PTAB

IPR2026-00171

Ford Motor Co v. AutoConnect Holdings LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Infotainment System for Persona-Based Assistance
  • Brief Description: The ’239 patent is directed to methods and systems for maintaining a "persona" of a vehicle occupant and, based on that persona and vehicle-related information, automatically performing an action to assist the occupant.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sundaram

  • Claims: 1-2, 5, 7-10, 12, 14-16, 19, 21-22, 30, 34-35 are obvious over Sundaram.
  • Prior Art Relied Upon: Sundaram (Application # US2011/0106375).
  • Core Argument for this Ground: Petitioner argued that Sundaram, a single prior art reference, discloses all limitations of the challenged claims. Sundaram teaches an in-vehicle computer that personalizes vehicle behavior according to a user’s needs and requirements by identifying the user and activating a corresponding profile.
    • Prior Art Mapping: Petitioner asserted that Sundaram’s disclosure of an in-vehicle computer that builds and maintains a "user's usage profile" based on biometric data (e.g., fingerprints, weight, height) and user data (e.g., favorite music) directly teaches the claimed limitation of maintaining a "persona." Sundaram’s system also determines "vehicle-related information" by using various sensors to monitor vehicle speed, location via GPS, and environmental states like road conditions. Finally, Petitioner argued that Sundaram teaches performing an automated "action assisting the selected vehicle occupant" by providing alerts when a user exceeds a preset speed limit or when a camera detects a "sleepy-eyed" driver, which constitutes a "reminder" or "notification" that is not based on a preceding user request.
    • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

Ground 2: Obviousness over Sundaram and Penilla

  • Claims: 13, 20, 23-28, and 31-33 are obvious over the combination of Sundaram and Penilla.
  • Prior Art Relied Upon: Sundaram (Application # US2011/0106375), Penilla (Patent 9,285,944).
  • Core Argument for this Ground: Petitioner contended that Sundaram provides the foundational personalized vehicle system, and Penilla supplies the missing teachings related to synchronizing a user profile with external sources and across different vehicles.
    • Prior Art Mapping: Penilla was cited for its disclosure of synchronizing a user's portable devices (phone, smartwatch) with an in-vehicle computer, including for applications like an electronic calendar. Critically, Penilla teaches performing data transfers "when the vehicle is off" to conserve fuel. Penilla also explicitly discloses transferring a "custom configuration" from vehicle to vehicle, including between different manufacturers (e.g., "Brand X" and "Brand Y") and for a defined "rental period," mapping directly to claim limitations requiring persona portability and use in rental cars.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sundaram's personalization features with Penilla's synchronization and portability capabilities to create a more robust and convenient system. This combination would yield predictable benefits, such as allowing users to maintain a consistent profile across multiple vehicles (including rentals) and performing data transfers efficiently (with the ignition off) to save fuel.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success, as both references operate in the same field of vehicle interface customization and the combination would involve a predictable software modification to Sundaram's existing platform.

Ground 3: Obviousness over Sundaram and Gruber

  • Claims: 4 and 18 are obvious over the combination of Sundaram and Gruber.
  • Prior Art Relied Upon: Sundaram (Application # US2011/0106375), Gruber (Application # 2012/0016678).
  • Core Argument for this Ground: Petitioner argued that Sundaram’s system of providing alerts would have been rendered obvious by combining it with Gruber’s teachings of an intelligent automated assistant that uses customizable voice and graphical representations.
    • Prior Art Mapping: Gruber discloses an in-vehicle intelligent assistant that delivers personalized outputs, including synthesized speech, sampled speech, and recorded messages, and can dynamically render these outputs in different voices based on user preferences. Petitioner argued this directly teaches the claim limitations requiring an action to be performed by an "avatar" that is a "voice representation" of a selected character and allowing "different vehicle occupants [to] have different avatars."
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to integrate Gruber’s assistant as an application onto Sundaram’s platform to provide more effective and personalized alerts. This would satisfy market demand for customization and improve user attentiveness compared to generic system alerts.
    • Expectation of Success (for §103 grounds): Because Sundaram's system is disclosed as a platform capable of running various applications, integrating Gruber’s assistant would be a straightforward and predictable software modification with a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Sundaram with Rork (for claims related to sensing other occupants, e.g., child seats), Sundaram with Vasa (for claims related to translating external signage), and three-reference combinations (e.g., Sundaram, Gruber, and Penilla) to address other specific claim limitations.

4. Key Claim Construction Positions

  • Petitioner proposed interpreting the term "and/or," which appears in numerous challenged claims, as "or" for the purposes of the IPR petition.
  • This construction was adopted from the Patent Owner's position in related district court litigation. Petitioner noted that it had challenged the term as indefinite in the parallel litigation because the ’239 patent’s specification provides conflicting definitions, describing "and/or" as being both disjunctive and conjunctive.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. It stated that the parallel district court litigation is in its earliest procedural stages. The trial is scheduled for October 2027, which is long after a final written decision in this IPR would be due, mitigating concerns of inefficient parallel proceedings.

6. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-35 of the ’239 patent as unpatentable under 35 U.S.C. §103.