Amazon.com Inc v. LightGuide Inc

1. Case Identification

• Case #: IPR2024-00130
• Patent #: 9,658,614
• Filed: November 1, 2023
• Petitioner(s): Amazon.com, Inc. and Amazon.com Services LLC
• Patent Owner(s): LightGuide, Inc.
• Challenged Claims: 1-25

2. Patent Overview

• Title: Light Guided Assembly System and Method
• Brief Description: The ’614 patent describes a system for guiding manufacturing or assembly operations by projecting visual indicators onto a work surface or object. The system uses a sequence of input signals to dynamically control the projection of these visual indicators to guide an individual's actions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yokota - Claims 1-2, 9, and 17 are obvious over Yokota

• Prior Art Relied Upon: Yokota (Japanese Patent Publication No. 2007-087251A) and the general knowledge of a Person of Ordinary Skill in the Art (POSITA) regarding database technology, as evidenced by Kroenke (a 2009 database textbook).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Yokota, which was not before the Examiner, discloses all limitations of the independent claims. Yokota teaches a light-guided manufacturing system that uses RFID tags to identify a product, looks up corresponding component information (e.g., shape, ID, location) in a database, and projects that information onto a semi-finished product to guide assembly. Petitioner contended that the key limitation added during prosecution—"creation of a dynamic, real time projection"—is met by Yokota, which combines component shape, location, and orientation information in real time to create a "light irradiation instruction signal."
  • Motivation to Combine (for §103 grounds): The argument for combining Yokota with a POSITA's general knowledge of databases is that Yokota explicitly discloses a "database 102." A POSITA would naturally and obviously implement this database using conventional structures, such as tables with rows and columns, where each data element (a display feature) has a unique address identifier (e.g., a primary key or row/column coordinate).
  • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in applying standard database principles to implement the database disclosed in Yokota, as this involves routine and predictable design choices.

Ground 2: Obviousness over Yokota and Ramsager - Claims 10-11 and 15-16 are obvious over Yokota in view of Ramsager

• Prior Art Relied Upon: Yokota (Japanese Patent Publication No. 2007-087251A) and Ramsager (Application # 2004/01955320).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses dependent claims requiring a "confirmation signal" upon completion of a task. While Yokota teaches confirming assembly by checking weight, Petitioner argued Ramsager explicitly teaches providing a confirmation signal back to the guide system controller. Ramsager describes a system for processing packages that uses sensors (e.g., a barcode scanner) to confirm the correct selection and packing of an item, which triggers a "release task" signal to the system controller.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Yokota and Ramsager to improve the guided assembly process. Ramsager's method of using a sensor to provide a confirmation signal is a well-known technique for advancing a workflow. A POSITA would be motivated to supplement Yokota's system with Ramsager's more direct confirmation method to create a more efficient and reliable automated process.
  • Expectation of Success (for §103 grounds): Success would be expected because both references address analogous problems in the field of light-guided systems for human operators and involve similar components like RFID readers and projectors.

Ground 3: Obviousness over Yokota and Fontanot - Claims 1, 3-8, and 18-22 are obvious over Yokota in view of Fontanot

• Prior Art Relied Upon: Yokota (Japanese Patent Publication No. 2007-087251A) and Fontanot (Application # 2009/0105866).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground challenges claims requiring the input signals to be provided by a separate computer system comprising a manufacturing execution system (MES) or a programmable logic controller (PLC). Fontanot discloses a complex manufacturing environment controlled by an MES (computer system 30) that directs production stages on a shop floor.
  • Motivation to Combine (for §103 grounds): Petitioner argued a POSITA would be motivated to use Yokota's flexible, projection-guided workstation as a production stage within Fontanot's broader MES-controlled system. Yokota provides a specific solution for a flexible assembly station, making it a natural fit for Fontanot's system, which is designed to manage "a great number of different items." This would be a predictable substitution of a generic production stage with a more advanced, specific one.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success, as the combination involves integrating two systems from the same manufacturing field to achieve a more specific and efficient implementation of a known manufacturing architecture.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Yokota with Pinhanez (a 2002 IBM research report) for adding a camera to the system, and with Pinhanez and Ryznar (Patent 7,515,981) for recording and displaying task time durations.

4. Key Claim Construction Positions

• "address identifier": Petitioner proposed this term refers to an identifier, such as a lookup table coordinate (e.g., "A1"), that provides the location of a data element (e.g., a visual display feature). This construction is based on the patent's description of a spreadsheet-like table.
• "a combination of the sequence of input signals resulting in a creation of a dynamic, real time projection of visual indicators": Petitioner argued this key phrase, added during prosecution to overcome prior art, requires that the projection of visual indicators must be created dynamically and in real time in response to input signals. This is distinct from merely selecting a pre-defined projection from a list. This construction is central to arguing that references like Yokota, which combine multiple data points to generate an instruction signal, meet the limitation.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §314(a) by stipulating that, if the IPR is instituted, it will not argue at trial that any claim is invalid on any ground that was raised or reasonably could have been raised in the IPR, thereby addressing the Fintiv factors.
• Petitioner also argued against denial under §325(d), contending that the petition presents materially different prior art than what was considered during prosecution. Specifically, Petitioner asserted that the primary reference, Yokota, is materially different because it discloses the dynamic, real-time creation of visual indicators—the very feature the Examiner found lacking in the previously considered art.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-25 of the ’614 patent as unpatentable.