Tesla Inc v. iQar Inc

1. Case Identification

• Case #: IPR2024-00499
• Patent #: 10,829,002
• Filed: January 25, 2024
• Petitioner(s): Tesla, Inc.
• Challenged Claims: 1-17

2. Patent Overview

• Title: VEHICLE DESTINATION PREDICTION
• Brief Description: The ’002 patent discloses a system and method for predicting a vehicle's destination. The system uses a processor to analyze sensor data samples stored in a memory to detect a pattern, and then predicts a destination based on that pattern and historical data associated with the vehicle's operation.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Kudo-325 and Kudo-066 - Claims 1-16 are obvious over Kudo-325 in view of Kudo-066.

• Prior Art Relied Upon: Kudo-325 (Application # 2005/0251325) and Kudo-066 (Application # 2004/0128066).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Kudo-325 teaches the core functionality of the challenged claims, including a vehicle navigation system that predicts destinations using travel history and current trip conditions. Specifically, Kudo-325’s "position detection section" acts as a sensor interface receiving sensor data, and its "history accumulation DB" serves as the claimed memory. Petitioner asserted that Kudo-325’s processor analyzes stored data (e.g., current position, time/date) to determine conditions like "weekday" or "afternoon" (detect a pattern) and uses these conditions along with stored travel histories (historical data) to predict a destination. Kudo-066, a related application from the same inventors, was argued to supply missing implementation details, teaching the use of GPS for position detection, which constitutes telemetry data, and using a remote server for its map database. The combined teachings were alleged to disclose every limitation of the independent claims.
  • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine the general system of Kudo-325 with the specific implementations of the highly similar Kudo-066 system. The motivation stemmed from the predictable benefits of improving the system, such as using Kudo-066's server-based map database to ensure map accuracy and reduce in-vehicle hardware costs, and incorporating its use of GPS for reliable and accurate position detection.
  • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved applying known techniques (GPS position detection, server-based databases) to a known system (vehicle destination prediction) to achieve predictable results and well-understood advantages.

Ground 1B: Obviousness over Kudo-325, Kudo-066, and Bolger - Claim 3 is obvious over Kudo-325 and Kudo-066 in view of Bolger.

• Prior Art Relied Upon: Kudo-325 (Application # 2005/0251325), Kudo-066 (Application # 2004/0128066), and Bolger (Patent 5,471,393).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground focused on claim 3, which requires that telemetry data comprises "map coordinates determined by a map service." Petitioner argued that while the primary combination disclosed map coordinates, Bolger explicitly taught a system that functions as a "map service." Bolger described using dead-reckoning techniques and reconciling the resulting coordinates with a "road map database" to produce normalized, more accurate map coordinates. Petitioner asserted that this process of using a map database to determine refined coordinates meets the "map service" limitation.
  • Motivation to Combine: A POSITA would have been motivated to incorporate Bolger's technique into the Kudo-325/Kudo-066 system to improve the accuracy and reliability of vehicle position detection. Bolger offered a known solution to the common problem of GPS unavailability or inaccuracy in navigation systems, making its integration a logical and obvious improvement.
  • Expectation of Success: Success was expected because the combination involved integrating a well-known position-determination method into an existing navigation system architecture, a common practice in the field to enhance system robustness.

Ground 1C: Obviousness over Kudo-325, Kudo-066, and Tryon - Claim 17 is obvious over Kudo-325 and Kudo-066 in view of Tryon.

• Prior Art Relied Upon: Kudo-325 (Application # 2005/0251325), Kudo-066 (Application # 2004/0128066), and Tryon (Application # 2005/0228553).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed claim 17, which adds a device configured to "adapt an operation of said vehicle based on said predicted destination." Petitioner argued that the Kudo-325/Kudo-066 combination provides the predicted destination. Tryon, in turn, disclosed an energy management system for a hybrid vehicle that explicitly uses a predicted destination to control and adapt vehicle operations. For example, Tryon's system determines if the vehicle's current stored energy is sufficient to reach the predicted destination and, based on that determination, adapts vehicle operation by either continuing on stored energy or starting a power generator to optimize fuel consumption.
  • Motivation to Combine: A POSITA would combine these references to improve vehicle efficiency. Using the predicted destination output from the Kudo system as an input to Tryon's energy management controller was a known technique to improve a similar system. This would allow the vehicle to make smarter, forward-looking energy decisions, leading to improved fuel efficiency and overall performance.
  • Expectation of Success: A high expectation of success was argued because Tryon’s control system is agnostic to the specific method used to predict the destination. Applying the output of the Kudo prediction system to the input of the Tryon control system represented a straightforward and predictable engineering design choice.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is inappropriate because none of the prior art references or arguments presented in the petition were previously considered by the USPTO during the original prosecution of the ’002 patent.
• Petitioner also contended that discretionary denial under Fintiv is unwarranted. The petition was filed early in the parallel district court proceeding, where no trial date has been set and discovery is in its initial stages. Petitioner argued that an IPR would resolve invalidity issues more efficiently than the district court. Furthermore, Petitioner asserted that the petition presents compelling evidence of unpatentability, which weighs strongly in favor of institution to serve overall system efficiency and integrity.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-17 of Patent 10,829,002 as unpatentable.