PTAB

IPR2023-01423

Amazon.com Inc v. LightGuide Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Guide System for Guiding Actions of an Individual
  • Brief Description: The ’036 patent describes a method and system for guiding an individual through an operation. The system uses a directional light device to project visual indicators onto a physical object, a camera to capture images of the individual interacting with the object and indicators, and a remote monitor to display the captured images.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kjeldsen and Pinhanez-III - Claims 1-12 are obvious over Kjeldsen in view of Pinhanez-III.

  • Prior Art Relied Upon: Kjeldsen (a 2002 article, "Interacting with Steerable Projected Displays") and Pinhanez-III (a 2004 article, "Projector-camera Systems for Telepresence").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kjeldsen disclosed nearly all limitations of independent claims 1 and 7. Kjeldsen described an IBM research prototype called the "Everywhere Displays" (ED) projector, a steerable projector-camera system. It was used in a demonstration to guide users through an augmented reality assembly task (assembling a picture from M&M's). The system projected visual indicators (e.g., highlighting a bucket of M&M's, displaying instructions) onto physical objects (the bucket, a canvas). The co-located camera was steered to follow the projection and captured images of the user's hand interacting with the physical object and the projected visual indicator. The one element Kjeldsen did not explicitly disclose was transmitting these images to a remote monitor. Petitioner contended Pinhanez-III supplied this element, as it described adapting the same ED-projector system for telepresence, expressly teaching the transmission of video from the system's camera to a remote user's display.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Kjeldsen and Pinhanez-III because both references concerned the exact same ED-projector system and were written by an overlapping team of IBM researchers. Pinhanez-III expressly suggested extending the local system of Kjeldsen to include remote capabilities for telepresence. Furthermore, a POSITA would have seen the benefit of using Pinhanez-III's remote monitoring to observe, troubleshoot, and provide real-time instruction for the M&M assembly experiment described in Kjeldsen.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying a known remote viewing technique (from Pinhanez-III) to a known, compatible system (Kjeldsen's ED-projector) to achieve the predictable result of remote monitoring.

Ground 2: Obviousness over Machino-I and Machino-II - Claims 1-12 are obvious over Machino-I in view of Machino-II.

  • Prior Art Relied Upon: Machino-I (a 2005 article, "Robot-Augmented Communication...") and Machino-II (a 2006 article, "Remote-Collaboration System using Mobile Robot...").

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that the combination of Machino-I and Machino-II taught all limitations of the challenged claims. The references described a remote collaboration system called "SCOPE," which used a co-located projector and camera to facilitate communication between an on-site worker and a remote supporter. The remote supporter sent input signals to the on-site system, causing it to project visual indicators ("meta-information" like text, images, or a mouse pointer) onto a physical object to guide the on-site worker. The system's camera captured a "shared view" that included the on-site worker, the physical object, and the projected indicators. This captured image was then transmitted over an IP network and displayed on the remote supporter's monitor, allowing the supporter to see the results of their guidance.
    • Motivation to Combine: A POSITA would combine Machino-I and Machino-II because they described the same SCOPE system, shared the same authors, were published within a year of each other, and referenced one another's work. Combining the references, which described stationary (Machino-I) and mobile (Machino-II) configurations, would have provided a more complete understanding of the system's capabilities.
    • Expectation of Success: A POSITA would have reasonably expected success in combining the teachings, as both references concerned the same underlying technology developed by the same research team, and the combination would merely implement known system configurations to yield predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Kjeldsen and Pinhanez-III with Pinhanez-I to further detail the "guide system controller" and with Pinhanez-II to teach a "separate computer system" for processing camera inputs.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv was inappropriate. A co-pending case in the Western District of Washington was in its infancy. A second co-pending case in the Eastern District of Texas, while having a trial date of July 2024, was subject to a motion to dismiss for improper venue that Petitioner expected to be granted. Petitioner contended that even if the Texas case proceeded, its early stage of discovery and distance from trial weighed in favor of institution of the inter partes review (IPR).

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-12 of the ’036 patent as unpatentable under 35 U.S.C. §103.