PTAB

IPR2023-01172

Tesla Inc v. Autonomous Devices LLC

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1. Case Identification

2. Patent Overview

  • Title: System for Autonomous Device Operation
  • Brief Description: The ’583 patent discloses a system for enabling autonomous device operation. The technology centers on a device "learning" correlations between digital pictures of its surroundings and corresponding instruction sets, storing this knowledge, and then using it to operate autonomously when it later encounters similar visual scenes.

3. Grounds for Unpatentability

Ground 1: Claims 1-9, 11-24, 26, 28-29, and 31-34 are anticipated by Grotmol under 35 U.S.C. §102.

  • Prior Art Relied Upon: Grotmol (Patent 9,604,359).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Grotmol, which was not considered during the prosecution of the ’583 patent, discloses every element of the challenged claims. Grotmol describes a "self-contained robotic apparatus" for training and operating a robotic device to follow a trajectory.
      • Independent Claim 1: Petitioner asserted Grotmol's system meets all limitations of claim 1. Grotmol teaches a robot with a processor and memory that, during a "training" phase, receives and stores "training sets." These sets comprise digital pictures (video frames of a visual scene) depicting the device's surroundings, which are correlated with instruction sets (motor commands issued by a trainer). This process constitutes the claimed "learning" of correlated pictures and instructions. Grotmol explicitly describes this as "learning of associations between sensory context ... and a respective action ... during training." The stored training sets in Grotmol's memory component constitute the claimed "non-transitory machine readable media."
      • Independent Claims 33 & 34: Petitioner contended that because Grotmol anticipates claim 1, it also anticipates corresponding method claim 33 and means-plus-function system claim 34. The elements map directly, with Grotmol's processors and computing platform meeting the structural requirements of claim 34's "means for" limitations.
      • Dependent Claims: Petitioner mapped Grotmol to key dependent claims. For claim 4, which requires receiving a new picture and determining instructions based on a match, Grotmol's "autonomous operation" mode was cited. In this mode, the robot compares a "most recent, current" acquired image with images in the "training buffer" to find the "best matching stored image" and execute its associated motor command. For claims involving a second device (e.g., claims 13 and 26), Petitioner pointed to Grotmol's disclosure that a robot's "trained configuration may be stored" and subsequently "loaded into one or more other robots in order to provide learned behaviors."
      • AI and Knowledgebase Claims: For claims requiring an "artificial intelligence system" (claim 19) and a "knowledgebase" (claim 9 and 22), Petitioner argued Grotmol's system qualifies. Grotmol describes its training as a "learning process" using techniques like supervised learning and discloses processors configured to operate a "k-nearest neighbors learning process," which constitutes an AI system. The memory component in Grotmol that stores the correlated training sets functions as the claimed knowledgebase.
    • Key Aspects: The core of the petition is that Grotmol, filed over four years before the ’583 patent, teaches the same fundamental approach to autonomous operation but was never presented to or considered by the Examiner.

4. Key Claim Construction Positions

  • "means for receiving or generating"; "means for learning" (Claim 34): Petitioner argued these means-plus-function terms are governed by 35 U.S.C. §112, ¶ 6. Based on the ’583 patent's specification, Petitioner identified the corresponding structure for performing these functions as "one or more processor circuits." This construction allows Grotmol's disclosure of a "processing unit" and "one or more physical processors" to satisfy these claim limitations.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-9, 11-24, 26, 28-29, and 31-34 of the ’583 patent as unpatentable.