Tesla Inc v. Intellectual Ventures II LLC

1. Case Identification

• Case #: IPR2025-00342
• Patent #: 7,336,805
• Filed: January 3, 2025
• Petitioner(s): Tesla, Inc.
• Patent Owner(s): Intellectual Ventures II LLC
• Challenged Claims: 1-2, 6-11

2. Patent Overview

• Title: Method for Assisting Vehicle Guidance
• Brief Description: The ’805 patent discloses a method for assisting vehicle guidance based on image data. The method involves acquiring images with a sensor, breaking the image data into a plurality of edge segments, storing the interrelationships of these segments in a mathematical tree structure, and analyzing the tree to identify geometric objects corresponding to a potential destination to calculate a travel path.

3. Grounds for Unpatentability

Ground 1: Obviousness over Broggi, Huttenlocher, and Brady - Claims 1-2 and 9-10 are obvious over Broggi in view of Huttenlocher and Brady.

• Prior Art Relied Upon: Broggi (“Visual Perception of Obstacles and Vehicles for Platooning,” a 2000 publication), Huttenlocher (“Object Recognition Using Alignment,” a 1989 publication), and Brady (Patent 5,434,927).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination disclosed all limitations of independent claim 1. Broggi taught an autonomous vehicle using cameras for "platooning" (automatic following of a preceding vehicle), which involved acquiring images, detecting the lead vehicle, and calculating a steering trajectory. However, Broggi only mentioned using a "traditional pattern matching technique" without detail. Huttenlocher supplied this detail, teaching a sophisticated pattern matching technique that performs edge detection, segments the edges, and stores them in a multi-scale mathematical tree structure to identify objects. Brady taught a system for tracking vehicles that stores identified vehicles and their positional data in an "object list" or "vehicle log." Petitioner contended that Broggi taught the overall method of guidance based on image data, Huttenlocher provided the specific claimed method of extracting object features using a mathematical tree structure, and Brady taught storing the identified object and its positional data in an object list. Dependent claims 2, 9, and 10 were also allegedly taught by the combination, covering tree traversal algorithms (Huttenlocher) and semi-automatic guidance with driver alerts (Broggi).
  • Motivation to Combine: A POSITA would combine Huttenlocher with Broggi because Broggi expressly called for a "traditional pattern matching technique," and Huttenlocher provided a known and improved method for this purpose to yield predictable results. A POSITA would have been further motivated to incorporate Brady's teachings because Broggi's platooning system required tracking vehicle data over time, and Brady provided a known, advantageous mechanism for storing and managing this data in an object list, thereby improving tracking accuracy.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because Huttenlocher and Brady provided established techniques for image recognition and data management, respectively, that were directly applicable to the vehicle guidance and platooning context described in Broggi.

Ground 2: Obviousness over Broggi, Huttenlocher, Brady, and Bertozzi - Claims 6-8 and 11 are obvious over Broggi, Huttenlocher, and Brady in view of Bertozzi.

• Prior Art Relied Upon: Broggi, Huttenlocher, Brady, and Bertozzi (“Automatic Vehicle Guidance: The Experience of the ARGO Autonomous Vehicle,” a 1999 publication).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination in Ground 1, adding Bertozzi to teach the limitations of claims 6-8 and 11. Petitioner asserted that Broggi and Bertozzi described the same "ARGO" autonomous vehicle, with Bertozzi providing additional implementation details. Claim 6 required considering a vehicle's "steering property and a capability" when calculating a trajectory. Bertozzi allegedly taught this by describing a control system that avoids "sudden and therefore dangerous movements of the steering wheel" by permitting only small steering movements at high speed, thus considering the vehicle's capabilities. This inherent safety limitation also taught claim 7's requirement of "rejecting a potential destination that is not reachable." Claim 8's limitation of "informing a driver" was met by Bertozzi's disclosure of displaying process results, including vehicle positions and paths, on an on-board color monitor. Finally, claim 11's limitations regarding continuous monitoring and selecting a new destination when the current one is unreachable were allegedly taught by the combination of Broggi's continuous image processing loop and Bertozzi's steering safety constraints.
  • Motivation to Combine: A POSITA would combine Bertozzi with the base combination because Bertozzi and Broggi described the same ARGO vehicle. A POSITA seeking to implement Broggi's platooning system would have naturally consulted Bertozzi for further configuration details and to incorporate known safety features, such as limiting steering movements based on speed to improve system performance and user experience.
  • Expectation of Success: There would have been a high expectation of success because Bertozzi's teachings were not for a disparate system but were specific implementation details for the very same vehicle platform discussed in Broggi, ensuring direct applicability and compatibility.

4. Arguments Regarding Discretionary Denial

• §325(d) Denial: Petitioner argued denial under §325(d) is inappropriate because the grounds are not cumulative to art considered during prosecution. The Examiner did not consider Broggi, Huttenlocher, Brady, or Bertozzi, nor the specific combinations presented in the petition.
• Discretionary Denial under Fintiv: Petitioner argued the Fintiv factors strongly favor institution. The parallel district court case is in its earliest stages, with a proposed trial date of May 14, 2026, which is projected to occur months after the Board's deadline for a Final Written Decision. Investment in the parallel litigation has been minimal, with no claim construction hearing or substantive discovery yet to occur. Petitioner asserted it filed its petition promptly after infringement contentions were served and that the petition presents compelling evidence of unpatentability.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2 and 6-11 of Patent 7,336,805 as unpatentable.