PTAB

IPR2023-01169

Tesla Inc v. Autonomous Devices LLC

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1. Case Identification

2. Patent Overview

  • Title: Learning an Avatar's Circumstances, Correlated Instruction Sets, and/or Autonomous Operation
  • Brief Description: The ’134 patent discloses systems and methods for autonomously operating an avatar within an application (e.g., a video game). The technology involves correlating "object representations" (e.g., the state or environment of an avatar) with corresponding instruction sets, storing these correlations, and later executing an instruction set when a newly generated object representation at least partially matches a stored one.

3. Grounds for Unpatentability

Ground 1: Anticipation and Obviousness over Thomas - Claims 1-20 are anticipated by or obvious over Thomas.

  • 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 program, like a video game. It operates in two modes: a "learn mode" and a "simulation mode." In learn mode, Thomas’s system records a user's inputs (the claimed "instruction sets") and associates them with the specific game situation or event that prompted them (the claimed "first object representations," such as the spatial position of other avatars). This creates the claimed "first correlation," which is stored in a database. In simulation mode, the system monitors the game for new situations (the "second object representations"), compares them to the stored situations, and upon finding a match, automatically invokes the corresponding recorded user input to control an avatar. This process, Petitioner contended, directly maps to the core method of independent claims 1, 10, and 19.
    • Motivation to Combine (for §103 grounds): For claims challenged as obvious (3, 5, 12-14), Petitioner argued a Person of Ordinary Skill in the Art (POSITA) would have found it obvious to make minor modifications based on Thomas’s teachings. For claim 5, which requires a second avatar to perform operations defined for a first avatar, Thomas teaches classifying players by archetype (e.g., "shooter"). A POSITA would find it obvious to apply a learned or default instruction set from one "shooter" avatar to another "shooter" avatar on the same team, especially in situations where no specific data exists for the second avatar.
    • Expectation of Success: The application of known gaming concepts, such as applying player archetypes or using default actions, would have been straightforward with a high expectation of success.

Ground 2: Anticipation over Buehler - Claims 1, 3, and 17 are anticipated by Buehler.

  • Prior Art Relied Upon: Buehler (Patent 9,434,072).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Buehler, which discloses a system for robot learning and training, anticipates the claims by teaching the same core functionality in a different technical context. Buehler’s system stores "template images" of objects (the "first object representations") correlated with specific "manipulation routines" (the "instruction sets") for a robot. The robot uses a camera to capture real-time images of its environment (the "second object representations"). The system compares these new images to the stored templates to find a match. Upon finding a match, it determines the appropriate instruction set and can execute it by causing a virtual representation of the robot (the "first avatar") to simulate an action, such as overlaying virtual grippers on the image to show how it would grasp the object. This system of matching a current visual state to a stored state to trigger a stored routine was argued to meet all limitations of independent claim 1.
    • Motivation to Combine (for §103 grounds): Not applicable for this anticipation ground.
    • Expectation of Success: Not applicable for this anticipation ground.

4. Key Claim Construction Positions

  • "means for generating or receiving..."; "means for determining..."; "means for executing..." [Claim 19]: Petitioner addressed the means-plus-function limitations of claim 19. Petitioner argued that the specification of the ’134 patent explicitly identifies the corresponding structure for performing these functions as "one or more processor circuits or processors." This construction is supported by the description of the system's overall architecture and is confirmed by dependent claim 20, which recites that the "means" include one or more processors. This construction is critical because it allows the functions to be mapped to the general-purpose processors disclosed in the Thomas and Buehler prior art references.

5. Relief Requested

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