PTAB

IPR2025-00955

Koito Mfg Co Ltd v. Longhorn Automotive Group LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Lens System for Computer Vision
  • Brief Description: The ’803 patent describes a lens system for creating a light pattern for use with computer vision systems. The system combines a light emitting diode (LED) cluster, a condenser lens, and a lens cluster to project a discernible pattern intended for more accurate object tracking.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 8 are anticipated by Mizusawa

  • Prior Art Relied Upon: Mizusawa (Patent 7,733,574).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mizusawa, which discloses an optical illumination system, teaches every element of claims 1 and 8. Mizusawa’s LED-array light source (11) with light-emitting sections (2) was identified as the claimed “light source including a plurality of emitters arranged in a pattern.” The constituent lenses (6a) of Mizusawa’s fly-eye lens (6) were mapped to the “cluster of lenses,” which is located in front of the light source and configured to receive light from the emitters. Petitioner asserted that Mizusawa’s cluster of lenses concurrently focuses and projects light in a plurality of directions to form multiple light-source images. Finally, Mizusawa’s focusing lens (16) was identified as the claimed “condenser lens” located between the light source and the lens cluster, which concentrates light toward the center of the cluster.

Ground 2: Claims 1-6, 8-13, and 15-16 are obvious over Weidel in view of Chinniah

  • Prior Art Relied Upon: Weidel (German Application # 10129743C2) and Chinniah (Patent 7,563,008).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Weidel discloses the fundamental architecture of the claimed system, including a light source with a two-dimensional array of emitters, a condenser lens (collecting lens 8), and a cluster of lenses (diffuser 10). However, Petitioner argued Weidel does not explicitly teach that its lens cluster concurrently focuses and projects light in a plurality of directions. This limitation, Petitioner asserted, is taught by Chinniah, which discloses a vehicle headlamp condenser lens with a plurality of facets structured to horizontally focus light differently from the vertical focus to create a predetermined beam pattern with increased horizontal spread.
    • Motivation to Combine: A POSITA would combine Weidel with Chinniah to address the shared problem of improving road illumination while minimizing glare for oncoming traffic. A POSITA implementing Weidel’s headlight system would be motivated to incorporate Chinniah’s faceted lens design to gain more precise control over the projected light pattern and improve visibility, a known objective in the art.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references operate in the same field of vehicle lighting, and modifying a lens with facets to shape a light beam was a well-understood and predictable technique.

Ground 3: Claims 7, 14, and 17 are obvious over Chinniah in view of Brandenburg and Osawa, and in further view of Hilaire and/or Cheon

  • Prior Art Relied Upon: Chinniah (Patent 7,563,008), Brandenburg (German Application # 102006004587A1), Osawa (Japanese Application # 2004214144A), Hilaire (Application # 2007/0263903), and Cheon (Korean Application # 100482557B1).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon a base combination (Chinniah, Brandenburg, Osawa) alleged to teach the optical system of claim 1, and added Hilaire and/or Cheon to teach the additional limitations of claims 7, 14, and 17. These claims require a camera configured to detect the light pattern on an object and a computing device to determine the object’s location in space. Petitioner argued Hilaire and Cheon explicitly teach such computer vision systems. Hilaire discloses a system that projects a textured pattern of light, uses a camera to capture images of an object illuminated by the pattern, and employs a computing device to calculate the object’s distance. Similarly, Cheon discloses a vehicle night-vision system using near-infrared lamps, a camera, and an image processing unit to detect pedestrians and alert the driver.
    • Motivation to Combine: A POSITA developing an advanced vehicle headlamp system as taught by the primary references would be motivated to integrate the camera and computing device of Hilaire or Cheon to provide enhanced safety features, such as object detection in low-visibility conditions. The use of infrared light, taught by the secondary references, aligns with the primary references’ goal of avoiding glare to other drivers while enabling machine vision.
    • Expectation of Success: The combination was presented as the integration of known optical systems with known computer vision systems to achieve the predictable result of object detection using patterned illumination.

  • Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges (Grounds 1, 3, 5, 7, 8) based on various combinations of Weidel, Tatsukawa, Chinniah, Brandenburg, and Osawa, relying on similar arguments regarding known component substitutions and design modifications.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 8,810,803 as unpatentable.