Tesla Inc v. AuTonomous DevIces LLC

1. Case Identification

• Patent #: 11,055,583
• Filed: June 30, 2023
• Petitioner(s): Tesla, Inc.
• Patent Owner(s): Autonomous Devices, LLC
• Challenged Claims: 1-9, 11-24, 26, 28-29, and 31-34

2. Patent Overview

• Title: System for Autonomous Device Operation via Learned Visual Correlations
• Brief Description: The ’583 patent relates to systems for autonomous device operation. The core technology involves a system that captures digital pictures of a device's surroundings, receives corresponding instruction sets, and "learns" the correlations between them. This learned knowledge is stored and used to operate the device autonomously when it later encounters similar visual scenes.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-9, 11-24, 26, 28-29, and 31-34 by Grotmol

• 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 prosecution, discloses every element of the challenged claims. Grotmol describes an apparatus and methods for training and operating a robotic device. The system functions by first operating in a "listen mode" or training mode where it observes a trainer's commands (instruction sets) and associates them with images captured by its camera (digital pictures). The robot stores these correlated image-command pairs in a "training buffer." Subsequently, in "autonomous mode," the robot compares new, currently observed images with the stored images in the buffer. Upon finding a "best matching stored image," it retrieves the associated command and executes it, thereby navigating autonomously. Petitioner contended this process directly maps to the limitations of the challenged claims.
  • Independent Claim 1: Petitioner asserted Grotmol's "self-contained robotic apparatus" meets the "system" limitation, which includes a "processing unit" and "memory unit" that satisfy the processor and non-transitory media limitations. The central "learning" element of claim 1 was argued to be disclosed by Grotmol's description of creating and storing "training sets," where camera images are correlated with motor commands. Grotmol explicitly describes this as "learning of associations between sensory context ... and a respective action ... during training."
  • Independent Claim 4: Petitioner argued that Grotmol’s "autonomous mode" discloses the limitations of claim 4. During this mode, the robot receives a "new" digital picture (the current camera view), determines an instruction set by finding a "partial match" (the "best matching stored image" from the training buffer), and, in response, causes the device to perform the operation defined by that instruction set (executing the motor command).
  • Method and Means-Plus-Function Claims: Petitioner asserted that because Grotmol anticipates system claims 1 and 4, it inherently anticipates the corresponding method claim 33 and the means-plus-function system claim 34. The arguments for these claims mirrored those for claim 1, relying on the functionality performed by Grotmol's processor-based system.
  • Key Dependent Claims: Petitioner detailed how Grotmol allegedly meets numerous dependent claim limitations. This included the use of a camera as a "picture capturing apparatus" (claim 2); storing the learned correlations in a "knowledgebase" (Grotmol's memory buffer) for multiple tasks (claim 9); and transferring a "trained configuration" from a first robot to be "loaded into one or more other robots" to provide learned behaviors (claims 13 and 26). Further, Grotmol was said to disclose modifying instruction sets to compensate for "position mismatch" (claim 15) and using an artificial intelligence system, such as a "random k-nearest neighbors learning process," to perform the learning and determining steps (claim 19).

4. Key Claim Construction Positions

• Petitioner argued that the terms "means for receiving or generating" and "means for learning" in independent claim 34 are means-plus-function limitations governed by 35 U.S.C. § 112, paragraph 6.
• Based on its review of the ’583 patent's specification, Petitioner asserted that the corresponding structure disclosed for performing these functions is "one or more processor circuits." This construction was central to Petitioner's argument, as it allowed the processor-based architecture of Grotmol, which performs these same functions, to be directly mapped to the limitations of claim 34.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and cancellation of claims 1-9, 11-24, 26, 28-29, and 31-34 of the ’583 patent as unpatentable under 35 U.S.C. §102.