PTAB

IPR2025-01342

Ford Motor Co v. AutoConnect Holdings LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Device Discovery Daemon for Vehicle Network Access Based on Device Location
  • Brief Description: The ’697 patent relates to methods and systems for managing a mobile device’s access to an onboard vehicle network. The system uses a "device discovery daemon," a background computer program, to determine the mobile device's location and permit or restrict access to vehicle functions accordingly.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-9, 11-16, and 18-21 are obvious over Clement

  • Prior Art Relied Upon: Clement (Patent 8,768,539).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Clement disclosed all limitations of the independent claims. Clement taught a vehicle permission management system where a portable computing device (e.g., smartphone) could control vehicle functions. The system’s vehicle control unit determined the device's location within predetermined regions of the passenger compartment (e.g., driver's seat vs. passenger seat). Based on this location, the system applied rules to either permit access (e.g., allow steering control when in the driver's seat) or not permit access to certain functions. This directly mapped to the ’697 patent’s core method of determining a device’s location within a zone and applying rules to grant or deny access to the vehicle network.
    • Key Aspects: For dependent claims, Petitioner asserted Clement taught using triangulation of signal strengths from multiple in-vehicle receivers to determine device location and disclosed that the portable device could be a smartphone or tablet.

Ground 2: Claims 3, 10, and 17 are obvious over Clement in view of Ghabra

  • Prior Art Relied Upon: Clement (Patent 8,768,539) and Ghabra (Patent 7,388,466).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring device discovery to be initiated by a specific trigger event. Petitioner asserted Clement provided the base system for location-based functional access. Ghabra, which disclosed a Passive Entry Passive Start (PEPS) system, supplied the missing trigger element. Ghabra taught that a physical user action, such as lifting a door handle or pressing an engine start button (an "on board vehicle sensor"), generated a trigger signal. In response, the vehicle system would emit a wakeup signal ("ping") to discover a nearby key fob and, upon receiving a response, determine the fob was attempting to connect.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Ghabra’s PEPS trigger-and-ping discovery method with Clement’s location-based permission system for predictable benefits. These benefits included improved user convenience (enabling hands-free operation), enhanced security (by initiating discovery only upon a valid user action), and conservation of battery life (by avoiding constant polling for devices).
    • Expectation of Success: Petitioner argued success was expected, as the combination involved integrating known, complementary technologies—a trigger sensor and discovery logic from Ghabra into the permission management framework of Clement—to achieve the predictable result of a more efficient and secure system.

Ground 3: Claims 1-2, 4, 6-9, 11, 13-16, 18, and 20-21 are obvious over Lickfelt

  • Prior Art Relied Upon: Lickfelt (Application # 2012/0092129).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Lickfelt, like Clement, independently taught the core invention. Lickfelt disclosed a passive vehicle entry system that used a key fob as the computational device. The system's Electronic Control Unit (ECU) defined a plurality of zones around the vehicle (e.g., an "internal zone," a "proximal zone," and an "outer zone"). The ECU determined the fob's location relative to these zones by polling for the fob and measuring signal strength. Based on the determined zone, the ECU applied rules to either permit access (unlocking the doors when the fob entered the proximal zone) or not permit access (locking the doors when the fob moved to the outer zone).
    • Key Aspects: Petitioner argued that Lickfelt’s disclosure of determining location based on comparing signal strength over time taught the "level of confidence" limitation in certain dependent claims, as a stronger subsequent signal indicates a higher probability (confidence) that the device is approaching the vehicle.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 3, 5, 10, 12, 17, and 19 over Lickfelt in view of Ghabra, relying on a similar motivation-to-combine rationale as in Ground 2 to add trigger-based discovery for passive start functionality to Lickfelt's passive entry system.

4. Key Claim Construction Positions

  • "daemon" means "computer program": Petitioner proposed this construction for claims 1, 8, and 15. The argument was based on the claim language requiring the daemon to be "microprocessor executable" and the specification explicitly stating the "device discovery daemon...may be a computer program." Petitioner contended this construction was necessary because interpreting "daemon" to inherently include discovery functionality would render the separate discovery-related steps in dependent claim 3 redundant.
  • "access or attempt to access the vehicle network..." means "access or attempt to access [functionality of] the vehicle network...": Petitioner argued that because step (a) of the independent claims already established that the device is "connected to or attempting to connect to" the network, the "access" permitted in step (c) must refer to something more than mere connection. The specification supported this by describing access in terms of enabling or restricting vehicle functions (e.g., "ignition access," "vehicle control functions") based on device location.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv. It asserted that the co-pending district court litigation was in its earliest stages and that a trial was not anticipated until late 2027, which is well after the statutory deadline for a Final Written Decision in this IPR.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’697 patent as unpatentable.