PTAB

IPR2025-00891

Toyota Motor Corp v. AutoConnect Holdings LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Personalization System Based on User Location
  • Brief Description: The ’296 patent describes methods and systems for automatically adjusting vehicle controls. The system determines a user's specific location within the vehicle, retrieves that user's saved preferences from a profile memory, and provides an output to adjust associated vehicle controls (e.g., seat position, mirrors, steering control) to match the stored settings.

3. Grounds for Unpatentability

Ground 1: Anticipation and Obviousness over Ikeda

  • Claims 1, 3-9, 11-12, 14-15, 17-18, and 20 are anticipated under 35 U.S.C. §102; Claims 2, 6, 10, 13, 16, and 19 are obvious under 35 U.S.C. §103 over Ikeda.
    • Prior Art Relied Upon: Ikeda (Application # 2008/0215209).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner argued that Ikeda, which was not considered during prosecution, teaches every limitation of the independent claims (1, 7, 8, 14) and renders the remaining claims obvious. Ikeda's disclosed system determines a user’s location (e.g., the driver’s seat via a seat sensor), identifies associated vehicle controls (e.g., seat position controller, mirror attitude controller), and determines the user's presence by detecting a portable device. The system then refers to a user profile memory ("storage unit 22") on the device to retrieve vehicle control settings ("environment setup information item") and transmits this data to the vehicle's control units to adjust them according to the user's preferences. Petitioner contended this maps directly to the elements of the challenged independent claims.
      • Motivation to Combine (for §103 grounds): For claims rendered obvious (e.g., claim 2, which adds storing user settings for multiple vehicle locations), Petitioner argued the motivation to modify Ikeda is found in the reference itself. Ikeda acknowledges that a known user may sit in a seat other than the driver's. A POSITA would thus be motivated to extend Ikeda’s system—which already stores settings for the driver’s seat—to other seats to provide a consistent and improved user experience throughout the vehicle.
      • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in extending Ikeda’s functionality to other vehicle locations. Applying the disclosed method of storing settings for one seat to other seats is a predictable application of a known technique that would yield expected results.

Ground 2: Obviousness over Ikeda in view of Hendry

  • Claims 6, 13, and 19 are obvious over Ikeda in view of Hendry.
    • Prior Art Relied Upon: Ikeda (Application # 2008/0215209) and Hendry (Application # 2012/0303178).
    • Core Argument for this Ground:
      • Prior Art Mapping: This ground provides an alternative obviousness argument for claims that require determining a user has made a change to an adjusted vehicle control and then storing that change. Petitioner asserted that to the extent the Board finds Ikeda does not explicitly teach this functionality, Hendry remedies the deficiency. Hendry discloses a system that, after a user manually changes a setting (e.g., for a seat), prompts the user via an interface to save the new settings. If the user affirms, the adjusted settings are saved in a datastore associated with the vehicle component.
      • Motivation to Combine: Petitioner argued a POSITA would combine Ikeda and Hendry because they are complementary technologies that address the same fundamental problem of vehicle personalization. Ikeda provides a robust system for initial setup based on a user's profile, while Hendry provides a user-friendly mechanism for updating those preferences over time. A POSITA would be motivated to integrate Hendry’s update feature into Ikeda’s system to enhance its utility, as it was well-known that a user's preferences may change over time due to factors like comfort, health, or age.
      • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the teachings. The integration would be a routine combination of known elements in the vehicle control systems field—marrying a profile recall system (Ikeda) with a profile update system (Hendry)—to create a more complete and commercially desirable product.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 9,147,296 as unpatentable.