PTAB

IPR2026-00156

Google LLC v. Gamba Group Holdings LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Location-Based Services
  • Brief Description: The ’193 patent describes methods for assisting a user in locating their parked vehicle. The challenged claims relate to a method where a Bluetooth transceiver integrated within a vehicle transmits the vehicle's location to a mobile device, which then provides navigation back to that location.

3. Grounds for Unpatentability

Ground 1: Anticipation by Baese - Claims 12, 13, and 15-18 are anticipated under 35 U.S.C. §102 by Baese.

  • Prior Art Relied Upon: Baese (Application # 2002/0082025).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Baese discloses every element of the challenged claims. Baese describes a "Return to Parking" application where a vehicle determines its position using GPS and/or other sensors. This location data is then transmitted via a Bluetooth link from a vehicle-mounted transmitter to the user's mobile device ("mobile radio terminal"). The mobile device stores this "exact parking space location" and subsequently provides navigation, including maps and directional instructions, to guide the user back to the vehicle. This disclosure was asserted to meet all limitations of independent claim 12 and the additional limitations of dependent claims 13 and 15-18, which add displaying a map and using GPS to register the location.

Ground 2: Anticipation by Phillips - Claims 12, 13, and 15-18 are anticipated under 35 U.S.C. §102 by Phillips.

  • Prior Art Relied Upon: Phillips (Application # 2003/0055560).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Phillips also discloses all claimed elements. Phillips teaches a system where a vehicle determines its location via GPS upon an event like the engine shutting off. A communication module in the vehicle, which can operate according to Bluetooth protocols, transmits the location to a user's mobile terminal. The terminal stores ("registers") the location in memory. To find the car, the user activates the system, and the terminal displays navigation information—such as a map overlay or a directional pointer with distance—to guide the user from their current location to the vehicle's saved location. This was argued to satisfy all limitations of the challenged claims.

Ground 3: Obviousness over Phillips and Soliman - Claims 12, 13, and 15-18 are obvious over Phillips in view of Soliman.

  • Prior Art Relied Upon: Phillips (Application # 2003/0055560) and Soliman (Patent 6,081,229).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner relied on Phillips for nearly all claim elements, as described in Ground 2. Soliman was introduced to supplement the teaching of determining an "exact parking space location," particularly in environments with poor GPS reception. Soliman discloses a system that merges GPS data with wireless communication technologies to achieve a "precise position location" in dense urban areas where line-of-sight to satellites is obscured, using as few as two or three satellites.
    • Motivation to Combine: Petitioner argued a POSITA would be explicitly motivated to combine these references because Phillips itself incorporates Soliman by reference. Phillips states that "various aspects of the present disclosure may be configured to allow the position of a mobile unit to [be] identified using a minimum number of GPS satellites" and then cites Soliman as a useful method for achieving this.
    • Expectation of Success: A POSITA would have a high expectation of success because Phillips expressly suggests the combination. Furthermore, both Phillips and Soliman were assigned to the same entity (Qualcomm), indicating that the assignee recognized the compatibility and desirability of combining these technologies to improve location accuracy in challenging environments.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Baese alone and Phillips alone, relying on the same evidence presented for the anticipation grounds.

4. Key Claim Construction Positions

  • "exact parking space location": Petitioner did not propose a formal construction for any term. However, it argued that the claim term "exact parking space location" must be interpreted in light of the accuracy disclosed in the prior art. Petitioner contended that references like Baese and Phillips, which can locate a vehicle to within 6-10 feet using GPS and other sensors, meet the "exact" limitation, especially since the ’193 patent's own specification alleges a similar accuracy for its preferred (non-GPS) embodiment.

5. Key Technical Contentions (Beyond Claim Construction)

  • Specification-Claim Contradiction: A central contention was that the challenged claims, which require or encompass using GPS, are directly contradicted by the ’193 patent’s specification. Petitioner highlighted that the specification repeatedly and extensively disparages GPS for its perceived limitations, such as inaccuracy (50-200 feet), unavailability indoors, and signal acquisition time. The specification states that a "main object of the present invention" is to provide navigation "without the need for any Global Positioning System (GPS) communication" and that its RF beacon system "replace[s] the satellite in the GPS based system." Petitioner argued that the patent owner improperly added GPS-based claims late in prosecution that lack written description support and contradict the patent's core disclosure.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 12, 13, and 15-18 of the ’193 patent as unpatentable.