Amazon.com Inc v. LightGuide Inc

1. Case Identification

• Case #: IPR2024-00141
• Patent #: 7,515,981
• Filed: November 4, 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
• Brief Description: The ’981 patent discloses an operational guide system for manufacturing that uses projected light to provide visual instructions to an operator for sequential assembly tasks. The system incorporates a sensor apparatus to detect "operation information" at a workstation and a controller that processes this information to selectively project the next set of light-based instructions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Poggi-SIMATIC - Claims 1-2, 4-7, 11-17, 19-21, 23, and 25 are obvious over Poggi in view of SIMATIC.

• Prior Art Relied Upon: Poggi (European Application # 0,470,901) and SIMATIC (a Siemens product manual).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Poggi, which was not considered during prosecution, discloses the core elements of the ’981 patent’s system. Poggi teaches an operational guide system with projectors (directional light devices), a computer (controller), and camera sensors to guide the manual lay-up of composite materials. The system projects images to show where to place successive layers and uses its cameras to verify correct placement. To meet the claim limitation of a sensor apparatus generating an output indicative of operation information, Petitioner combined Poggi with SIMATIC, an off-the-shelf machine vision sensor manual. SIMATIC describes cameras with built-in processing that can detect part presence/absence, identify part type, and generate output signals (e.g., PASS/FAIL) based on this detection. Petitioner asserted that substituting the SIMATIC camera for Poggi’s sensor would render the claimed sensor limitations obvious.
  • Motivation to Combine: A POSITA would combine the references by substituting the SIMATIC vision sensor into Poggi's system. This is a simple substitution of one known component for another to perform the same function. The motivation would be to use a commercially available, integrated device (SIMATIC) with built-in image processing capabilities to save the time, effort, and expense associated with implementing the image evaluation functions on Poggi’s separate computer.
  • Expectation of Success: A POSITA would have had a high expectation of success because the SIMATIC camera provides the same or better functionality (image capture and analysis) as required by the Poggi system. The combination involves reassigning a known processing task from a general-purpose computer to a specialized camera sensor, a predictable design choice with a finite number of variations.

Ground 2: Anticipation by Green - Claims 1-2, 4-6, 8, and 11-12 are anticipated by Green.

• Prior Art Relied Upon: Green (Application # 2007/0236354).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Green, a Boeing reference also not cited during prosecution, discloses every element of the challenged claims. Green describes a "ply layup orientation detection system" that guides an operator in assembling composite parts. It uses a laser projector (a directional light device) to project an outline (a visual indicator) for sequential ply placement. The system includes tag sensors that detect electronically identifiable tags on each ply to determine its presence, identity, and position (operation information). A computer system (controller) receives this sensor data (an input signal), and if the ply is correctly placed, it selectively provides a command signal to the projector to display the outline for the next ply. This process directly maps to the system and methods of the independent claims.

Ground 3: Obviousness over Poggi-SIMATIC in view of Kaufman - Claims 9-10, 18, 22, and 24 are obvious over Poggi-SIMATIC in view of Kaufman.

• Prior Art Relied Upon: Poggi (European Application # 0,470,901), SIMATIC (a Siemens product manual), and Kaufman (Patent 6,547,397).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on the Poggi-SIMATIC combination to address dependent claims requiring a programmable controller with a display screen and specific input fields. While Poggi-SIMATIC provides the base operational system, Kaufman teaches a light-guided assembly system with an "Administrator program." This program provides a graphical user interface with program screens and input fields (e.g., description, graphic, and location fields) for entering and editing parts information, including the layers that define a projected pattern.
  • Motivation to Combine: A POSITA would be motivated to incorporate Kaufman’s administrator interface into the Poggi-SIMATIC system to improve the programmability and control over the assembly process. Adding a user interface to control a computer-based manufacturing system was a well-known design incentive to increase functionality and efficiency.
  • Expectation of Success: The combination would yield predictable results, as it involves integrating a known user interface (Kaufman) with a known light-guided assembly system (Poggi-SIMATIC) to add a known function (programmability).
• Additional Grounds: Petitioner asserted additional obviousness challenges based on Poggi-SIMATIC in view of Pinhanez, and Green in view of Kaufman or Pinhanez, relying on similar motivations to add specific features like component highlighting and user input capabilities.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial is inappropriate. To address Fintiv factors, Petitioner stipulated that if the IPR is instituted, it will not argue at trial that any claim is invalid on any ground that it raised or reasonably could have raised in the IPR. Petitioner also argued that denial under §325(d) is unwarranted because the petition relies on prior art references (Poggi, Green, Kaufman, etc.) that are materially different from the art considered during the original prosecution and were never before the Examiner.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of the ’981 patent as unpatentable.