Avidbots USA Corp v. Brain Corp

1. Case Identification

• Case #: IPR2025-01601
• Patent #: 10,379,539
• Filed: December 1, 2025
• Petitioner(s): Avidbots Corp. and Avidbots USA Corp.
• Patent Owner(s): Brain Corporation
• Challenged Claims: 1-20

2. Patent Overview

• Title: Dynamic Navigation and Route Planning of a Robot
• Brief Description: The ’539 patent relates to a system and methods for autonomous robot navigation. The technology involves using sensor data to generate a map of an environment, determining a route on that map, and then computing simulated repulsive forces from detected objects to dynamically guide the robot along a collision-free path.

3. Grounds for Unpatentability

Ground 1: Obviousness over Beardsley and Castellanos - Claims 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 on probabilistic mapping).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Beardsley taught the core elements of an autonomous robot that uses a "potential field" approach with repulsive forces for obstacle avoidance. Beardsley’s robot navigated along a pre-defined "grid map" composed of waypoints. However, Beardsley did not teach how this map was generated. Petitioner asserted that Castellanos, a well-known reference on Simultaneous Localization and Mapping (SLAM), supplied this missing element by teaching a method for the automatic construction of a map of the environment using sensor data.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Beardsley’s obstacle avoidance system with Castellanos’s map generation technique to create a complete and functional navigation system. Since Beardsley’s method required a map as a starting point, it would have been obvious to turn to a known and compatible SLAM method like that in Castellanos to generate it.
  • Expectation of Success: Both references operate in the same technical field of autonomous robotics and rely on sensor data, making their integration straightforward. The combination addressed complementary sub-problems—mapping and navigation—with a high and predictable likelihood of success.

Ground 2: Obviousness over Yamamoto and Khatib - Claims 1-20 are obvious over Yamamoto in view of Khatib.

• Prior Art Relied Upon: Yamamoto (a 2008 journal article on on-line path planning) and Khatib (a 1986 journal article on real-time obstacle avoidance).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Yamamoto disclosed a complete autonomous robot system for indoor environments that integrated path planning, map creation using a Voronoi diagram, and obstacle avoidance. Crucially, Yamamoto explicitly cited and implemented the potential field method taught by Khatib for its obstacle avoidance component. Khatib, a seminal paper in the field, provided the foundational teachings on using artificial potential fields with repulsive forces from obstacles to guide a robot manipulator.
  • Motivation to Combine: The motivation was inherent, as Yamamoto expressly relied on Khatib’s technique. A POSITA implementing Yamamoto’s system would be directly led to the Khatib reference. The POSITA would then be motivated to apply Khatib’s more detailed disclosures, such as using multiple control points ("PSPs") on the robot to protect all of its parts, to enhance the collision avoidance capabilities of the Yamamoto robot.
  • Expectation of Success: A POSITA would have a high expectation of success because Yamamoto had already successfully experimented with and validated Khatib’s potential field approach, demonstrating the compatibility and effectiveness of the core techniques.

Ground 3: Obviousness over Beardsley, Castellanos, and Scholz - Claims 3, 10, and 16 are obvious over Beardsley in view of Castellanos and Scholz.

• Prior Art Relied Upon: Beardsley (Application # 2015/0284010), Castellanos (a 1999 IEEE journal article), and Scholz (a 2011 IEEE conference paper on navigation with moveable objects).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targeted claims requiring a robot footprint that is adjustable or dynamically reshaped based on the environment. Petitioner argued that while Beardsley and Castellanos provided the base navigation system, Scholz taught the specific claimed feature. Scholz disclosed a mobile robot that dynamically reshaped its effective footprint by using "articulated primitives" to reduce its size for executing tight turns in cluttered environments. Scholz also explicitly acknowledged that collision risk is dependent on footprint size.
  • Motivation to Combine: A POSITA would combine Scholz’s advanced footprint modeling with the Beardsley/Castellanos system as a predictable improvement for navigating in constrained spaces. This would provide a more sophisticated and effective implementation of the adjustable "active area" concept already present in Beardsley, thereby enhancing the robot's maneuverability and safety.
  • Expectation of Success: The combination involved applying a known technique for improved maneuverability in cluttered environments (Scholz) to a general-purpose navigation framework (Beardsley/Castellanos). This would have been a predictable and successful integration.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-20 based on Beardsley in view of Castellanos and Khatib, arguing Khatib’s teachings on applying repulsive forces to multiple points on a robot would have been an obvious way to improve the granularity and safety of the base system.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 10,379,539 as unpatentable.