PTAB

IPR2023-01026

Mercedes Benz USA LLC v. Spero Yechezkal

Title: Vehicle Headlight System
Brief Description: The ’503 patent relates to a vehicle headlight system that uses a plurality of light clusters (e.g., LEDs), sensors to gather data about the vehicle’s field-of-view, and a processor. The processor uses the sensor data, such as the detection of an oncoming vehicle, to selectively control the light clusters to reduce illumination in specific sub-sections to prevent glare while maintaining full illumination elsewhere.

Prior Art Relied Upon: Alden (Application # 2003/0137849).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Alden discloses all limitations of the independent claims. Alden teaches an adaptive headlight system with a plurality of individually controllable LEDs arranged on a curved structure within a headlamp. The system includes a sensor unit with a CPU to detect oncoming vehicles and, in response, adjusts individual LEDs to create a low beam in the sector of the detected vehicle while concurrently maintaining a high beam in other sectors. This processor-controlled, selective illumination based on sensor data was argued to directly map to the core features of independent claims 1, 20, and 26 of the ’503 patent.

Prior Art Relied Upon: Alden (Application # 2003/0137849) and Harbers (WO 2001/001038A1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that while Alden provides the foundational system, it does not explicitly teach controlling the spectral characteristics (color) of the light. Harbers, in the same field, taught an adaptive LED headlamp system that uses different colored LEDs to create distinct spectral properties in different beam segments (e.g., blue-green light for peripheral areas, yellow-orange light for on-axis areas) to enhance driver visibility, particularly for objects on the side of the road.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Harbers’ use of colored LEDs with Alden’s system to gain the known benefit of improved driver visibility. The combination represented a simple substitution of colored LEDs for white LEDs in a similar system to achieve a predictable improvement.
- Expectation of Success: A POSITA would have a high expectation of success, as both references describe similar adaptive lighting systems, and incorporating color control is a known technique for enhancing visibility in vehicle headlamps.

Prior Art Relied Upon: Alden (Application # 2003/0137849) and Beam (Patent 6,144,158).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Alden’s disclosure focused on detecting oncoming vehicles. Beam taught a nearly identical adaptive headlight system but explicitly disclosed detecting the taillights of preceding vehicles to reduce glare reflected in a rear-view mirror.
- Motivation to Combine: A POSITA would be motivated to modify Alden's system to also detect preceding vehicles, as taught by Beam, to create a more comprehensive anti-glare solution, which is the core purpose of both inventions. This would address glare from both oncoming and preceding traffic.
- Expectation of Success: Success would be expected, as Alden’s existing sensor and control logic could be adapted to detect taillights in the same manner it detects headlights, without requiring significant changes or undue experimentation.

Prior Art Relied Upon: Alden (Application # 2003/0137849) and Kobayashi (Patent 6,049,749).
Core Argument for this Ground:
- Prior Art Mapping: Alden taught using sensors to detect road reflectors or steering wheel angle to anticipate turns and adjust lighting. Kobayashi taught using a GPS sensor to obtain road profile data and control headlight irradiation for upcoming curves.
- Motivation to Combine: A POSITA would combine Kobayashi’s GPS sensor with Alden’s system to create a more robust and reliable method for detecting road curvature. This would be particularly useful in environments where road reflectors are absent or unreliable, providing a complementary and superior method for predictive lighting.
- Expectation of Success: A POSITA would expect success because Alden’s processor was already designed to synthesize various sensor data to control lighting. Adding a GPS data feed is a well-known technique in vehicle control systems.
Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 6 based on Alden in view of Bergkvist (Patent 4,970,628), which taught including an ultraviolet (UV) light source to illuminate roadside objects without distracting other drivers.

Petitioner argued against discretionary denial under §314(a) based on Fintiv factors, stating that the parallel district court cases are in their infancy. It was noted that there is no case schedule, no discovery has occurred, and the cases are indefinitely stayed pending resolution of other issues, making it speculative that a court would ever address the invalidity challenges raised in the petition.
Petitioner also argued against denial under §325(d), asserting that the primary prior art reference, Alden, was never considered by the Examiner during prosecution. It was further argued that the grounds presented are not cumulative of other pending IPR proceedings against the ’503 patent, which do not rely on Alden or the specific combinations asserted herein.

Petitioner requests institution of an inter partes review and cancellation of claims 1-36 of Patent 10,894,503 as unpatentable.