PTAB

IPR2026-00059

Toyota Motor Corp v. Emerging Automotive LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle with Systems for Sharing and Monitoring
  • Brief Description: The ’245 patent discloses a system for providing vehicle access using electronic keys (e-keys). The system allows a vehicle owner or administrator to assign temporary, privilege-based access to other users via a mobile application, which communicates with a server and the vehicle's on-board computer to control vehicle functions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kleve and Mottla - Claims 1-8 and 11-18 are obvious over Kleve in view of Mottla.

  • Prior Art Relied Upon: Kleve (Application # 2014/0129053) and Mottla (Application # 2011/0060480).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kleve, which describes a short-term vehicle rental system using a server-generated, time-limited "virtual key" (e.g., a matrix barcode) sent to a user's mobile device, discloses nearly all limitations of independent claim 1. Kleve’s system includes an on-board computer, systems for unlocking and starting the vehicle, communications circuitry for server and mobile device interaction, and a dashboard camera for monitoring user actions during the rental period. Petitioner asserted that Mottla, which teaches a car-sharing system, provides the only missing element: a graphical user interface (GUI) on a mobile device for managing the e-key, including reserving a vehicle and viewing functions as icons.
    • Motivation to Combine: A POSITA would combine Kleve’s robust back-end rental system with Mottla’s user-friendly mobile GUI to improve the user experience. Both references are in the same field of electronic key systems for shared vehicles and address the same problem of controlling vehicle access. The combination would have been a predictable implementation of known technologies to create a more commercially appealing product.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination because implementing a standard GUI, as shown in Mottla, on a mobile application to control the functions already present in Kleve's system was well within the ordinary skill in the art at the time.

Ground 2: Obviousness over Kleve, Mottla, and Goudy - Claims 9-10 are obvious over Kleve and Mottla in view of Goudy.

  • Prior Art Relied Upon: Kleve (Application # 2014/0129053), Mottla (Application # 2011/0060480), and Goudy (Application # 2005/0038573).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the combination of Kleve and Mottla to address claims 9 and 10, which relate to limiting or disabling vehicle interfaces for safety. Petitioner argued Goudy teaches this exact concept, describing a system that disables infotainment device functions to reduce driver distraction and the probability of crashes.
    • Motivation to Combine: A POSITA developing the shared vehicle system of Kleve and Mottla would be motivated to incorporate Goudy's safety features. A vehicle owner would want to impose limitations on a temporary user, such as a young driver, to ensure safe operation. Disabling distracting interfaces, as taught by Goudy, is a logical and known method for improving vehicle safety, making its inclusion in a rental system an obvious improvement.
    • Expectation of Success: The combination would have been straightforward, as the base system of Kleve already included the hardware for monitoring vehicle usage and determining when a restriction should apply. Adding a software-based function to disable certain interfaces based on risk-level assessments would be a predictable modification.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, primarily by substituting Zaid (Application # 2011/0112969) as the primary reference for Kleve. Ground 3 argued claims 1-8 and 11-18 are obvious over Zaid in view of Kleve and Mottla, with Zaid providing the base car-sharing system and Kleve supplying the specific teaching of a camera for monitoring. Ground 4 argued claims 9-10 are obvious over Zaid, Kleve, and Mottla in view of Goudy, paralleling the logic of Ground 2.

4. Key Claim Construction Positions

  • Petitioner noted that a District Court construed the term "electronic key”/"eKey”/"e-key” as "electronic data that enables one or more functions of the vehicle." Petitioner agreed with this construction and stated that no other terms required specific construction for the purposes of the IPR.

5. Key Technical Contentions

  • Priority Date Challenge: A central contention is that the ’245 patent is not entitled to a priority date earlier than October 25, 2013. Petitioner argued that the parent applications filed before this date do not provide written description support for the claimed "electronic keys" or "e-keys." Because this subject matter was first introduced in a continuation-in-part application filed on that date, Petitioner asserted that Kleve (filed in 2012) qualifies as prior art under 35 U.S.C. §102.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 11,104,245 as unpatentable.