PTAB

IPR2023-01169

Tesla Inc v. AuTonomous DevIces LLC

Log In

1. Case Identification

2. Patent Overview

  • Title: System and Method for Operating an Avatar
  • Brief Description: The ’134 patent describes a system for autonomously operating an avatar in an application (e.g., a video game). The system learns correlations between object representations (game situations) and instruction sets (user actions), and then uses this knowledge to operate an avatar when similar situations are encountered.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are anticipated by Thomas under 35 U.S.C. §102.

  • Prior Art Relied Upon: Thomas (Patent 8,142,268).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thomas discloses every limitation of the challenged claims. Thomas describes a system for simulating a user's behavior in an interactive computer system, such as a video game. The system operates in two primary modes: a "learning mode" and a "simulation mode."
    • In the learning mode, Thomas’s system records a user's inputs (the "instruction set") in response to specific game events or situations (the "first one or more object representations"). For example, it records the user's controller inputs when their basketball avatar is covered by a certain number of defensive players. This creates a stored correlation between a situation and a responsive action.
    • In the simulation mode, the system monitors the game for new events or situations (the "second one or more object representations"). It compares these new situations to the stored situations from the learning mode. When a match is found, Thomas’s system automatically invokes the corresponding stored user input ("determines the first one or more instruction sets") to operate an avatar autonomously ("executing the first one or more instruction sets").
    • Petitioner asserted that this process directly maps to the core steps of independent claims 1, 10, and 19. For dependent claims, Petitioner argued Thomas discloses the required features, such as using a "database" or "user's profile" which functions as the claimed "knowledgebase" (claims 4, 9, 11), using numerical thresholds to determine when criteria for a match are met (claim 3), and applying learned behaviors to a second avatar of the same archetype (claim 5).

Ground 2: Claims 1, 3, and 17 are anticipated by Buehler under 35 U.S.C. §102.

  • Prior Art Relied Upon: Buehler (Patent 9,434,072).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Buehler, which describes a system for robot learning and training, anticipates the key claims. Buehler’s system uses a memory to store "template images" of objects (the "first one or more object representations") correlated with specific "manipulation routines" or instructions for handling those objects (the "first one or more instruction sets"). The robot and its end-effector, when simulated, act as the claimed "avatar."
    • The system generates or receives new object representations by capturing real-time images of its environment with a camera. It then compares these new images to the stored template images to find a match based on a "similarity metric" (an "at least partial match").
    • Upon finding a match, the system determines the appropriate manipulation routine and executes it. This includes causing a virtual representation of the robot’s end-effector (the "first avatar") to perform the defined operations in a simulation. For example, it overlays virtual grippers on an image to show how it would pick up an object.
    • Petitioner argued this framework anticipates all limitations of independent claim 1. For dependent claims, Petitioner asserted Buehler discloses using a "threshold" metric to assess a match (claim 3) and modifying the stored instruction routines during a training mode where a user can provide feedback, which is then executed by the system (claim 17).

  • Additional Grounds: Petitioner asserted an alternative ground that claims 3, 5, and 12-14 are obvious over Thomas. This argument relied on the same core disclosures from Thomas, arguing that a person of ordinary skill in the art (POSITA) would have found it obvious to implement features like using numerical thresholds for matching or applying learned behaviors to different avatars of the same archetype.

4. Key Claim Construction Positions

  • Petitioner addressed the means-plus-function terms in claim 19, which recites a "means for generating or receiving," a "means for determining," and a "means for executing."
  • Petitioner argued that based on the ’134 patent’s specification and the language of claim 1, the corresponding structure for performing all three of these functions is "one or more processor circuits or processors." This construction is central to the argument that Thomas and Buehler, which disclose processor-based systems performing these exact functions, anticipate claim 19.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of the ’134 patent as unpatentable.