PTAB
PGR2025-00041
Toyota Motor Corp v. AutoConnect Holdings LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: PGR2025-00041
- Patent #: 12,039,243
- Filed: April 7, 2025
- Petitioner(s): Toyota Motor Corp.
- Patent Owner(s): AutoConnect Holdings LLC
- Challenged Claims: 1-20
2. Patent Overview
- Title: System for Accessing and Updating Vehicle User Profiles
- Brief Description: The ’243 patent discloses a system for managing user profiles that govern vehicle functions. The system receives a request to access a profile stored at the vehicle, performs a verification or authentication process, and, upon authorization, creates an updated user profile based on requested modifications.
3. Grounds for Unpatentability
Ground 1: Patent Ineligibility under §101 - Claims 1-20
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that all challenged claims are directed to the patent-ineligible abstract idea of accessing and updating information. The claims recite functional steps of receiving a request, determining authorization, determining modifications, and creating an updated profile. Petitioner contended these are mental processes or methods of organizing human activity that could be performed with pen and paper. The claims invoke only generic and conventional computer components (e.g., memory, processors) to perform these abstract functions in the known environment of a vehicle, which is insufficient to confer patent eligibility.
- Key Aspects: Petitioner asserted that under the Alice two-step test, the claims fail at both steps. At step one, they are directed to an abstract idea. At step two, they lack an inventive concept because they merely apply the abstract idea using well-understood, routine, and conventional computer technology without improving the functioning of the computer itself. The patent’s specification admits to using known processors, memory, and authentication techniques.
Ground 2: Obviousness over Hendry in view of Poulsen - Claims 2-7 and 12-17
- Prior Art Relied Upon: Hendry (Application # 2012/0303178) and Poulsen (Application # 2007/0276795).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Hendry discloses the core system of claim 1, including receiving a request from an external device to access a user profile stored in a vehicle, authenticating the device/user, and updating vehicle settings. Poulsen was argued to supply the limitations of dependent claims 2-5, specifically teaching the transmission of an updated user profile to an external location (e.g., a database or remote server) and providing a process for determining and resolving conflicts between the updated profile and a previously stored local profile.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Hendry’s in-vehicle profile system with Poulsen’s remote storage and conflict resolution features. The motivation would be to enhance user convenience by allowing profiles to be backed up, remotely updated, and shared across multiple vehicles, thus eliminating the need to manually configure settings in each new vehicle. Both references address the same problem of managing user preferences for vehicle settings.
- Expectation of Success: A POSITA would have a high expectation of success, as the combination involves integrating known data management techniques (profile sharing and synchronization from Poulsen) with a known vehicle system (Hendry) using conventional communication and processing technologies.
Ground 3: Obviousness over Singh in view of Rovik - Claims 9-10 and 19-20
Prior Art Relied Upon: Singh (Application # 2007/0255464) and Rovik (Patent 8,918,231).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Singh discloses the base system of claim 1, teaching an "intelligent vehicle" that authenticates drivers using multi-factor methods (e.g., passwords and fingerprints) and loads customized settings from a user profile. Rovik was cited to teach the "template" limitations of claims 9 and 10. Specifically, Rovik discloses storing user settings at a remote server for use across vehicles of different makes and models, using user profiles with common setting options and a common organization (i.e., a template format) that can be standardized.
- Motivation to Combine: A POSITA would be motivated to apply Rovik’s standardized, template-based profile architecture to Singh’s authenticated vehicle system. This combination would solve the problem of user profiles being limited to a single vehicle by creating a portable profile that could be used across different vehicles, including rental cars from different manufacturers, consistent with Rovik’s stated goals.
- Expectation of Success: Success would be expected because the combination merely involves applying a known data structure (Rovik’s templates for interoperability) to a known vehicle personalization system (Singh) to achieve the predictable benefit of profile portability.
Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 1, 6-8, 11, and 16-18 as obvious over Hendry alone; claims 1, 6-7, 11, and 16-17 as obvious over Singh alone; and other combinations including Singh in view of Cazanas and Forstall.
4. Relief Requested
- Petitioner requests institution of post-grant review and cancellation of claims 1-20 of the ’243 patent as unpatentable.
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