PTAB

IPR2025-00758

Mercedes Benz Group AG v. Phelan Group LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Driver Authentication and Safety System
  • Brief Description: The ’508 patent discloses a system for authenticating a driver and monitoring vehicle operation against a pre-defined "operating profile." The system is intended to control vehicle usage by high-risk drivers by enforcing restrictions on parameters like speed, location, and hours of operation, and taking control actions if the driver violates the profile.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8-11, and 13-14 are anticipated by or obvious over Murphy

  • Prior Art Relied Upon: Murphy (Patent 6,225,890)
  • Core Argument for this Ground: Petitioner argued that Murphy, which predates the ’508 patent by over a decade, discloses a near-identical system for restricting vehicle use by selected operators, including high-risk drivers like teenagers.
    • Prior Art Mapping: Petitioner asserted that Murphy discloses all limitations of the independent claims. For independent claim 1, Murphy teaches a driver authentication system with a controller that authenticates drivers via various interfaces (biometric, smart card, keypad). This system uses a unique "ident indicium" (e.g., biometric sample, coded sequence) to permit vehicle operation only within pre-defined "vehicle operation restrictions" (an operating profile) stored in a database. Murphy’s controller and associated modules monitor vehicle status (speed, location) against the profile, generate signals upon a violation, and cooperate to control vehicle operation by taking actions such as reducing speed or disabling the vehicle. Similar arguments were made for the limitations of independent claim 11, including its GPS module and data logging features.

Ground 2: Claims 1-6, 8-11, and 13-14 are anticipated by or obvious over Petrik

  • Prior Art Relied Upon: Petrik (Application # 2007/0168125)
  • Core Argument for this Ground: Petitioner contended that Petrik, a GPS-based vehicle monitoring and management system, discloses all elements of the challenged claims.
    • Prior Art Mapping: Petitioner alleged Petrik's "in-vehicle monitoring unit" functions as the claimed driver authentication system, using a smart card reader and fingerprint reader as the identification interface. For claim 1, Petrik’s use of a smart card with a unique fingerprint template recorded on it was argued to be the "unique identification code" that permits vehicle operation within an associated operating profile (e.g., intended route plan, rest times, speed limits). The in-vehicle unit, in communication with an "engine management system" computer, monitors vehicle activity, generates signals (e.g., beeps for speed zone changes), and cooperates with the engine management system to control the vehicle (e.g., slow down, speed up, or disable). Petitioner extended this mapping to the elements of independent claim 11 and the various dependent claims.

Ground 3: Claims 1-6, 8-11, and 13-14 are obvious over Petrik in view of Schanz

  • Prior Art Relied Upon: Petrik (Application # 2007/0168125), Schanz (German Application # DE 10,323,723)

  • Core Argument for this Ground: Petitioner argued that even if Petrik does not anticipate all claims, it would have been obvious to a Person of Ordinary Skill in the Art (POSITA) to modify Petrik’s system with features taught by Schanz to arrive at the claimed invention.

    • Prior Art Mapping: This ground focused on modifying Petrik’s authentication method. Schanz discloses a driver authentication system with a reading device that recognizes an "identification code" to identify a driver and assign individual vehicle parameters (e.g., maximum power, speed) based on driver skill. Petitioner argued this teaching from Schanz could be applied to the "unique identification code" and "operating profile" limitations of the claims.
    • Motivation to Combine: A POSITA would combine Schanz's teachings with Petrik's system to provide greater flexibility in driver authentication. This would allow for authenticating drivers using methods other than a fingerprint on a smart card and enable more tailored, customized operating parameters based on factors like driver skill.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success because both Petrik and Schanz disclose similar driver identification interfaces. The combination would have been a straightforward implementation of a known type of interface for its intended purpose in a similar system.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Murphy with Adams (Application # 2008/0046739) to teach an RFID device for claim 10, and combining both Murphy and Petrik with Wu (Application # 2008/0114501) to teach common vehicle components like starter relays and power regulators for claims 7 and 12.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) based on Fintiv factors would be inappropriate. The parallel district court case was asserted to be in its very early stages, having been recently transferred with no case schedule set and a trial date no earlier than February 2026.
  • Petitioner also argued against denial under §325(d), contending that the prior art and arguments presented in the petition are not the same or substantially the same as those considered by the USPTO during the original prosecution, and therefore constitute new, non-cumulative grounds for review.

5. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-14 of Patent 9,908,508 as unpatentable.