Tesla Inc v. iQar Inc

1. Case Identification

• Case #: IPR2024-00543
• Patent #: 10,882,399
• Filed: February 2, 2024
• Petitioner(s): Tesla, Inc.
• Patent Owner(s): iQar Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Electric Vehicle Power Management System
• Brief Description: The ’399 patent discloses devices, methods, and systems for controlling power applied to a vehicle engine. The technology focuses on calculating and applying electric power to optimize vehicle operation based on various inputs, including environmental conditions, operational status, and user commands, to achieve criteria such as optimal speed or travel time.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 5, 6, 9-12, 15, 16, 19, and 20 are obvious over Hongo, Obradovich, and Niki.

• Prior Art Relied Upon: Hongo (Japanese Publication # JP 2003-276472), Obradovich (Patent 6,282,464), and Niki (Patent 7,059,435).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references taught all limitations of the challenged claims. Hongo disclosed the core functionality: an adaptive cruise control system that determines a target vehicle speed (and thus applied power) based on external road conditions, operational status (vehicle speed), and information from external sources (e.g., radio traffic data). Obradovich, which taught a multimedia control system, supplied the claimed user interface features, specifically disclosing the use of voice commands and a touch screen to control vehicle functions, including cruise control. Niki provided the context for applying this technology to a hybrid vehicle, which Petitioner asserted is an example of an electric vehicle as claimed, disclosing a control apparatus for a hybrid vehicle driven by an internal combustion engine and an electric motor.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hongo and Obradovich to improve the user experience and safety of Hongo's adaptive cruise control by integrating Obradovich's well-known, user-friendly voice and touch interfaces. This improved system would then be predictably implemented in a hybrid vehicle like that taught by Niki, as it represented a known and suitable platform for such advanced cruise control systems.
  • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success, as the combination involved integrating known user interface technologies with a known type of cruise control system in a conventional hybrid vehicle architecture, representing a predictable application of existing technologies.

Ground 2: Claims 3, 4, 13, and 14 are obvious over Hongo, Obradovich, and Niki in view of Kudo.

• Prior Art Relied Upon: Hongo (JP 2003-276472), Obradovich (Patent 6,282,464), Niki (Patent 7,059,435), and Kudo (Application # 2005/0251325).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Kudo to the base combination from Ground 1 to teach the limitations of selecting a destination using historical data or statistical logic. Kudo disclosed a navigation technology for predicting a vehicle's travel destination by accumulating a travel history (historical data associated with a driver) and using factors like time, date, and weather to infer likely destinations using prediction probabilities (statistical destination logic).
  • Motivation to Combine: A POSITA, seeking to improve the navigation capabilities provided by Obradovich in the primary combination, would be motivated to incorporate Kudo's destination prediction technology. This addition would enhance user convenience by automating destination selection, addressing the recognized problem of drivers finding it arduous to manually input destination information.
  • Expectation of Success: Success would be expected because Kudo's technology was a known vehicle navigation technique. Integrating this predictive feature into a system already equipped with navigation (from Obradovich) and adaptive cruise control (from Hongo) would be a predictable improvement.

Ground 3: Claims 7 and 17 are obvious over Hongo, Obradovich, and Niki in view of Kuroda.

• Prior Art Relied Upon: Hongo (JP 2003-276472), Obradovich (Patent 6,282,464), Niki (Patent 7,059,435), and Kuroda (Patent 6,314,347).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Kuroda to the base combination to teach communicating with a remote database. While Hongo suggested receiving traffic information from a "radio," it lacked implementation details. Kuroda disclosed a specific implementation: a Vehicle Information Communication System (VICS) that receives traffic and road information from a beacon receiver and a remote road map database. This directly taught the claimed step of communicating with a remote database to determine external environment information.
  • Motivation to Combine: A POSITA implementing Hongo's system would look to conventional technologies to realize its general teaching of receiving traffic information. Kuroda's VICS provided a well-known and specific solution, and its integration would improve the functionality and accuracy of Hongo's adaptive cruise control calculations by providing more detailed, real-time data.
  • Expectation of Success: A POSITA would have reasonably expected to succeed, as this involved using a known communication system (Kuroda's VICS) to implement a feature (receiving traffic data) already contemplated by the primary reference (Hongo).

Ground 4: Claims 8 and 18 are obvious over Hongo, Obradovich, and Niki in view of Newstrom.

• Prior Art Relied Upon: Hongo (JP 2003-276472), Obradovich (Patent 6,282,464), Niki (Patent 7,059,435), and Newstrom (Patent 7,552,008).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Newstrom to teach communicating with a remote database for determining a vehicle's operational status. Newstrom disclosed a system that used a remote geospatial database containing lane boundary information to monitor for and warn of lane departures. Petitioner argued that determining lane departure information (based on vehicle speed, position, and orientation) constituted determining "information about operational status of a vehicle" via communication with a remote database.
  • Motivation to Combine: A POSITA would be motivated to enhance the safety of the base combination's cruise control system, particularly in adverse weather conditions considered by Hongo. Newstrom's lane departure warning system offered a known technique to improve vehicle safety, making it a logical and desirable addition.
  • Expectation of Success: Success would be expected because the combination involved integrating a known safety system (Newstrom's lane departure warnings) with an adaptive cruise control system to yield the predictable result of a safer, more robust driver assistance feature.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) was not warranted because the prior art references asserted in the petition were not previously presented to or considered by the Examiner during prosecution. Petitioner contended the Examiner committed a material error by allowing the claims without considering highly relevant prior art on adaptive cruise control.
• Petitioner also argued that the Fintiv factors weighed against discretionary denial under §314(a). Key arguments included that the parallel district court litigation was in a very early stage with no trial date set, discovery had been stayed pending a motion to transfer, and there was no substantive overlap between the proceedings. Petitioner asserted that the compelling merits of the petition strongly favored institution to serve system efficiency and integrity.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 of the ’399 patent as unpatentable.