PTAB

IPR2026-00034

Samsara Inc v. Motive Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Camera Initialization for Lane Detection and Distance Estimation using Single-View Geometry
  • Brief Description: The ’276 patent describes a network-based system for calibrating vehicle-mounted cameras. The system receives video images of a roadway, identifies features like horizon and lane lines, overlays these lines on the image, and computes camera parameters. The patent also discloses a process for a remote user to modify the overlaid lines, with the system then recomputing the parameters and sending them back to the vehicle.

3. Grounds for Unpatentability

Ground 1: Obviousness over Choe - Claims 1-3, 5-10, 12-16, and 18-20 are obvious over Choe.

  • Prior Art Relied Upon: Choe (Application # 2020/0410704).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Choe teaches the entire workflow claimed in the ’276 patent. This includes capturing roadway images from a vehicle camera, detecting a horizon line, overlaying that line on the image, allowing a user to modify the line’s position, computing camera calibration parameters (e.g., pitch) based on the modified line, and transmitting the updated parameters back to the vehicle’s camera system. Choe discloses both local, in-vehicle calibration and a client-server architecture for performing calibration remotely.
    • Motivation to Combine (for §103 grounds): This ground asserted that all claim elements are found within Choe. For claim elements related to transmitting an overlaid image to a remote server for modification, Petitioner argued that Choe discloses all the necessary components for such a system. A person of ordinary skill in the art (POSITA) would have found it a simple and predictable design choice to allocate the disclosed user-adjustment functionality to Choe's remote server, which would necessarily involve transmitting the overlaid image to the server for context and receiving the modified line back.
    • Expectation of Success: Implementing the user-adjustment feature on Choe's disclosed server would be a routine allocation of functions within its existing client-server architecture, yielding predictable results with a high expectation of success.

Ground 2: Obviousness over Choe and Davies - Claims 1-3, 5-10, 12-16, and 18-20 are obvious over Choe in view of Davies.

  • Prior Art Relied Upon: Choe (Application # 2020/0410704) and Davies (Application # 2014/0240500).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on Choe for the foundational camera calibration workflow. To the extent Choe is found not to explicitly teach the transmission of overlaid images for remote user interaction, Davies was argued to supply this element. Davies discloses a bidirectional, networked system where captured images are sent to a remote operations base, an operator uses a GUI to adjust the imagery, and the processed output is returned to update local parameters.
    • Motivation to Combine: A POSITA seeking to implement the remote calibration system suggested in Choe would look to references like Davies for established methods of transmitting and remotely editing vehicle-based imagery. Davies provides an explicit blueprint for the bidirectional data flow that Choe's remote calibration system requires. A POSITA would combine the references to achieve well-known benefits such as verification consistency (allowing a remote operator to see what the vehicle sees), computational offload, and fleet-wide quality assurance.
    • Expectation of Success: The combination was presented as predictable because both references address camera systems in distributed environments. Applying Davies’s conventional network transport and remote GUI workflow to Choe’s calibration logic would involve using known elements for their intended purposes.

Ground 3: Obviousness over Westmacot and Tal - Claims 1-20 are obvious over Westmacot in view of Tal.

  • Prior Art Relied Upon: Westmacot (WO 2019/175286) and Tal (Application # 2022/0019829).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Westmacot teaches a local road-annotation and camera calibration system that performs the core steps of the ’276 patent: capturing images, overlaying horizon and lane lines, allowing user modification of those lines, and recalculating camera parameters. However, Westmacot does not explicitly teach transmitting these annotated images or recalculated parameters over a network. Tal was argued to fill this gap by disclosing a bidirectional, networked pipeline for exchanging raw and processed imagery, including overlays, between a vehicle and a remote server for analysis, feedback, and further processing.
    • Motivation to Combine: A POSITA would have been motivated to combine Westmacot’s powerful local annotation and calibration engine with Tal’s robust networked pipeline. This combination would predictably enhance the scalability of Westmacot’s system, enabling distributed processing, remote collaborative annotation, and consistent calibration across a fleet of vehicles—goals consistent with Westmacot's focus on generating scalable training data.
    • Expectation of Success: Both references operate in the same field of autonomous vehicle image processing and are complementary. Using Tal's established network architecture to enable remote access and refinement of the annotated data generated by Westmacot's system would be a predictable integration of known technologies with a reasonable expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 4, 11, and 17 based on combining Choe (or Choe and Davies) with Kuehnle (WO 2009/027090). Kuehnle was cited for its teaching of conditioning calibration updates on the vehicle traveling above a predefined speed or for a predefined duration to ensure stable driving conditions and improve accuracy.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 12,136,276 as unpatentable.