PTAB

IPR2025-01064

Volkswagen Group Of America Inc v. Longhorn Automotive Group LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Forming a Medical Image of a Mobile Object
  • Brief Description: The ’353 patent discloses methods to reduce motion artifacts in medical imaging. The invention combines images from two different imaging techniques (e.g., CT and PET) with data from two independent sensor systems that measure an object’s movement to create a corrected, composite image.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 are obvious over Weese.

  • Prior Art Relied Upon: Weese (Application # 2005/0226527).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Weese teaches every limitation of the challenged claims. Weese describes methods for combining CT images ("first images" from a "first imaging technique") and PET images ("second images" from a "second imaging technique") to correct for motion artifacts. Weese discloses using a first sensor system (e.g., sensor 15) to obtain motion measurements corresponding to the CT imaging and a second sensor system (e.g., sensor S1) to obtain motion measurements during PET imaging. Weese then uses these measurements to construct a motion model (M2) which associates the images with their respective motion states and forms various fused, motion-corrected images (e.g., I5, I6, I7, I9), thereby meeting the limitations of independent claims 1 and 12.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner asserted that Weese's flexible framework, which describes multiple embodiments and alternative processing pathways for both combined and separate CT/PET systems, inherently discloses and renders obvious all claimed combinations of steps.
    • Expectation of Success (for §103 grounds): A person of ordinary skill in the art (POSITA) would have had a high expectation of success as Weese explicitly aims to improve image fusion and reduce motion artifacts using the claimed techniques.

Ground 2: Claims 1-18 are obvious over Weese in view of Muehllehner.

  • Prior Art Relied Upon: Weese (Application # 2005/0226527), Muehllehner (Patent 5,744,802).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements Weese to address the limitation of obtaining a "plurality of second images" ([1c-i]). While Petitioner argued Weese alone teaches this, this combination provides an alternative basis. Weese refers to creating "volume images" using "known" techniques but does not provide specific implementation details. Muehllehner, in contrast, explicitly teaches a well-known method of generating 3D PET volume images by collecting and reconstructing a series of 2D slices. This slice-by-slice method is a "known" technique a POSITA would have used to implement the volume imaging mentioned in Weese.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Muehllehner's detailed slice-by-slice volume rendering with Weese's general motion-correction framework to achieve a practical implementation of Weese's system. The combination would reduce blurring and improve efficiency, goals shared by both references, using the same conventional PET hardware.
    • Expectation of Success (for §103 grounds): The combination would have been predictable because it involves applying a known imaging technique (Muehllehner) to a system expressly designed to incorporate such known techniques (Weese).

Ground 3: Claims 1-18 are obvious over Weese in view of Wainer.

  • Prior Art Relied Upon: Weese (Application # 2005/0226527), Wainer (Patent 5,871,013).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground provides an alternative way Weese's system could be implemented using known techniques. Weese teaches correcting motion artifacts by focusing images on a single motion state, while Wainer teaches the conventional technique of "gating" images—grouping image data into bins based on physiological cycles (respiratory and cardiac) detected by sensors. A POSITA would have applied Wainer’s gating methods to both the CT ("first") and PET ("second") images in Weese’s system. This combination provides detailed sensor-based gating for obtaining measurements, associating them with images, and forming motion-corrected images.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wainer’s gating with Weese's motion-correction to improve the reliability and precision of matching motion states between the CT and PET images. Wainer's method directly addresses the problem of motion artifacts from body rhythms, which is the central goal of Weese, and Wainer states that gating is "preferable" because it facilitates automatic registration.
    • Expectation of Success (for §103 grounds): Success would be expected, as this involves applying a standard, textbook technique (gating) to reduce motion artifacts in a system designed for that exact purpose, using hardware (sensors, processors) already present in Weese.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-18 based on Wainer alone, arguing Wainer teaches forming fused, dual-gated structural and functional images.

4. Key Claim Construction Positions

Petitioner asserted that numerous limitations in apparatus claims 12-18 are means-plus-function limitations under 35 U.S.C. §112, ¶6. Petitioner's arguments relied on construing these terms based on the structure disclosed in the specification, which they contended is conventional imaging and processing hardware.

  • "[12a-i]/[12c-i] means for obtaining... images": The identified function is obtaining images using an imaging technique. The proposed corresponding structure is a conventional imaging system, including an attenuation or emission radiation source, detector, gantry, processor, and memory.
  • "[12a-ii]/[12c-ii] means for obtaining... measurements": The identified function is obtaining movement measurements. The proposed corresponding structure is a breathing sensor, pressure sensor, or electrocardiogram sensor.
  • "[12b]/[12d] means for associating..." and "[12e] means for forming an image...": The identified functions are associating data and forming an image. The proposed corresponding structure for these steps is a computer programmed to perform the specified associating and forming functions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 8,265,353 as unpatentable.