Amazon.com Inc v. Kaifi LLC

1. Case Identification

• Case #: IPR2025-00627
• Patent #: 7,689,001
• Filed: February 27, 2025
• Petitioner(s): Amazon.com Inc.
• Patent Owner(s): Kaifi LLC
• Challenged Claims: 1-12

2. Patent Overview

• Title: Location Recognition Device and Method Thereof
• Brief Description: The ’001 patent discloses a method and device for determining the location of a mobile terminal. The system uses the terminal's built-in camera to photograph one or more "location recognition tags" (e.g., barcodes) that are placed at known positions in a physical area.

3. Grounds for Unpatentability

Ground 1: Obviousness over Emanuel and Ihara - Claims 1, 2, 5, 7, 8, and 10 are obvious over Emanuel in view of Ihara.

• Prior Art Relied Upon: Emanuel (Patent 7,845,560) and Ihara (Patent 6,650,776).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Emanuel taught the core method of the ’001 patent: a mobile machine-vision system that determines its position by capturing and processing images of position markers (barcodes) placed at known locations. Emanuel’s system calculated its position by analyzing the barcode to get location information, measuring distance to the marker by comparing a known feature size on the marker to its apparent size in the image, and obtaining direction information from the marker's position in the camera's field of view. However, Emanuel depicted its camera and computer as separate components. Ihara was cited to remedy this, as it explicitly taught a personal computer with a built-in camera for the purpose of capturing and recognizing barcode data. The combination of Emanuel's method with Ihara's integrated hardware allegedly rendered the concept of a "mobile terminal having a built-in camera" obvious.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Ihara’s built-in camera with Emanuel’s system to achieve predictable benefits. These included reducing the number of components, simplifying system configuration, and decreasing points of failure compared to Emanuel's separate camera and computer setup. This combination was argued to be a simple application of a known technique (integrating a camera into a computer) to improve a known system (Emanuel's).
  • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, particularly because Emanuel itself disclosed that a "preferred embodiment" utilized a commercial Cognex machine-vision system which, as Petitioner showed, was an integrated device with a built-in camera.

Ground 2: Obviousness over Emanuel, Ihara, and Tanaka - Claims 3, 4, and 9 are obvious over the combination of Emanuel, Ihara, and Tanaka.

• Prior Art Relied Upon: Emanuel (Patent 7,845,560), Ihara (Patent 6,650,776), and Tanaka (Application # 2004/0189856).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Emanuel/Ihara combination by adding Tanaka. Claims 3, 4, and 9 require measuring distance using an auto-focusing operation or a dedicated sensor with infrared or ultrasonic waves. Petitioner contended that while Emanuel taught measuring distance via image analysis, Tanaka taught using an "automatic focusing function" (AF) in portable devices to measure distance to a subject by emitting infrared or ultrasonic waves.
  • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate Tanaka's AF-based distance measurement into the Emanuel/Ihara system to improve and verify the accuracy of the primary image-based distance calculations. This would further Emanuel’s stated goal of "high accuracy" and would also allow the system to work with a wider variety of position markers that might lack the specific geometric features required for Emanuel's image-based measurement.
  • Expectation of Success (for §103 grounds): Success would be expected because Tanaka's AF system was specifically designed for portable devices like the notebook computer disclosed in Ihara, making its application straightforward.

Ground 3: Obviousness over Emanuel, Ihara, and deVos - Claims 6 and 12 are obvious over the combination of Emanuel, Ihara, and deVos.

• Prior Art Relied Upon: Emanuel (Patent 7,845,560), Ihara (Patent 6,650,776), and deVos (Patent 5,137,354).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed claims 6 and 12, which require calculating the terminal’s location via a "triangulation measuring algorithm" using "three or more location recognition tags." Petitioner argued that Emanuel itself suggested using "more than one position marker... to verify the calculation and improve the precision." DeVos was introduced because it explicitly taught a position sensing system that "calculates the X-Y-Z coordinates of a point in space using triangulation" based on the known coordinates of "at least three" distinct elements, each identified by a unique barcode.
  • Motivation to Combine (for §103 grounds): When implementing Emanuel’s suggestion to use multiple markers to improve precision, a POSITA would naturally turn to a well-known and powerful technique for that exact purpose: triangulation, as taught by deVos. Applying deVos's triangulation algorithm to the multi-marker scenario in Emanuel was presented as an obvious design choice to achieve the desired precision improvement.
  • Expectation of Success (for §103 grounds): A POSITA would expect success because the combination merely applied a known calculation method (triangulation) to a system (Emanuel's) that was already described as suitable for using multiple data points to enhance accuracy.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 11 based on Emanuel, Ihara, and Sheynblat (Patent 6,677,894), which taught offloading location processing to a remote server. Petitioner also presented alternative grounds 5-7, which argued the same prior art combinations against claims 8-12 under a means-plus-function claim construction interpretation.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv would be inappropriate. The key reasons asserted were that the co-pending district court litigation was in its very early stages with minimal investment, the trial date was speculative and distant, and the petition presented compelling evidence of unpatentability.
• Petitioner also argued that denial under §325(d) was not warranted because the prior art references and combinations presented in the petition were not considered by the Examiner during the original prosecution of the ’001 patent.

5. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-12 of the ’001 patent as unpatentable under 35 U.S.C. §103.