- Hanshow America Inc. / Hanshow Technology Co., Ltd. v. Ses-Imagotag GmbHSome claims unpatentablePTAB · May 14, 2025 · IPR2024-00188 · APJ Terrence W Mcmillin · IPR · Final written decision
Claims 1–10 and 12–15 are unpatentable as obvious over either asserted combination; claim 11 was not shown unpatentable under either ground.
RulingsFinal written decision- Skill levelSkill level board ownDecided for petitioner
“The only significant difference between the positions of Petitioner and Patent Owner is that Patent Owner would require that a skilled artisan have coursework or training or work experience in multimedia systems in addition to the other requirements. Otherwise, the positions of the parties are similar. Based upon this record and the qualifications on which the parties and their experts agree, we determine that a person of ordinary skill in the art to which the ’669 patent relates would have at least a Master of Science Degree (or higher degree) in an academic area emphasizing electrical engineering, computer engineering, or a similar technical Master’s Degree; or alternatively, a Bachelor’s Degree (or higher degree) in an academic area emphasizing electrical engineering, computer engineering, or an equivalent field with two or more years of work experience in a relevant field or relevant industry experience. However, our decision on obviousness is supported by either of the definitions offered by the parties.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededPlain and ordinary meaningOther
“Accordingly, we determine that no claim terms require express construction. See, e.g., Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . 4 Neither party argues lexicography or disavowal applies to any claim term. See generally Pet.; see generally PO Resp. that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))). We apply the plain and ordinary meaning to all the claim terms. To the extent it is necessary to address the meaning of any claim term in order to make a final determination whether or not any challenged claim is unpatentable based on the arguments and evidence presented, we address the meaning as part of our unpatentability analysis.” slip op. at 11
- Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble not limitingDecided for petitioner
“[1.0] A video playback system (1), comprising The Petitioner contends that the preamble of claim 1 is not limiting. Pet. 17 (“The preamble of claim 1 is not limiting because it merely states the purpose or intended use of the alleged invention. It does not define any of the claim limitations, which are set forth fully in the body of the claim (i.e., a video playback system).”). Nonetheless, Petitioner cites both Swafford and Masumoto and shows both cited references disclose video playback systems. Id. at 17–18. Patent Owner does not dispute Petitioner’s contention that the preamble is not limiting or dispute that the cited art discloses the preamble. See generally PO Resp. We determine that the preamble is not limiting but, if it were, the cited art has been shown to teach it. [1.1] a number of playback devices (6A, 6B) to playback a video on their” slip op. at 19
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“However, we do agree with Patent Owner that Petitioner’s contention that the cited combination of teachings is supported “because of the structural similarity between Swafford’s and Masumoto’s devices” (Pet. 54– 55) does not provide a motivation to combine. PO Resp, 47–48. The only structural similarity relied on by Petitioner in support of this argument is that Swafford and Masumoto both disclose use of LCDs. See Pet. 54–55. Petitioner provides an inadequate explanation as to how or why the use of LCDs which are a common form of video displays would motivate the combination of the relied-upon teachings. But, this deficiency does not undermine the persuasiveness of Petitioner’s overall showing of motivation to combine. After considering all the arguments and evidence offered by the parties, we determine that Petitioner shows that a person of ordinary skill in the art would have been motivated to combine the relied-upon teachings of Swafford and Masumoto with a reasonable expectation of success.” slip op. at 48
Patent outcomesUS 11,405,669 mixedClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,405,669 - Hum Industrial Technology, Inc. v. Amsted Rail Company, Inc.Some claims unpatentablePTAB · Aug 7, 2024 · IPR2023-00538 · APJ Kevin W Cherry · IPR · Final written decision
Claims 1, 5–10, 13–18, 20–22, 24, 31, and 32 are unpatentable; claims 2–4, 23, and 25–30 were not shown unpatentable. The revised motion to amend was granted in part and denied in part.
RulingsFinal written decision- PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend granted in partGranted in part
“d. Summary For the above reasons, we determine that Patent Owner has not shown” slip op. at 100
- ExcludeMotion to exclude, deniedOther
“IV. PATENT OWNER’S MOTION TO EXCLUDE Patent Owner seeks to exclude Exhibit 1034 and page 10 of the Reply” slip op. at 86
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed patent owner constructionDecided for patent owner
“A. “housing” Patent Owner proposes that we construe the term “housing” to mean” slip op. at 15
- Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusDecided for petitioner
“suggested to one skilled in the art, objective evidence of non-obviousness (“secondary considerations”) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Objective evidence of non-obviousness “may often be the most probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012) (citation omitted). For us to give substantial weight to objective evidence of nonobviousness, a proponent must establish a nexus between the evidence and the merits of the claimed invention. ClassCo, Inc., v. Apple, Inc., 838 F.3d 1214, 1220 (Fed. Cir. 2016). Nexus is a legally and factually sufficient connection between the objective evidence and the claimed invention, such that the objective evidence should be considered in determining non-” slip op. at 21
Patent outcomesUS 9,365,223 mixedClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,365,223 - TRW Automotive U.S. LLC v. Magna Electronics Inc.Some claims unpatentablePTAB · Nov 16, 2015 · IPR2014-01351 · APJ James P Calve · IPR · Final written decision
Claims 60, 61, 70–74, and 77 are unpatentable as obvious over Blank, Kakinami, and Schofield; the other challenged claims were not shown unpatentable.
RulingsFinal written decision- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“Dr. Nranian testifies that the proposed modification would require substantial reconstruction or a redesign of Blank or a change in the principle of operation. Ex. 2005 ¶¶ 106–110. Dr. Nranian does not elaborate on this opinion or explain what redesigns and reconstructions would be required. We find persuasive the testimony of Dr. Kazerooni that designing a housing to hold components therein is a basic engineering concept within the level of ordinary skill in the art, particularly in view of, and as evidenced by, the disclosures of Blank and Schofield. Ex. 1016 ¶¶ 21–23. Blank discloses that circuit board 150 may be configured for a supplemental vision system. Ex. 1005, 7:51–59. TRW proposes to use this principle of operation and include Kakinami’s camera with Blank’s module 26. Pet. Reply 15–17. As discussed above, Blank and Schofield disclose reconfiguration and redesign of accessory housings, both internally and externally, to accommodate a variety of different accessories. Ex. 1005, 3:8–11, 7:6–10; Ex. 1006, 9:24– 36. Kakinami also discloses mounting of video camera 20, which includes lens 14, video device 15, and signal processing unit 16. Ex. 1010, 2:15–26, Fig. 2a. Physical incorporation is not required to demonstrate obviousness. See In re Yamamoto, 740 F.2d at 1573.” slip op. at 25
- Skill levelSkill level petitioner adoptedOther
“sophistication of the technology, all as addressed herein, it is submitted that the person of ordinary skill in the art of the ’590 Patent at the time of the invention would have had at least the qualifications of or equivalent to either a undergraduate degree in electrical engineering or mechanical engineering with course work or research in automobile accessory systems with at least two years of work making automobile accessory systems. Ex. 1012 ¶ 30. This discussion appears in Dr. Kazerooni’s Declaration in a section entitled “LEVEL OF ORDINARY SKILL.” Ex. 1012 ¶¶ 29–30. This definition of a skilled artisan in paragraph 30 immediately precedes Dr. Kazerooni’s discussion of the “STATE OF THE ART IN THE RELEVANT TIMEFRAME.” See id. ¶¶ 31–48. This definition of a skilled artisan in paragraph 30 of Dr. Kazerooni’s Declaration matches TRW’s definition of a skilled artisan in the Petition and is cited as the basis of TRW’s definition of a skilled artisan. See Pet. 17 (citing Ex. 1012 ¶¶ 29–30); Ex. 1012 ¶ 30. Another definition of a skilled artisan appears in Dr. Kazerooni’s Declaration in a section entitled “SUMMARY OF OPINIONS.” Ex. 1012 ¶ 10. It is unclear what use, if any, is made of this definition. Accordingly, we understand TRW and Dr. Kazerooni to assert the same definition of a skilled artisan, which definition appears at page 17 of the Petition and paragraph 30 of Dr. Kazerooni’s Declaration. Dr. Kazerooni identifies November 4, 1999 as the priority date of the ’590 patent invention. Ex. 1012 ¶ 26. Magna does not dispute this date. PO Resp. 57. Dr. Kazerooni testifies to the level of ordinary skill at the time of the invention. Id. ¶ 30. Dr. Kazerooni provides a detailed discussion of the state of the art at the time of the invention by discussing the disclosures of Blank, Kakinami, Schofield, Carter, Anderson, and Klappenbach. Id. ¶¶ 31– 48. These references were filed and issued before November 4, 1999. TRW” slip op. at 32
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“We interpret “bus communication” as “information transferred over a set of signal lines between devices connected to the signal lines.” We are not persuaded that a bus must include an interface. The IEEE Standard 969 Interface Devices (Ex. 1004) defines a bus in that context. The’590 patent discloses a CAN bus without disclosing an interface. Ex. 1002, 4:15–17. An ordinary meaning of “bus” includes “[a] set of signal lines to which a number of devices are connected and over which information is transferred between them.” See ANSI/IEEE Standard 1196-1987 IEEE Standard for a Simple 32-Bit Backplane Bus: NuBus (Ex. 3001).” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for petitioner
“We construe “cluster of individual sensors” as “a group of individual sensors or components of individual sensors positioned close together.” Pet. 6–7; Prelim. Resp. 11–12. This interpretation is consistent with an ordinary meaning of “cluster” which includes “a group of things or people that are close together” (Pet. 6) and the claims, which recite “a cluster of individual sensors resides on or near said in-cabin surface of said windshield.” This interpretation is consistent with the ’590 patent specification, which discloses that housing 10 is divided by wall 16 into adjacent first and second compartments 18, 20. Ex. 1002, 3:29–31, Fig. 2. One embodiment contains rain sensor 26 in first compartment 18 and printed circuit board 30 bearing a compass sensor 30 in second compartment 20. Id. at 5:62–6:12, 7:52–55, Figs. 2, 8. The ’590 patent specification discloses that the housing may accommodate a plurality of electrical accessories. Id. at 6:42–44. The ’590 patent further discloses that component 30 “can be any of a number of sensors or circuits which can be made small enough to fit in the compartment 20.” Id. at 7:64–67 (emphasis added). Preferably, component 30 is provided as a unitary module received in compartment 20. Id. at 7:67– 8:1. An ordinary meaning of “any” is one or more. Thus, the ’590 patent specification discloses that component 30 may include more than one sensor.” slip op. at 9
Patent outcomesUS 8,513,590 mixedClaim construction§ 103 obviousnesscites KSRPatents in suitUS 8,513,590
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.