PTAB

IPR2024-00814

Toyota Motor Corp v. Emerging Automotive LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cloud Services System for Interfacing with Vehicles
  • Brief Description: The ’244 patent describes methods and systems for customizing vehicles by transferring user-specific settings from a profile stored on a server. The system uses cloud services to apply these settings, including restrictions, when a user is authenticated in a vehicle.

3. Grounds for Unpatentability

Ground 1: Claims 1, 9, 11-17, 19, and 20 are obvious over Rector in view of Kleve

  • Prior Art Relied Upon: Rector (Application # 2011/0137520) and Kleve (Application # 2014/0129053).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rector discloses a method for controlling vehicle settings based on a driver’s identity, executed by a settings server that receives a request from a vehicle, determines permitted settings from a database, and transmits them. Rector’s system is designed to limit driver distractions by enforcing restrictions (e.g., parental controls on speed or radio volume). Petitioner contended that Rector teaches nearly all limitations of independent claim 1, including receiving a request from a vehicle to access a profile, processing user information, and transferring settings to customize the vehicle, with at least one setting being restricted. Kleve was introduced to supplement Rector’s disclosure regarding server-side user verification, teaching a cloud-based rental car system where a server performs remote credential verification before applying personal settings (e.g., radio presets, seat position) to the vehicle.
    • Motivation to Combine: A POSITA would combine Rector with Kleve to improve the security of Rector’s system. Since Rector already used a server to manage settings, it would have been a natural and straightforward step to incorporate Kleve’s server-side credential verification before applying those settings, thereby ensuring the correct user profile is applied.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because implementing Kleve’s server-based verification logic within Rector’s existing server architecture is a predictable integration of known technologies for a common purpose.

Ground 2: Claims 2, 4, 10, and 18 are obvious over Rector in combination with Kleve and Yassin

  • Prior Art Relied Upon: Rector (Application # 2011/0137520), Kleve (Application # 2014/0129053), and Yassin (Patent 6,505,780).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Yassin to the base combination of Rector and Kleve to address limitations related to profile transferability and dynamic updates. Petitioner asserted Yassin teaches personalizing vehicle settings via a remote profile database that can be wirelessly communicated to a plurality of different vehicles, thus rendering a user’s profile transferrable. Yassin further discloses that changes a driver makes to settings during vehicle use are communicated back to the server, which then updates the user’s profile database. This teaching was argued to render obvious claim 2 (profile transferrable to other vehicles) and claim 4 (server receiving inputs made during use to update the profile).
    • Motivation to Combine: A POSITA would combine Yassin with the Rector/Kleve system to enhance convenience and safety. Allowing a user’s profile to be applied across multiple vehicles and automatically saving any in-vehicle adjustments reduces driver distraction and improves the user experience, a goal shared by Rector.
    • Expectation of Success: Success would be expected as Yassin demonstrates the feasibility of applying a single, remotely stored profile to multiple vehicles and synchronizing user changes, a logical extension for any cloud-based vehicle settings system.

Ground 3: Claims 5-7 are obvious over Rector in combination with Kleve, Yassin, and Patenaude

  • Prior Art Relied Upon: Rector (Application # 2011/0137520), Kleve (Application # 2014/0129053), Yassin (Patent 6,505,780), and Patenaude (Application # 2006/0136106).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Patenaude to address the “learning engine” limitations of claims 5-7. Petitioner argued that Patenaude discloses a method for determining and predicting a user's entertainment selections by monitoring user behavior over time to find patterns. Patenaude’s system uses these learned patterns (e.g., based on time of day, location, or other conditions) to automatically apply personalized settings. This directly teaches the limitation in claim 5 of a “learning engine that uses the inputs made to the systems of the vehicle to find patterns.” Patenaude’s disclosure of correlating patterns with conditions like "number of passengers" and "time of day" was argued to meet the limitations of claim 7.
    • Motivation to Combine: A POSITA would be motivated to integrate Patenaude's learning engine into the Rector/Kleve/Yassin system to further improve convenience and reduce driver distraction. By automatically predicting and applying settings based on learned patterns, the system would require less manual input from the driver.
    • Expectation of Success: Adding a software-based learning module to a server-side system was a known and predictable modification. Patenaude demonstrates the methodology for learning user preferences, which could be readily implemented on the servers disclosed by Rector and Kleve.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 8 and 21 based on Rector, Kleve, and Faenger (Application # 2011/0035031), which also teaches a learning engine for personalizing vehicle entertainment. A final ground for claim 22 combined Rector, Kleve, Faenger, and Yassin.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial under Fintiv. Key arguments included that the petition was filed diligently (within three months of receiving infringement contentions in a related district court case), and that significant litigation milestones like claim construction and discovery would occur after the Board’s institution decision, minimizing duplicative effort. Petitioner also contended that the petition raises strong arguments based on materially different and non-cumulative prior art not considered during prosecution, weighing heavily in favor of institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 4-22 of the ’244 patent as unpatentable.