ABB Inc v. RoBoTicVisionTech Inc

1. Case Identification

• Case #: IPR2023-01426
• Patent #: 8,095,237
• Filed: September 22, 2023
• Petitioner(s): ABB Inc.
• Patent Owner(s): Roboticvisiontech, Inc.
• Challenged Claims: 1-10 and 12-28

2. Patent Overview

• Title: 3D Pose Estimation for Vision-Guided Robotics
• Brief Description: The ’237 patent discloses methods and apparatus for three-dimensional (3D) pose estimation using a single camera mounted on a movable robot. The technology involves camera calibration, teaching features on an object, and determining the object's 3D pose to guide robotic manipulation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Corke - Claims 1-4, 6-10, 17-20, and 24-28 are obvious over Corke in view of the knowledge of a POSITA.

• Prior Art Relied Upon: Corke (Peter I. Corke, Visual Control of Robots: High-Performance Visual Servoing, a 1996 textbook).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Corke, a foundational textbook on visual servoing, discloses all limitations of the challenged claims. Corke described a robot with a single camera mounted on its end-effector to implement 3D pose estimation. The process involved capturing a 2D image of a target, locating features within that single image, and using a processor to determine the object space-to-camera space transformation. This determination was based on an algorithm that used the position of the located features in conjunction with a known geometric model of the target. For apparatus claims 20 and 25, Corke was argued to disclose a computer vision system with a single camera and a processor programmed to perform the same calibration and pose estimation steps.
  • Motivation to Combine (for §103 grounds): This ground asserted that Corke alone, or as understood by a person of ordinary skill in the art (POSITA), rendered the claims obvious. Petitioner contended that implementing the methods described in Corke would inherently result in the claimed invention, as Corke provided a complete blueprint for a single-camera, vision-guided robotic system.
  • Expectation of Success: As Corke detailed established techniques and functional systems for visual servoing, a POSITA would have had a high expectation of success in applying its teachings to achieve the claimed methods and apparatus.

Ground 2: Obviousness over Corke and Wei-I - Claims 5, 12-16, and 21-24 are obvious over Corke in view of Wei-I.

• Prior Art Relied Upon: Corke (as in Ground 1) and Wei-I (Guo-Qing Wei, et al., “Active Self-calibration of Robotic Eyes and Hand-eye Relationships with Model Identification,” a 1998 journal article).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed claims requiring calibration using a "teaching object," defined as a sample of an object type the robot will manipulate, rather than a dedicated calibration target. Petitioner argued that Corke taught the foundational system, while Wei-I supplied the specific teaching of self-calibration using such an object. Wei-I described an autonomous self-calibration method for a robotic hand camera that tracked features on an "Orbital Replacement Unit" (ORU)—an object the robot was designed to grasp—to determine intrinsic, extrinsic, and hand-eye parameters without a separate calibration plate.
  • Motivation to Combine: Petitioner argued a POSITA would combine Wei-I's advantageous self-calibration method with Corke's foundational visual servoing system. The motivation was to improve Corke's system by replacing its requirement for a "mechanically complex calibration frame" with Wei-I's more streamlined and efficient technique of using the actual workpiece as the calibration object. This combination represented the application of a known, advantageous technique (from Wei-I) to a known, similar system (from Corke) to achieve a predictable improvement.
  • Expectation of Success: Both references operated in the same technical field of vision-guided robotics and addressed compatible problems of camera calibration and pose estimation. Therefore, a POSITA would have reasonably expected that Wei-I’s self-calibration techniques would function successfully within the framework of Corke's system.

4. Key Claim Construction Positions

• Petitioner argued that the terms "means for calibrating the camera" (claims 20, 28) and "means for estimating a pose of a target object" (claims 20, 28) are not means-plus-function limitations subject to 35 U.S.C. §112(6).
• The argument was that the claims themselves recite sufficient structure—in the form of the specific algorithmic steps for determining intrinsic/extrinsic parameters and for capturing images and determining transformations—to perform the recited functions, obviating the need for construction under §112(6).

5. Arguments Regarding Discretionary Denial

• §314 (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation was in its initial stages with minimal investment and a trial date scheduled for after the statutory deadline for a Final Written Decision in the inter partes review (IPR). Petitioner contended these factors weighed strongly against denial.
• §325(d): Petitioner argued that denial under §325(d) was unwarranted because the primary prior art references, Corke and Wei-I, were not applied by the Examiner during prosecution. The Patent Owner overcame a rejection over a different reference (Wei-II) by arguing it used a "stereo pair of cameras," whereas the invention used a "single camera." Petitioner emphasized that the current petition’s primary reference, Corke, explicitly teaches a single-camera system, thereby presenting a new and more pertinent invalidity challenge that was not previously considered.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-10 and 12-28 of the ’237 patent as unpatentable.