PTAB

IPR2025-01603

Avidbots USA Corp v. Brain Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Robotic Mapping and Navigation
  • Brief Description: The ’576 patent discloses systems and methods for an autonomous robot to generate a graphical map of an environment while simultaneously navigating through it. The system creates a map from a graph of nodes, where each node represents an estimated position and includes a confidence-based range of uncertainty, which can be refined using techniques like loop closure.

3. Grounds for Unpatentability

Ground 1: Claims 1-36 are anticipated by Olson under 35 U.S.C. §102.

  • Prior Art Relied Upon: Olson (a 2008 Ph.D thesis from MIT titled "Robust and Efficient Robotic Mapping").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Olson, a foundational text on graph-based Simultaneous Localization and Mapping (SLAM) optimization, discloses every element of the challenged claims. Olson described a robot that generates a map from a graph of nodes (poses) based on sensor data. Critically, Olson taught that its system maintains an error estimate and "confidence of each individual node," which is used in its optimization algorithm. Petitioner asserted this directly corresponds to the ’576 patent's key limitation of a "range... based on confidence measure at a respective node," the very feature added during prosecution to overcome prior art rejections and secure allowance. Olson was also alleged to disclose real-time map generation, loop closure to reduce uncertainty, and associating robot actions with locations on the map.
    • Key Aspects: Petitioner contended the examiner erred by being assigned to a generic art unit and thus failing to consider fundamental prior art like Olson, which allegedly demonstrates the purportedly novel features were standard in the field of robotic mapping well before the patent's priority date.

Ground 2: Claims 1-11, 13-23, and 25-36 are anticipated by Stachniss under 35 U.S.C. §102.

  • Prior Art Relied Upon: Stachniss ("Springer Handbook of Robotics (2d ed.): Simultaneous localization and mapping," 2016).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Stachniss, a comprehensive review of SLAM techniques, also teaches all limitations of the challenged claims (excluding the cleaning-specific claims 12, 24, and 36). Stachniss explicitly described graph-based SLAM where robot locations and landmarks are treated as nodes in a graph. Petitioner argued that Stachniss teaches that each node has an associated uncertainty, often represented as a probability distribution (e.g., a Gaussian function), which directly corresponds to the claimed "range." Stachniss provided figures showing these uncertainty ellipses, which grow and shrink based on proximity to known landmarks, illustrating the claimed variable range based on confidence. Stachniss further described online, real-time mapping where the map is generated concurrently with data collection.

Ground 3: Claims 1-36 are obvious over Stachniss in view of Prassler under 35 U.S.C. §103.

  • Prior Art Relied Upon: Stachniss ("Springer Handbook of Robotics (2d ed.): Simultaneous localization and mapping," 2016) and Prassler ("Springer Handbook of Robotics (2d ed.): Domestic Robots," 2016).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent Stachniss does not anticipate all claims, the combination with Prassler renders them obvious. Stachniss was argued to provide the foundational SLAM system with confidence-based ranges for each node, as detailed in Ground 2. Prassler, a chapter from the same comprehensive robotics handbook, reviewed the history and technology of autonomous cleaning robots (e.g., Roomba). Prassler explicitly taught that numerous manufacturers had already implemented SLAM techniques in commercial cleaners to enable systematic and efficient operation. Prassler disclosed robots with the specific cleaning functions recited in the dependent claims (brushes, vacuums, water flow) and the ability to selectively activate those functions.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Stachniss's advanced SLAM methods with Prassler's known cleaning robots to improve cleaning efficiency and coverage, a known industry problem that Prassler identified SLAM as a solution for. The fact that both references appeared as complementary chapters in the same authoritative handbook on robotics would have prompted a POSITA to consider their combined application.
    • Expectation of Success: A POSITA would have a high expectation of success, as Prassler explicitly documented that other manufacturers had already successfully and economically combined SLAM techniques with the exact cleaning functions at issue. The integration was a known and proven solution in the art.
  • Additional Grounds: Petitioner asserted additional obviousness challenges over Olson or Stachniss in combination with Fong (Patent 9,538,892) to teach features such as using fiducial markers for a home locator and docking station.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-36 of Patent 10,823,576 as unpatentable.