4, 10, 14, 16, 17, 19-21, and 31 are obvious over Hardouin.

  • Prior Art Relied Upon: Hardouin (Patent 6,311,078).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Hardouin, which discloses a system for inhibiting wireless telephone functions based on vehicle speed, also rendered the claims obvious. Hardouin’s system uses a GPS-based "speed transceiver" to detect the speed of the wireless telephone (sensing movement) and compares it to a predefined limit (threshold). Above the threshold, Hardouin inhibits incoming call alerts like ringtones or vibrations (preventing output in original format) and can instead transmit a voice message to the caller (providing a different output). Below the threshold, the system allows "normal processing," permitting call alerts and keypad use for originating calls (permitting input/output in original format). Petitioner argued Hardouin's keypad served as the claimed "input interface."
    • Motivation to Combine (for §103 grounds): This ground was asserted against Hardouin alone. Petitioner contended Hardouin’s teachings directly addressed the problem of driver distraction, and its methods for disabling and re-enabling phone functions based on speed were a direct and obvious solution.
    • Expectation of Success (for §103 grounds): A POSITA would have readily understood how to implement Hardouin's logic using standard mobile phone technology, as all components and methods described were conventional at the time.

Ground 3: Claims 4 and 13 are obvious over Hardouin in view of Trauner or Krueger.

  • Prior Art Relied Upon: Hardouin (Patent 6,311,078), Trauner (Application # 2002/0070852), and Krueger (Patent 7,711,355).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the teachings of Hardouin to address dependent claims 4 and 13. For claim 13 (reading an incoming text-based message), Petitioner argued Hardouin taught suppressing incoming calls and allowing callers to leave a telephone number. Trauner explicitly taught downloading text-based messages (e.g., email) and reading them aloud via a speech synthesizer to enhance driver safety. For claim 4 (providing information on how to re-enable a suppressed function), Petitioner argued Hardouin's "reorder tone" was a basic signal. Krueger improved on this by teaching an explicit acoustic or optical notification that informs the driver to reduce speed to re-enable telephone operation.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Hardouin with Trauner to enhance driver safety by allowing drivers to receive text-based information audibly without stopping, a logical extension of Hardouin's goal. Similarly, a POSITA would combine Hardouin with Krueger to provide more effective and safer feedback to the driver than a simple reorder tone, directly aligning with the safety objectives of both references.
    • Expectation of Success (for §103 grounds): The proposed combinations involved integrating known software features (text-to-speech from Trauner, enhanced notifications from Krueger) into Hardouin's existing hardware (e.g., audio transducer), which would have been a predictable and straightforward modification.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv by noting that the trial in the related district court litigation was scheduled for February 2023, approximately 18 months after the petition's filing. Petitioner stated its intent to move to stay the litigation pending the outcome of the IPR, thereby conserving judicial and party resources.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-4, 6, 10, 12-17, 19-21, and 31 of Patent 9,047,170 as unpatentable.