PTAB

IPR2025-01524

Ford Motor Co v. AutoConnect Holdings LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Control System
  • Brief Description: The ’186 patent discloses methods and systems for a vehicle control system that controls a user’s access to vehicle tasks and functions based on rights and privileges defined in a user account. The system authenticates a user and then applies rules based on the user's account and the vehicle's operating state.

3. Grounds for Unpatentability

Ground 1: Claims 1, 5, 8, 15, and 19 are obvious over Gratz and Bosch.

  • Prior Art Relied Upon: Gratz (Application # 2008/0245598) and Bosch (Automotive Handbook, 6th Ed., 2004).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gratz disclosed all elements of the independent claims except for the explicit use of a "microprocessor." Gratz taught a vehicle restriction control system that uses driver-specific "restriction profiles" (accounts) to define permissions (rights and privileges) for vehicle operations, such as setting a maximum speed. The system determines the vehicle's operating state (e.g., speed) and applies rules from the user's profile to permit or deny requested operations. Petitioner contended that Bosch, a standard automotive engineering handbook, taught that electronic control units (ECUs) in vehicles commonly used microprocessors to perform logic processing.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references to implement Gratz’s CPU as a microprocessor taught by Bosch. This was presented as a predictable design choice to improve Gratz's system by using a known, cost-effective, and space-saving component for a high-volume automotive application.
    • Expectation of Success: A POSA would have a high expectation of success because implementing a known control system's CPU with a standard microprocessor was a routine practice in the automotive industry.

Ground 2: Claims 6-7, 12-14, and 20-21 are obvious over Gratz, Bosch, and Rector.

  • Prior Art Relied Upon: Gratz (Application # 2008/0245598), Bosch (Automotive Handbook, 6th Ed., 2004), and Rector (Application # 2011/0137520).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Gratz and Bosch by adding the teachings of Rector. Petitioner argued Rector addressed the same problem of teenage-driver safety and disclosed a system that, in addition to parent-set restrictions, allowed for driver-created "personal settings" to be stored in a user's account. These personal settings included seat position, mirror positions, and pre-set radio stations. This combination was alleged to teach the limitations of the dependent claims, which require the user account to comprise "personal settings of the vehicle occupant" (claim 6) and specify those settings (claim 7).
    • Motivation to Combine: A POSA would be motivated to add the personal settings taught by Rector to the restriction profiles of Gratz to further customize the vehicle and improve both driver experience and safety. For example, automatically adjusting the seat and radio presets upon driver authentication would reduce distractions. Rector's direct approach to limiting radio volume was also argued to be a clear improvement over Gratz's indirect method.
    • Expectation of Success: Combining these features was argued to be a predictable software modification, requiring only the addition of data fields to Gratz's existing profile database to store the personal settings taught by Rector.

Ground 3: Claims 1-4, 6-11, 14-18, and 20 are obvious over Moinzadeh.

  • Prior Art Relied Upon: Moinzadeh (Application # 2011/0093153).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Moinzadeh, by itself, rendered the claims obvious. Moinzadeh disclosed a vehicle system that controls how a mobile phone application can use the vehicle's head unit as an extended interface. The system used an "account" (comprising a subscriber database, an application whitelist, and a permissions mapping) to define rules for application access. These rules were based on the vehicle's operating state (e.g., stopped, moving below a certain speed, moving above that speed) and occupant location (e.g., passenger seat occupied). For instance, Moinzadeh taught disabling access to a video game application on the head unit's touch screen when the vehicle is moving but allowing a navigation application to remain visible.
    • Motivation to Combine: As this ground relied on a single reference, no motivation to combine was necessary. Petitioner asserted that Moinzadeh's disclosure of a microprocessor-based head unit that authenticates a user and applies rules from an account based on vehicle status directly mapped onto the elements of the challenged claims.

4. Key Claim Construction Positions

  • "rights and privileges": Petitioner argued this phrase, as used throughout the ’186 patent, should be construed to mean "permissions." This construction was based on the specification's interchangeable use of "rights," "privileges," and "rights and privileges" to describe what actions a user is or is not permitted to perform.
  • "at least one of an area and/or zone occupied by the vehicle occupant and an operating state of the vehicle": For the purpose of the IPR only, Petitioner adopted the Patent Owner's proposed construction from district court litigation, interpreting the phrase to mean at least one of (1) an area occupied by the occupant, (2) a zone occupied by the occupant, or (3) an operating state of the vehicle.
  • "and/or": Petitioner interpreted "and/or" as "or," consistent with the Patent Owner's position in related litigation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, asserting that the co-pending district court litigation was in a very early stage. It was noted that a trial would likely not occur until late 2027, long after a Final Written Decision (FWD) in the IPR would issue. Petitioner also noted that despite the ’186 patent issuing over nine years ago, the Patent Owner had not commercialized, marked, or otherwise asserted it until December 2023, giving Petitioner a settled expectation that it would not be asserted.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’186 patent as unpatentable.