PTAB

IPR2025-01600

Avidbots USA Corp v. Brain Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Autonomous Robot Navigation
  • Brief Description: The ’780 patent discloses a robot and methods for autonomous navigation. The system uses sensor data to generate a map, determines a route composed of poses, and applies simulated attractive and repulsive forces to points on those poses to adjust the route and avoid obstacles.

3. Grounds for Unpatentability

Ground 1: Obviousness over Beardsley and Castellanos

  • Claims Challenged: 1-20 are obvious over Beardsley in view of Castellanos.
  • Prior Art Relied Upon: Beardsley (Application # 2015/0284010) and Castellanos (a 1999 IEEE journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Beardsley taught an autonomous vehicle using a "potential field approach" with repulsive and attractive forces to navigate a pre-defined grid map with waypoints (route poses) for collision avoidance. However, Beardsley did not detail how the map was created. Petitioner asserted that Castellanos supplied this missing element by teaching a well-known SLAM (Simultaneous Localization and Mapping) method for automatically constructing a map from sensor data. The combination of Beardsley's force-based navigation on a route of waypoints and Castellanos's sensor-based map generation allegedly rendered all limitations of the independent claims obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to create a "complete navigation system." Petitioner contended that since Beardsley's navigation method required a map, a POSITA would have naturally looked to a known mapping solution like Castellanos to provide that map, thereby improving Beardsley's system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references address complementary sub-problems in autonomous robotics (navigation and mapping) and rely on sensor data, making their integration predictable.

Ground 2: Obviousness over Beardsley, Castellanos, and Khatib

  • Claims Challenged: 1-20 are obvious over Beardsley in view of Castellanos and Khatib.
  • Prior Art Relied Upon: Beardsley (Application # 2015/0284010), Castellanos (a 1999 IEEE journal article), and Khatib (a 1986 robotics journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground augmented Ground 1 by adding Khatib, a seminal 1986 paper on real-time obstacle avoidance using artificial potential fields. Petitioner argued that while Beardsley taught the general concept of forces, Khatib explicitly taught applying forces to a plurality of points on the robot (termed "Points Subjected to the Potential" or PSPs) to ensure protection of the entire robot body. This teaching directly mapped to claim limitations requiring the determination of forces on a "plurality of points of each route pose," a detail Petitioner argued was more explicitly disclosed in Khatib than in Beardsley.
    • Motivation to Combine: A POSITA would be motivated to incorporate Khatib's teachings into the Beardsley/Castellanos framework to create a more robust and reliable collision avoidance system. Using Khatib's multi-point force application provides a more granular method for accounting for a robot's complete footprint, a known challenge in the field. Khatib itself stated that its application to mobile robots was "straightforward."
    • Expectation of Success: The combination was asserted to be predictable, as all three references use potential field concepts and sensor data within the same technical field of robotics.

Ground 3: Obviousness over Yamamoto and Khatib

  • Claims Challenged: 1-20 are obvious over Yamamoto in view of Khatib.
  • Prior Art Relied Upon: Yamamoto (a 2008 journal article) and Khatib (a 1986 robotics journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Yamamoto disclosed a complete system that rendered the claims obvious. Yamamoto described an autonomous indoor robot that expressly used Khatib's potential field method for obstacle avoidance and a Voronoi diagram approach for map creation and path planning. Yamamoto's system generated a map from sensor data, determined a path using reference points and sub-goals (the claimed "route poses"), and calculated attractive and repulsive forces based on Khatib's method to navigate a collision-free path.
    • Motivation to Combine: The motivation was inherent, as Yamamoto explicitly cited and integrated Khatib's potential field technique into its own system. A POSITA implementing Yamamoto's design would be directly led to Khatib for the underlying principles of force calculation, including the application of forces to multiple points on the robot to ensure its protection.
    • Expectation of Success: A POSITA would have a very high expectation of success, as Yamamoto reported successfully experimenting with a real robot using the very techniques described, demonstrating the viability of combining these methods.
  • Additional Grounds: Petitioner asserted that claim 8 is obvious over Yamamoto in view of Khatib and Beardsley, arguing a POSITA would have been motivated to modify Yamamoto's indoor robot to include the floor cleaner taught by Beardsley.

4. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-20 of the ’780 patent as unpatentable.