Tesla Inc v. iQar Inc

1. Case Identification

• Case #: IPR2024-00541
• Patent #: 7,925,426
• Filed: February 5, 2024
• Petitioner(s): Tesla, Inc.
• Challenged Claims: 1-4

2. Patent Overview

• Title: Power Management Systems and Devices
• Brief Description: The ’426 patent discloses a method for managing a vehicle’s power consumption. The method involves a computer receiving a route, segmenting it, and for each segment, calculating an "optimized speed" to minimize power use, calculating a "probable speed," determining a final "efficient speed" based on the two, and applying the corresponding power to the engine.

3. Grounds for Unpatentability

Ground 1: Claims 1-2 are obvious over Neiss in view of Ran

• Prior Art Relied Upon: Neiss (Application # 2004/0068359) and Ran (Patent 6,317,686).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Neiss disclosed a predictive cruise control system that met most limitations of claim 1. Neiss’s system calculates an optimized speed over route segments (called “frames”) by minimizing a cost function that includes fuel consumption. However, Neiss’s system adapts its optimization based on the vehicle’s “current velocity,” which is a poor proxy for conditions in upcoming segments. Petitioner asserted that Ran supplied the missing element by teaching a system that predicts travel speeds for a route using real-time traffic data, historical data, and traffic prediction models. This predicted speed, according to Petitioner, corresponded to the claimed “probable speed.”
  • Motivation to Combine: A POSITA would combine Ran’s traffic-based speed prediction with Neiss’s optimization framework to improve its accuracy and realism. Neiss already sought to adapt to real-time conditions, and Ran provided a known and superior method for doing so. Substituting Ran’s predicted speed for Neiss’s use of “current velocity” would yield a more effective and reliable power management system, which was a predictable improvement.
  • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because both references related to computer-implemented vehicle speed calculation. Integrating Ran’s predicted speed as an input into Neiss’s existing optimization algorithm would have been a straightforward modification.

Ground 2: Claim 3 is obvious over Neiss in view of Ran and Andersson

• Prior Art Relied Upon: Neiss (Application # 2004/0068359), Ran (Patent 6,317,686), and Andersson (Patent 6,836,719).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Neiss-Ran combination to address dependent claim 3, which added the limitation of “determining a historical speed for a similar destination.” While the base combination (specifically Ran) taught using historical speed data for a given route, Andersson taught a method for predicting a driver’s speed on a new road section by analyzing historical data from similar road sections (e.g., those with similar curvature or road type).
  • Motivation to Combine: A POSITA would augment the Neiss-Ran combination with Andersson’s teachings to make the “probable speed” calculation more robust and accurate, particularly when historical data for the exact upcoming route segment was unavailable. This would allow the system to leverage a wider pool of historical data, improving its predictive capabilities for routes the vehicle had never traveled before.
  • Expectation of Success: Petitioner argued success would be expected, as combining different data sources (real-time traffic, direct historical data, and similar-route historical data) using known techniques like weighted averaging was common in the art to create more accurate speed predictions.

Ground 3: Claim 4 is obvious over Neiss in view of Ran and Hosoda

• Prior Art Relied Upon: Neiss (Application # 2004/0068359), Ran (Patent 6,317,686), and Hosoda (Japanese Patent Pub. No. 11220807).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed dependent claim 4, which added “notifying the operator of the vehicle of the calculated applied power.” The base Neiss-Ran system already calculated the applied power (disclosed in Neiss as throttle position values corresponding to the optimized speed). Hosoda taught a system for displaying various types of vehicle operational data, including throttle opening and fuel efficiency information, to the operator on an in-vehicle display.
  • Motivation to Combine: A POSITA would combine these teachings to provide the vehicle operator with useful feedback. As taught by Hosoda, displaying the calculated applied power would enable the operator to “easily understand a change in fuel efficiency” and be aware of the system’s performance. This represented the simple application of a known display technique to the known Neiss-Ran system to gain a predictable benefit.
  • Expectation of Success: Petitioner asserted success was highly likely, given that in-vehicle displays for notifying operators of vehicle parameters were conventional and well-known. Integrating Hosoda’s display concept to show an output already generated by the Neiss-Ran system would be a simple and routine design choice.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv would be inappropriate. The parallel district court litigation was in a very early stage, with discovery stayed and no trial date set. The Final Written Decision (FWD) in the inter partes review (IPR) would therefore likely issue long before a potential trial. Petitioner further contended that there was no overlap between the petition’s grounds and any invalidity contentions in the litigation, as none had been served. Finally, Petitioner asserted the petition presented compelling merits based on prior art not previously considered by the USPTO, weighing strongly in favor of institution.

5. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1-4 of the ’426 patent as unpatentable.