PTAB

IPR2025-01383

Ford Motor Co v. AutoConnect Holdings LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Infotainment System with Device Discovery and Customization
  • Brief Description: The ’153 patent relates to methods and systems for controlling a vehicle's subsystems by communicating with a mobile device. The invention uses a "device discovery daemon" to discover connected devices, populate system data with the device's information and capabilities, and refresh the vehicle's graphical display to reflect the connected device, with access to certain functions based on the device's physical location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Moinzadeh - Claims 1-3 and 11-14 are obvious over Moinzadeh.

  • Prior Art Relied Upon: Moinzadeh (Application # 2011/0093153).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Moinzadeh discloses all elements of the independent claims. Moinzadeh teaches a vehicle head unit ("communication subsystem") that discovers a mobile phone ("communication device") via a wireless Bluetooth connection ("network") when the vehicle is powered up. Moinzadeh's control software, executed by a microprocessor, acts as a "device discovery daemon" by searching for the device. Upon connection, the software accesses the phone's unique identifier ("device information") and its ability to act as an IP gateway ("capabilities"). This information is used to download a user-specific frontend configuration. Moinzadeh's "web code renderer" functions as the claimed "desktop manager," executing on the microprocessor to process the configuration and "refresh" a graphical user interface on the vehicle's display with customized elements like wallpaper and buttons that reflect the discovered device.
    • Motivation to Combine (for §103 grounds): Not applicable for a single-reference ground. Petitioner contended Moinzadeh alone renders the claims obvious.

Ground 2: Obviousness over Moinzadeh and Clement - Claims 4-5, 7-10, 15-16, and 18-21 are obvious over Moinzadeh in view of Clement.

  • Prior Art Relied Upon: Moinzadeh (Application # 2011/0093153) and Clement (Patent 8,768,539).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that this combination addresses the dependent claims related to location-based access. Moinzadeh provides the base system for device discovery and graphical user interface updates. Clement teaches a vehicle permission management system that determines the current location of a portable control device within predetermined zones of a vehicle's passenger compartment (e.g., driver's seat vs. passenger areas). Based on this determined location, Clement's system permits or denies the device access to control certain vehicle functions, such as steering or entertainment systems.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Clement's location-based permission management with Moinzadeh's infotainment system to improve vehicle safety and security. Adding Clement’s functionality is a predictable expansion of Moinzadeh's system, as both references are from the same field of vehicle-device communication.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success, as the combination involves integrating known software logic for location detection and permission management from Clement into the infotainment framework taught by Moinzadeh.

Ground 3: Obviousness over Rasin and Bosch - Claims 1, 3, 11-12, and 14 are obvious over Rasin in view of Bosch.

  • Prior Art Relied Upon: Rasin (Patent 7,783,699) and Bosch (Bosch Automotive Handbook 6th Edition).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Rasin discloses a vehicle user interface system ("communication subsystem") that connects to an electronic device via a wireless protocol like Bluetooth. Upon connection, Rasin's "networking gateway" and "service engine" perform "service discovery," acting as the claimed "device discovery daemon" to identify the device and its available services ("device information and capabilities"). A "data transformation agent" and "data engine" then act as the "desktop manager" to update or "refresh" graphical elements on the vehicle's display. Bosch, a standard industry handbook, teaches that such automotive systems are implemented on common electronic control units (ECUs) containing a programmable microprocessor and memory.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Rasin's system with Bosch's teachings to implement the disclosed software functions on a standard, cost-effective microprocessor. This represents a common design choice to reduce the piece-price of components for high-volume automotive applications, yielding predictable results.
    • Expectation of Success (for §103 grounds): A POSITA would have readily known how to execute Rasin's software control strategies on a standard microprocessor-based ECU as described by Bosch.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Rasin, Bosch, and Clement for location-based functionality (Ground 4); Rasin, Bosch, and Ghabra for event-triggered discovery (Ground 5); and Rasin, Bosch, Clement, and Ghabra for combined location and event-triggered features (Ground 6).

4. Key Claim Construction Positions

  • "daemon" means "computer program": Petitioner proposed this construction for claims 1 and 12. The argument was based on the claim language requiring the daemon to be "executed by a microprocessor" and the patent's specification explicitly stating that the "device discovery daemon... may be a computer program."
  • "access or attempt to access the vehicle network..." means "access or attempt to access [functionality of] the vehicle network...": For claims 4c and 15c, Petitioner argued that "access" must mean more than a mere connection, because a preceding claim step already establishes that the device is connected or attempting to connect. The construction is supported by the specification, which describes the system enabling access to a "defined set of functions" based on device location.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. It was contended that the co-pending district court litigation is in its earliest procedural stages, with a trial not expected until late 2027, well after a Final Written Decision would issue in this inter partes review.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of Patent 9,290,153 as unpatentable.