PTAB

IPR2023-01422

Hesai Technology Co Ltd v. Ouster Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Rotating Compact Light Ranging System Comprising A Stator Driver Circuit Imparting An Electromagnetic Force On A Rotor Assembly
  • Brief Description: The ’515 patent discloses a rotating Light Detection and Ranging (LiDAR) system. The asserted advantage is a compact design achieved by integrating motor components, such as stator and rotor elements, directly onto parallel circuit boards.

3. Grounds for Unpatentability

Ground 1: Obviousness over Pacala, Johnson, Pardhan, and Zhang - Claims 1-2, 4-9, 11, 14, 16-17, and 19 are obvious over Pacala in view of Johnson, Pardhan, and Zhang.

  • Prior Art Relied Upon: Pacala (Application # 2014/0211194), Johnson (Patent 10,790,077), Pardhan (Patent 10,749,308), and Zhang (WO 2018/201567).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pacala teaches the overall structure of a rotating LiDAR system with a base, top cover, and transparent window but does not detail its rotating mechanism. The combination supplies these details: Johnson discloses a compact "PCB motor" for LiDAR with rotor magnets and stator coils integrated onto opposing circuit boards. Pardhan teaches a support component with a sleeve fitted over a hollow shaft via bearings, allowing rotation. Zhang and other references teach modifying this support component with arms extending from the sleeve to strengthen the structure and dissipate heat, a known problem in LiDAR devices.
    • Motivation to Combine: A POSITA would combine these references to implement the general rotating LiDAR of Pacala with a known, compact, and efficient motor design. Pacala's failure to detail the rotation mechanism would motivate a POSITA to look to references like Johnson and Pardhan, which disclose rotor-stator structures for LiDAR. Pardhan's support structure would be modified with arms as taught by Zhang to address the known issues of heat dissipation and structural stability for the bearings.
    • Expectation of Success: The combination involved integrating known components for their established purposes (e.g., a PCB motor for rotation, a bearing-supported shaft for stable rotation, and arms for heat dissipation), leading to a predictable outcome.

Ground 2: Obviousness over Pacala, Johnson, Pardhan, and Zhang in view of Cai - Claims 2, 4-6, and 17 are obvious over the combination of Ground 1 in further view of Cai.

  • Prior Art Relied Upon: The combination from Ground 1, plus Cai (CN 205027903U).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the core combination of Ground 1. Cai was introduced to teach specific features for dependent claims, including a communication channel extending through a hollow shaft (claim 2) and placing wireless power transformer coils outside the outer perimeter of the stator and rotor elements (claim 17). Cai discloses mounting transceivers on circuit boards above and below a motor to provide wireless communication through a hollow shaft. It also explicitly shows transformer coils positioned on the outer perimeter of the motor.
    • Motivation to Combine: A POSITA would add Cai's teachings to improve the reliability of signal transmission, as placing transceivers at the center of rotation guarantees their position is relatively unchanged. Further, placing transformer coils on the outside of the motor elements is a straightforward design choice when central space is limited or larger coils are needed, as acknowledged by Johnson and shown by Cai.

Ground 4: Obviousness over Pacala, Johnson, Pardhan, and Zhang in view of Spector - Claims 12 and 20 are obvious over the combination of Ground 1 in further view of Spector.

  • Prior Art Relied Upon: The combination from Ground 1, plus Spector (Patent 10,473,766).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Spector to the core combination to teach the limitations of claims 12 and 20. Spector discloses a LiDAR system with detector circuitry having a plurality of pixels with non-overlapping fields-of-view. It achieves this using an aperture array that limits each detection site's visibility to a single corresponding light spot from the emitter, ensuring the illumination pattern is coincident with the pixel fields-of-view.
    • Motivation to Combine: A POSITA would incorporate Spector's techniques into Pacala's LiDAR device to solve known problems of signal noise, crosstalk, and multipath signals. Pacala itself notes the need to improve LiDAR performance without increasing susceptibility to noise, providing an express reason to apply Spector's noise-reduction techniques to the base combination.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including:

    • Substituting Pacala with Pacala-2017 (Application # 2017/0289524), an application assigned to the Patent Owner with a similar disclosure.
    • Adding Hall (Patent 11,723,762) to teach specific arrangements of transmit/receive modules.
    • Adding Droz (Patent 10,605,984) to teach that each pixel can comprise a plurality of single-photon avalanche diodes (SPADs).
    • Adding Yan (Application # 2018/0003823) to teach using alignment posts and cutouts to mount circuit boards.

4. Arguments Regarding Discretionary Denial

  • §314 (Fintiv): Petitioner argued against discretionary denial under Fintiv, stating that the parallel district court litigation was stayed at a very early stage before any responsive pleading was served, and no trial date has been set. Further, the parallel ITC investigation was terminated based on an arbitration proceeding. These facts, Petitioner contended, weigh in favor of institution.
  • §325(d): Petitioner argued that denial under §325(d) is inappropriate. Although some references were cited in an Information Disclosure Statement (IDS) during prosecution of the ’515 patent, they were among dozens of references and were never applied in a substantive rejection, giving no indication the Examiner considered them on the merits. Petitioner asserted that the Examiner's failure to apply these highly relevant references constituted a material error.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-2, 4-9, 11-14, 16-17, and 19-25 of the ’515 patent as unpatentable.