PTAB

IPR2025-00632

Revvo Technologies Inc v. Cerebrum Sensor Technologies Inc

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: SENSOR ASSEMBLIES AND SYSTEMS FOR MONITORING A DYNAMIC OBJECT
  • Brief Description: The ’421 patent discloses sensor assemblies for monitoring dynamic objects, such as vehicle tires. The technology aims to improve upon traditional tire-pressure monitoring systems (TPMS) by reducing size and weight while adding functionality, such as monitoring tire performance parameters beyond pressure.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 7-9, 11, 12, and 20-24 are obvious over Yamaguchi-727.

  • Prior Art Relied Upon: Yamaguchi-727 (Application # 2021/0370727).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yamaguchi-727, which describes a "functional component" for monitoring tires, discloses all limitations of the challenged claims. Yamaguchi-727’s component includes a housing, an internal electronic module with sensors (the "electrical sensor device"), and a skirt for attachment (the "retaining member"). Critically, Petitioner asserted that Yamaguchi-727 teaches the key limitation of an "unfilled open space" above the sensor device. This is because Yamaguchi-727 uses only partial potting material, which leaves an open air path through a hole in the housing cap to its pressure and temperature sensors, a feature added to the ’421 patent claims during prosecution to overcome prior art that was fully encapsulated.

Ground 2: Claims 5, 28, 31-33, 41, 43, 44, 48, and 50-52 are obvious over Yamaguchi-727 in view of Yamaguchi-566.

  • Prior Art Relied Upon: Yamaguchi-727 (Application # 2021/0370727) and Yamaguchi-566 (Application # 2021/0394566).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements Yamaguchi-727 with Yamaguchi-566 primarily to teach the "one or more surface features" (claim 5) that create a "fixed placement" (claim 28) for the sensor device within the housing. While Yamaguchi-727 discloses a general "positioning means," Yamaguchi-566 explicitly describes using ribs (convex parts) and grooves on the inner surface of the housing to engage the sensor module and prevent its radial movement. This combination allegedly provides a clear structural basis for fixing the sensor's position and orientation.
    • Motivation to Combine: A POSITA would combine these references because they are analogous art from the same inventor and assignee, were filed on the same day, and describe complementary aspects of the same tire sensor invention. Petitioner contended that Yamaguchi-566 provides specific implementation details that a POSITA would naturally use to refine and improve the more general design disclosed in Yamaguchi-727.
    • Expectation of Success: Petitioner argued for a high expectation of success, as the combination would involve applying routine fabrication techniques to integrate the specific rib-and-groove features of Yamaguchi-566 into the housing of Yamaguchi-727.

Ground 3: Claims 34 and 53 are obvious over Yamaguchi-727 and Yamaguchi-566 in further view of Dodani-859.

  • Prior Art Relied Upon: Yamaguchi-727 (Application # 2021/0370727), Yamaguchi-566 (Application # 2021/0394566), and Dodani-859 (WO 2020/036859).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Dodani-859 to teach the specific data processing methods recited in claims 34 and 53. While the Yamaguchi combination provides a sensor system with an accelerometer that transmits data, Dodani-859 allegedly supplies the missing teaching of how to use that accelerometer data to "determine" specific operating parameters, such as "road conditions" and "vehicle camber and/or toe alignment."
    • Motivation to Combine: A POSITA would combine Dodani-859 with the Yamaguchi sensor system to enhance its functionality. The Yamaguchi system provides the hardware platform to collect and transmit data, while Dodani-859 teaches known software-based methods for processing that data into valuable, actionable information, which was the ultimate goal of such sensor systems.
    • Expectation of Success: Success would be expected, as the combination would only require the routine application of conventional software programming to implement Dodani-859's known data analysis techniques in the receiver unit of the Yamaguchi system.

Ground 4: Claim 10 is obvious over Yamaguchi-727 in view of McDonald.

  • Prior Art Relied Upon: Yamaguchi-727 (Application # 2021/0370727) and McDonald (Patent 6,769,319).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 10, which requires a "filter" covering the opening in the sensor housing. Yamaguchi-727 discloses a housing with an opening for its pressure sensor but does not explicitly mention a filter. McDonald was cited for its teaching of using a filter in tire-mounted sensors to block corrosive elements while permitting the transmission of air pressure.
    • Motivation to Combine: A POSITA would add McDonald's filter to the opening in Yamaguchi-727's housing to solve the well-known and predictable problem of sensor corrosion from exposure to tire mounting pastes and other chemicals. Protecting sensors was a known design consideration, and using a filter was one of a limited number of established solutions.
    • Expectation of Success: The combination was presented as a straightforward incorporation of a standard component (a filter) into a known device (a tire sensor) to achieve a predictable result (corrosion protection), leading to a high expectation of success.

4. Key Claim Construction Positions

  • Petitioner stated it accepts Patent Owner's proposed claim constructions from the co-pending district court litigation for the purposes of the IPR.
  • Key accepted constructions that are central to Petitioner's arguments include:
    • "unfilled open space" as "space without filing agents or materials."
    • "fixed"/"having a fixed placement" as "not displaceable in at least one direction."
    • "surface feature[s]" as "structure[s] on or of a surface."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate.
  • Regarding §314(a) and Fintiv, Petitioner asserted that the co-pending litigation is in a very early stage, with no claim construction rulings issued and all deadlines currently stayed.
  • Regarding §325(d), Petitioner argued that its grounds are based on new prior art (Yamaguchi-727, Yamaguchi-566, etc.) that was not before the Examiner during prosecution. It contended this art is not cumulative to the Saito reference previously overcome, because the cited art, unlike Saito, discloses a partially potted rather than a fully encapsulated sensor, directly aligning with the claim limitation added to secure allowance.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 5, 7-12, 20-24, 28, 31-34, 41, 43, 44, 48, and 50-53 of the ’421 patent as unpatentable.