• Tesla, Inc. v. Iqar Inc.Some claims unpatentable
  PTAB · Jul 21, 2025 · IPR2024-00543 · APJ Sean P O’Hanlon · IPR · Final written decision

  Claims 1–7, 9–17, 19, and 20 are unpatentable as obvious; claims 8 and 18 were not shown unpatentable because Newstrom’s database was not shown to be remote.

  RulingsFinal written decision

  • Skill levelSkill level board ownDecided for petitioner

    “Patent Owner does not contest Dr. Morellas’s proposed definition or proffer a definition of its own. See generally PO Resp.; see also Ex. 2007 ¶ 43 (setting forth a substantially similar definition as Dr. Morellas). We find Dr. Morellas’s unopposed definition to be consistent with the problems and solutions disclosed in the patent and prior art of record, and adopt it as our own for purposes of this Decision. See, e.g., In re GPAC, 57 F.3d at 1579 (approving the determination of the level of ordinary skill in the art by appeal to the references of record).” slip op. at 8

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for patent owner

    “We disagree with Patent Owner’s assertion that claim 1 requires that a route from the vehicle’s current position to a final destination must be known. See PO Resp. 7. Initially, claim 1 does not recite “destination.” Instead, claim 1 recites only “determining a segment of a vehicle route.” Ex. 1001, 27:44 (emphasis added). Nor does the ’399 patent specification require the interpretation proffered by Patent Owner. Notably, the ’399 patent discloses that the power management device may rely on historical route information to optimize the energy used to travel each segment of a route. Ex. 1001, 17:39–43, 17:64–67. Such reliance on historical data beneficially reduces the amount of required computing power. Id. at 18:5–9. Under this approach, “the location of the vehicle is periodically determined” and “used to determine[] a historical segment corresponding to the current location.” Id. at 18:30–33 (emphasis added). If the vehicle has moved into a new route segment, the historical data is queried to determine the most efficient speed to travel for the current segment. Id. at 18:39–56. Thus, the ’399 patent explicitly discloses calculating and applying power to a vehicle based on the route segment in which the vehicle is currently traveling. See id. at 18:64–67 (“The flowchart shown in FIG. 5 illustrates a continuous process, in which the power management device can determine a probable optimal speed as the current segment changes (e.g., as the vehicle moves).”), Fig. 5. Furthermore, the ’399 patent explains that “[t]he route used by the power management device typically includes a starting position . . . , an ending position, . . . , and any intermediate positions between the initial and the final positions.” Id. at 14:6–10 (emphasis added). Notably, the ’399 patent sometimes refers to the “entire route,” indicating that use of “route” in the claims does not necessarily mean the entire route. Indeed, the ’399 patent explains that, “[i]n some variations, the entire route (or the entire predicted route) may be divided up into N segments” and “[i]n some variations, probable optimal speeds may be identified for the entire route.” Ex. 1001, 14:38–39, 19:1–2 (emphases added). This strongly suggests that, in some other variations, the entire route is not divided into segments and optimal speeds are not identified for the entire route, further indicating that the recited “route” is not the entire path the vehicle will take. Therefore, we find that the ’399 patent contemplates routes that, although not typical, do not include an ending position. Moreover, to the extent a destination is required, the ’399 patent discloses that the destination can be derived based on the vehicle’s location or driving history, and there can be multiple “likely destinations” and the system can “continuously infer the vehicle’s destination” and the probable destination “may constantly change to revise the destination” while the vehicle is traveling along the route. Ex. 1001, 12:16–59. Contrary to Patent Owner’s arguments, neither the claim language nor the specification of the ’399 patent requires the route be predetermined or extend from the vehicle’s current position to a final destination.” slip op. at 16

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “have been obvious in view of Hongo, Obradovich, and Niki. Pet. 4–62. In support of its showing, Petitioner relies upon the Morellas Declaration. Id. (citing Ex. 1003). We have reviewed the parties’ briefs and the evidence of record and determine that, for the reasons explained below, Petitioner has shown, by a preponderance of the evidence, that claims 1, 2, 5, 6, 9–12, 15, 16, 19, and 20 would have been obvious in view of Hongo, Obradovich, and Niki and that Petitioner has set forth reasoning with rational underpinning why it would have been obvious to combine the teachings of these references.” slip op. at 10

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner

    “limiting, Hongo and Niki support Petitioner’s contentions. We determine that Petitioner sets forth reasoning with rational underpinning as to why a person having ordinary skill in the art would have combined the teachings of Hongo and Niki. See, e.g., Pet. 21–23 (arguing that the modification “would have involved choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success” and “Niki’s teachings and/or suggestions improve vehicle control in the Hongo vehicle”).” slip op. at 14

  Patent outcomesUS 10,882,399 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,882,399
• Tesla, Inc. v. Iqar Inc.All claims unpatentable
  PTAB · Jul 14, 2025 · IPR2024-00499 · APJ Brent M Dougal · IPR · Final written decision

  Claims 1–17 are unpatentable: claims 1–16 as obvious over Kudo-325 and Kudo-066, and claim 17 as obvious over those references and Tryon.

  RulingsFinal written decision

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner

    “Thus, for all of the above reasons, we decline to construe “data, regarding multiple route segments” to require the data include information regarding the route the vehicle traveled between the starting and end points of the route segment. Rather, this is but one example of the type of data included within the scope of the claim. We further make final our preliminary finding that the claim explicitly allows for data, regarding a route segment to be stored in the memory at “different points in time along a route segment.” We determine that no other terms need to be construed. See Realtime” slip op. at 7

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “regarding route segments because it does not identify “what occurred—or what path the vehicle traveled—between the different nodes in Kudo 325’s transition state data.” PO Resp. 9. However, we have rejected herein Patent Owner’s implicit claim construction argument that such additional information is required. Though the exact the path traveled between a starting and end point is data regarding a route segment, the starting and end points are also data regarding a route segment. As acknowledged by Patent Owner, Kudo 325’s transition state data includes the starting and end points of route segments, as well as “a list of (or pointers to) all other nodes to which the vehicle previously traveled from that node.” PO Resp. 9 (citing Ex. 1004 ¶ 93). After our review of the evidence and arguments, summarized above, we determine that Petitioner has shown by a preponderance of the evidence that the combination teaches or suggests “data, regarding multiple route segments,” and “data, regarding multiple sequences of route segments” as required by claim 1. d) Conclusion For the reasons discussed above, we determine that Petitioner has shown by a preponderance of the evidence that the combination of Kudo- 325 and Kudo-066 teaches or suggests claims 1, 15 and 16.” slip op. at 18

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundUnpatentable

    “be motivated to implement Kudo-325’s historical accumulation database at the server. Pet. 73, 68, 70. Petitioner argues that Kudo-325 teaches that “a part of the functions that a car navigation system has may be provided in a server on a network.” Id. at 68 (quoting Ex. 1004 ¶ 75). Petitioner further argues that doing so would beneficially allow remotely stored historical data to be accessible to multiple vehicles. Id. at 70 (citing Ex. 1003 ¶ 203). Petitioner argues that housing this information at the server is a known technique and would yield predictable results. Id. (citing Ex. 1003 ¶ 204). Petitioner argues that Kudo-325 teaches storing sensor data samples including historical data at the historical accumulation database. Pet. 73–74 (citing Ex. 1004 ¶¶ 14, 75, 78, 87–88, 90–92, 94, 96, Fig. 3; Ex. 1003 ¶¶ 218–220). Petitioner further argues that “a POSITA would have understood data in the history accumulation database (historical data) to be provided to the car navigation system (present said historical data to said device) to enable generation of transition state information.” Id. at 74 (citing Ex. 1003 ¶ 221).” slip op. at 21

  Patent outcomesUS 10,829,002 unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,829,002
• Toast, Inc v. Gratuity, LLCAll claims unpatentable
  PTAB · Mar 24, 2025 · IPR2023-01408 · APJ Cynthia L Murphy · IPR · Final written decision

  Claims 1–13 are unpatentable as obvious over Marshall, Marshall and Webb, Phillips and Marshall, or Phillips, Marshall, and Webb.

  RulingsFinal written decision

  • Skill levelSkill level patent owner adoptedDecided for patent owner

    “We agree with Patent Owner’s proposed definition of a POSITA, to the extent that it aligns with the level of skill portrayed by the ’050 Patent. As discussed above, the ’050 Patent does not does not provide one with any technical direction for making and using a multi-restaurant embodiment that avoids or solves calculation/extraction problems due to disparate client (e.g., restaurant) systems. The ’050 Patent also does not provide one with any technical direction for scaling up and/or transitioning to a cloud-based system. We infer from this that a POSITA would have the education and the experience enabling him/her to effectively and economically handle these tasks without technical direction, despite the problems associated therewith. Put another way, the actual application of these technical endeavors would not be beyond his/her skill. Although Petitioner provides a slightly different expression for the level of ordinary skill in the art (see Pet. 9–10), it substantively agrees with Patent Owner’s proposed level of skill and adopting Petitioner’s precise level of ordinary skill would not change our decision.” slip op. at 9

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner

    “Patent Owner presents several pages of argument about claim construction, but offers no proposed construction for any of the claim terms. See PO Resp. 11–18. “Petitioner maintains that no claim construction is necessary.” Pet. Resp. 4. We determine that no express claim construction is necessary for any claim terms. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (holding that only claim terms in controversy need to be construed, and only to the extent necessary to resolve the controversy (citing Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 10

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundUnpatentable

    “with a restaurant’s timeclock programs, time and attendance systems, and/or payroll processing systems. See Ex. 1004 ¶¶ 69, 108. Webb discloses that, in a restaurant setting, a POS system can be communicatively coupled to a time and attendance server. See Ex. 1006, Abstract, 24:51–60, Figs. 1A, 1B. Thus, Marshall and Webb describe similar and compatible systems in the same field of art—systems for tracking employee and sales information in the hospitality business. And Petitioner provides evidence that it would have been obvious to a POSITA to combine these teachings in the claimed manner. See Ex. 1002 ¶¶ 207–212. Patent Owner argues that Webb “does not cure the deficiencies” of Marshall. PO Resp. 41. However, as discussed above, we disagree with Patent Owner regarding Marshall’s deficiencies. Thus, Webb need not cure these alleged deficiencies in Marshall.10 Patent Owner does not otherwise contest Petitioner’s contention with respect to this asserted ground of unpatentability. Consequently, we conclude that, on the record before us, Petitioner has proven that claims 4–7, 9, and 11–13 would have been would have been obvious over Marshall and Webb. 10 Patent Owner also mentions that there is “simply no motivation to combine Marshall and Webb.” PO Sur-Reply 7; see also PO Resp. 42. But Patent Owner does not address the arguments and evidence set forth by Petitioner.” slip op. at 18

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “Patent Owner’s client-side-only arguments are overly focussed on the setup disclosed in Marshall’s Figure 3, and, in any event, do not coincide with Petitioner’s citations to Marshall. Petitioner points out in its Reply that Patent Owner (and its expert) fail to address Marshall’s multi-employer 8 The ’050 Patent lists a provisional application filed on September 4, 2012 as a related application. Ex. 1004, code (60). 9 Marshall discloses that “data transfer” can be “data transfer is performed via uploading and downloading via HyperText Transfer Protocol (‘HTTP’), Extensible Markup Language (‘XML’), and/or HTML as is known in the art.” Ex. 1004 ¶ 110. embodiment. See Pet. Reply 6. Petitioner also points out in its Reply that Patent Owner (and its expert) fail to address Marshall’s disclosure that the server executing the GrataSoft software can be separate (i.e., not co-located) with the POS server executing the Aloha software. Id. at 10. In Patent Owner’s Sur-Reply, these topics remained undiscussed. See PO Sur-Reply 1–6. Both aspects of Petitioner’s contentions support that Marshall’s system does disclose a gratuity management system that is separate and distinct from the client POS servers. Patent Owner argues that there would be problems “associated with calculations of gratuities based on client-specific information extracted from disparate, ad hoc client business systems.” PO Resp. 27–28; Ex. 2006 69–73. Patent Owner also argues that there would be “problems associated with scale-up and transitioning to a cloud-based system, and associated cost and security issue. PO Resp. 27; Ex. 2006 ¶¶ 87–91. However, as discussed above, the ’050 Patent portrays that a POSITA would have the education and experience enabling him/her to effectively handle the conversion of a singlerestaurant system to a multi-restaurant system; and to transition to a safe and secure cloud system in a cost/time effective manner. Thus, these problems would not detract from the obviousness of a multi-restaurant and/or cloud-based version of Marshall’s invention. Patent Owner does not otherwise contest Petitioner’s contention with respect to this asserted ground of unpatentability. Consequently, we conclude that, on the record before us, Petitioner has proven that claims 1–3, 8, and 10 would have been would have been obvious over Marshall.” slip op. at 16

  Patent outcomesUS 9,741,050 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,741,050
• Askeladden, L.L.C. v. Ohva, Inc.All claims unpatentable
  PTAB · Mar 10, 2025 · IPR2023-00921 · APJ Amee A Shah · IPR · Final written decision

  Claims 1–4 are unpatentable as obvious: claim 1 over Cho, Aaron, and Carpenter; claim 2 over those references and de Geer; claim 3 over Cho and Aaron; and claim 4 over Cho, Aaron, and de …

  RulingsFinal written decision

  • Disclosure Requirements (§112) › Written description (Ariad)Not entitled to earlier dateDecided for petitioner

    “application are similar, as indicated by the redline comparison of two provided as Exhibit 1015. Critically, however, the “Summary of the Invention” sections are completely different. Id. at 2–4. The question is whether one of ordinary skill in the art would have understood with reasonable clarity, without the benefit of the Summary added for the ’286 patent/’674 application, that the ՚030 application describes a smart telephone that executes coded instructions to “convert the analog variable voltage audio signal received at the microphone port to the transaction data as digital data.”” slip op. at 43

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner

    “Here, although the ’286 patent distinguishes “account data” from “transaction data” in the embodiment of Figure 11, the “transaction data” is submitted by the user to perform a series of banking transactions after manually entering a PIN code, whereas the “account data” is stored on the server, and the token information is accepted from the smart card’s 1001, 10:12–18, 10:30–35, 10:40–42, 11:21–22, 11:65–12:4, 12:22–36. Thus, the claimed “transaction data” that is “accepted . . . from an output interface of a transaction card” and “accepted . . . from a transaction card at an input interface of the card reader,” as recited in independent claims 1 and 3, comprises data stored on and read from a card, such as an ID number, password, authentication information, or session information, that can be used to facilitate a transaction. The evidence indicates that the claimed “transaction data” is distinct from the “transaction data B1-Bn” described in connection with the Figure 11 embodiment.” slip op. at 24

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “As discussed above in Section II.C, we construe the term “transaction data” as encompassing any data involved in a transaction, including account data. Again, we emphasize that claim 1 requires that the transaction data is accepted by the card reader from an output interface of the transaction card. Cho provides that card reader 230 reads a digital signal that includes account information of card 130 whereby the account information “may include at least one of an account number, a card expiration data, etc.” Ex. 1005, 5:54–58. We further agree with Petitioner that to the extent “transaction data” is for the purpose of conducting banking transactions, Cho’s account data of a credit card number and expiration date can perform that purpose. Patent Owner’s arguments that the transaction data cannot be “static” and that claim 1 requires “processing actual transaction-specific data” are not commensurate with the scope of the claim 1. The claim does not recite any limitations that the transaction data be dynamic or “not static,” nor does it recite any processing of the transaction data outside of using it to “facilitate transactions.” Petitioner has shown that Cho teaches the claimed transaction data.” slip op. at 55

  Patent outcomesUS 9,679,286 unpatentable
  Claim construction§ 103 obviousness§ 112 disclosurecites KSR · Graham
  Patents in suitUS 9,679,286
• Adb Safegate Sweden AB / Adb Safegate BV et al. v. Honeywell International Inc.All claims unpatentable
  PTAB · Feb 12, 2025 · PGR2023-00053 · APJ James P Calve · PGR · Final written decision

  Claims 1–20 are unpatentable under § 101; claims 1, 6–10, and 13–20 are also unpatentable over Berkmo, and claims 1–20 over Berkmo and Richman.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner asserts that a skilled artisan would have “held at least a degree in electrical engineering, computer engineering, computer science or a similar discipline, with at least two years of relevant industry or research experience, including experience designing, planning, or implementing sensor networks using LIDAR, radar and/or cameras and corresponding data analysis” and “[a]dditional work or research experience can substitute for less or different education, and vice versa.” Pet. 10 (citing Ex. 1003 ¶¶ 18– 23). Patent Owner does not dispute Petitioner’s definition of a person of ordinary skill in the art. PO Resp. 14. Having considered the record, we adopt Petitioner’s uncontested level of ordinary skill as articulated above. Petitioner’s description appears to be consistent with the prior art cited and the skill reflected in the Specification of the ’349 patent. See Okajima v. Bourdeau, 261 F.3d 1350, 1354–55 (Fed. Cir. 2001) (the applied prior art may reflect an appropriate level of skill).” slip op. at 8

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner

    “We reject Patent Owner’s interpretation because it limits the claims to an exemplary embodiment that “can, for example, provide the remaining distance and the horizontal deviation with respect to the center line of a path” (Ex. 1001, 10:8–11), and it reads limitations of that embodiment into the claims. Absent a lexicographic definition or a disavowal, such claim interpretations are not permissible. See Phillips, 415 F.3d at 1312, 1316 (claims are given their ordinary, customary meaning in the context of the entire patent and the specification absent a lexicographic definition or a disclaimer or disavowal of claim scope by the inventor); Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898, 906 (Fed. Cir. 2004) (“Even when the specification describes only a single embodiment, the claims of the patent will not be read restrictively unless the patentee has demonstrated a clear intention to limit the claim scope using ‘words or expressions of manifest exclusion or restriction.’”) (citation omitted). Patent Owner has not asserted a definition or a disclaimer to support its interpretation. PO Resp. 16–17. The parties agree that “directional guidance” includes “navigational instructions” and “maneuvering guidance information.” PO Resp. 16 (“the claims make clear that this guidance refers to the navigational instructions to be provided to the pilot guiding the airplane”), 17 (a skilled artisan “reading the challenged claims in light of the specification would understand that ‘directional guidance’ refers to navigational instructions including the horizontal deviation with respect to the center line of a path”); Reply 21 (Berkmo teaches providing “pilot maneuvering guidance information . . . for aiding a pilot of the approaching aircraft towards [a] parking position”); Pet. 54 (Berkmo provides maneuvering guidance information). We interpret “directional guidance” as navigational instructions and maneuvering guidance information. This interpretation is consistent with the claims, which do not recite features of “directional guidance,” much less a horizontal deviation with respect to a center line as Patent Owner asserts.” slip op. at 10

  • Patent Eligibility (§101) › Alice/Mayo step one — 'directed to'Step1 directed to exceptionUnpatentable

    “We agree with Petitioner that the merging recites mental processes because the algorithms described in the specification (Ex. 1001, 8:50–9:10) can be performed as mental processes. Pet. 20–22; Reply 9–11; Ex. 1044 ¶¶ 56–58; Elec. Power Grp., 830 F.3d at 1351–52, 1353–54 (receiving time stamped synchronized phasor measurements at different points of an electric power grid and analyzing and updating the measurements in real time using limits, sensitivities, and rates of change of dynamic stability metrics derived from voltages, power flows, phase angles, damping, and oscillation modes recite mental processes); id. at 1354 (analyzing data by mental steps or mathematical algorithms is an abstract mental process). Merging data by transforming and converting it from one format to another is an abstract idea. See AI Visualize, Inc. v Nuance Commc’ns, Inc., 97 F.4th 1371, 1379 (Fed. Cir. 2024) (“But ‘converting information from one format to another . . . is an abstract idea.’” (citation omitted); creating virtual views in real time by “creating the requested frames of the requested views from the volume visualization dataset” created a virtual view from the existing volume visualization dataset as “abstract data manipulation”); Hawk Tech. Sys., LLC v. Castle Retail, LLC, 60 F.4th 1349, 1357 (Fed. Cir. 2023) (the method receives, displays, converts, stores, and transmits digital video data using result-based functional language); FICEP Corp. v. Peddinghaus Corp., No. 2022-1590, 2023 WL 5346043, *3–4 (Fed. Cir. Aug. 21, 2023) (the focus of the advance is on automating the identification, extraction, and transfer of a 3D rendering of an object by a CAD design model including dimensions and intersection parameters without specifying how intersection parameter data was generated or used to create a design model and therefore encompasses a human deriving intersection parameters and adding this data to the design model for extraction); Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014) (“[A] process that employs mathematical algorithms to manipulate existing information to generate additional information is not patent eligible.”) (quoting Parker v Flook, 437 U.S. 584, 595 (1978) (“If a claim is directed essentially to a method of calculating, using a mathematical formula, even if the solution is for a specific purpose, the claimed method is nonstatutory.”)); MPEP § 2106.04(a)(2) (mathematical relationships include converting binary coded decimal numerals to pure binary numerals as did the claims in Gottschalk v. Benson, 409 U.S. 63, 71–72 (1972)); see also Tr. 22:24–25:23.” slip op. at 20

  • Patent Eligibility (§101) › Alice/Mayo step two — inventive conceptStep2 no inventive conceptUnpatentable

    “The ordered combination of elements recites no more than when the elements are considered individually and thus does not provide an inventive concept. We disagree with Patent Owner’s argument that “[w]hen considered individually or in combination with the other claimed elements, the reliance on this merged data from a camera and LIDAR/RADAR sensor is itself an inventive concept because it was not conventional and improves the technology of aircraft tracking and guidance.” PO Resp. 49–50. Merging data from two different sensors is part of the abstract idea and therefore cannot provide an inventive concept that makes that abstract idea patent eligible. See, e.g., BSG, 899 F.3d at 1291–92; Guidance at 56. “If a claim’s only ‘inventive concept’ is the application of an abstract idea using conventional and well-understood techniques, the claim has not been transformed into a patent-eligible application of an abstract idea.” BSG, 899 F.3d at 1290–91. “It has been clear since Alice that a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention ‘significantly more’ than that ineligible concept.” Id. at 1290. Even if merging camera and LIDAR/RADAR sensor data is treated as an additional element, the description of the point cloud process and iterated point cloud algorithm indicates Patent Owner did not invent or improve the merging process. Ex. 1001, 8:64–9:40; MPEP § 2106.05(d)I.2. (a generic description indicates that elements are conventional enough that no further description is needed to satisfy § 112(a)); see AI Visualize, 97 F.4th at 1379 (converting data from one format to another is an abstract idea); Adaptive Streaming Inc. v. Netflix, Inc., 836 F. App’x 900, 903 (Fed. Cir. 2020) (encoding and decoding image data and converting data formats are abstract ideas). Dr. Campbell and Mr. Wilson testify that merging data is known for detecting and tracking objects and navigation. Ex. 1044 ¶¶ 41–51, 56–59; Ex. 1003 ¶¶ 54–65, 81–87; Ex. 1045, 20:6–23:18. A “data fusion process” is not claimed, much less one of any particular features. See PO Resp. 50. Nor do the claims recite a non-conventional arrangement of sensors. See Ex. 1003 ¶¶ 42–67, 83; iLife, 839 F. App’x at 538 (because sensors for measuring static and dynamic acceleration were known, and claim 1 did not recite unconventional means for processing that data, sensing and processing the static and dynamic acceleration information using generic components did not transform the nature of claim 1 into patent eligible subject matter).” slip op. at 39

  Patent outcomesUS 11,538,349 unpatentable
  Claim construction§ 101 eligibility§ 102 anticipation§ 103 obviousnesscites Alice · Mayo · Enfish · Phillips · KSR · Graham
  Patents in suitUS 11,538,349
• Mercedes-Benz USA, LLC v. Yechezkal Evan SperoSome claims unpatentable
  PTAB · Jan 16, 2025 · IPR2023-01027 · APJ Aaron W Moore · IPR · Final written decision

  Claims 37–70 are unpatentable: claims 37–41, 47, 50–56, 58–59, 60–62, 64–65, and 70 as anticipated by Alden; the remaining challenged claims as obvious over Alden and the listed combinations.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “alleged invention “would have had an undergraduate degree in mechanical engineering, electrical engineering, automotive engineering, optical engineering, applied physics, computer science, or similar disciplines, along with two years of experience working with intelligent vehicle systems, automotive control systems, or lighting control systems” and that more education could compensate for less experience and vice versa. See Pet. 8–9 (citing Ex. 1003 ¶ 33). 3 PCT Patent App. Pub. No. WO 01/70538 A2 (Exhibit 1010). 4 PCT Patent App. Pub. No. WO 01/01038 (Exhibit 1006). 5 U.S. Patent No. 4,970,628 (Exhibit 1007). 6 U.S. Patent No. 6,144,158 (Exhibit 1008). 7 U.S Patent No. 6,049,749 (Exhibit 1009). 8 PCT Patent App. Pub. No. WO 02/04247 A1 (Exhibit 1011). Patent Owner “does not dispute Petitioner’s proposed skill level for a person of ordinary skill in the art” (PO Resp. 4), and, as we generally agree that it is consistent with the subject matter disclosed in the ’503 patent and the prior art, we adopt it for purposes of this decision. B.” slip op. at 9

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther

    “Claim Construction We construe claims using the standard that would be applied in a civil action under 35 U.S.C. § 282(b), giving terms their ordinary and customary meaning to one of ordinary skill in the art in view of the specification and prosecution history. See 37 C.F.R. § 42.100(b). The Petition asserts that all claim terms should be given their “ordinary and customary meaning.” See Pet. 8. Patent Owner also proposes that the claim terms be given their ordinary meaning, and identifies the “ordinary meaning” for the terms “identify,” “turn,” and “curve,” which we discuss in our analysis below. We otherwise find that that no express claim construction is necessary. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (explaining that construction is needed only for terms that are in dispute, and only as necessary to resolve the controversy). C.” slip op. at 10

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableNot shown unpatentableMixed

  Patent outcomesUS 10,894,503 mixed
  Claim construction§ 102 anticipation§ 103 obviousness
  Patents in suitUS 10,894,503
• Mercedes-Benz USA, LLC v. Yechezkal Evan SperoAll claims unpatentable
  PTAB · Jan 16, 2025 · IPR2023-01026 · APJ Aaron W Moore · IPR · Final written decision

  Claims 1–36 are unpatentable: claims 1–4, 7, 10–17, 19–23, 25–27, and 30–36 are anticipated by Alden; claims 5, 6, 8, and 9, and 28–29, are obvious over the stated combinations.

  RulingsFinal written decision

  • BurdenUnpatentable

    “III. CONCLUSION For the reasons given, Petitioner has met its burden of showing that claims 1–36 of U.S. Patent 10,894,503 B2 are unpatentable.12 The results are summarized below:” slip op. at 47

  • Skill levelSkill level petitioner adoptedOther

    “alleged invention “would have had an undergraduate degree in mechanical engineering, electrical engineering, automotive engineering, optical engineering, applied physics, computer science, or similar disciplines, along with two years of experience working with intelligent vehicle systems, automotive control systems, or lighting control systems” and that more education could compensate for less experience and vice versa. See Pet. 8–9 (citing Ex. 1003 ¶ 33). Patent Owner “does not dispute Petitioner’s proposed skill level for a person of ordinary skill in the art” (PO Resp. 4), and, as we generally agree that it is consistent with the subject matter disclosed in the ’503 patent and the prior art, we adopt it for purposes of this decision. B.” slip op. at 10

  • Expert testimonyPetitioner expert creditedOther

    “While Alden’s Figure 5 shows a sectional view of a segmented-headlight embodiment, thus depicting a single line of LEDs, that does not restrict the embodiment to a one-dimensional array. Indeed, Alden’s disclosures discussed above contradict such a view, as do the disclosures regarding Figure 5 and other segmented-headlight embodiments. We credit Petitioner’s expert’s testimony in this regard. Ex. 2041, 59:10–12 (“[I]t’s very clear we’re talking about a two-dimensional structure that is map of this set of slices in figure 5.”); accord id. at 56:25–60:18. The Figure 5 embodiment includes a switch array to control the individual lighting elements, with “[e]ach lighting element being independently controlled by a corresponding switch in an array of switches 115.” Ex. 1005 ¶ 29. The Figure 6 embodiment includes a face-on view of the headlight plainly showing a two-dimensional array, in addition to a sectional view similar to that of Figure 5. Id. at Fig. 6. And Alden describes that the Figure 6 embodiment uses a “switch array similar to 115 and the process previously described herein.” Id. ¶ 30. Considering Alden’s description of its sensing-and-control circuit in connection with Figure 3, which illustrates a two-dimensional array, and its description of Figure 5’s segmented headlight as working with that approach, we find that Alden’s LED-based segmented headlight is capable of selective illumination in two dimensions. See id. ¶¶ 27, 29, Figs. 3, 5.” slip op. at 17

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther

    “The Petition asserts that all claim terms should be given their “ordinary and customary meaning.” See Pet. 8. Patent Owner also proposes that the claim terms be given their ordinary meaning, and identifies the “ordinary meaning” for the terms “identify,” “turn,” and “curve,” which we discuss in our analysis below. We otherwise find that that no express claim construction is necessary. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (explaining that construction is needed only for terms that are in dispute, and only as necessary to resolve the controversy). C.” slip op. at 11

  Patent outcomesUS 10,894,503 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousness
  Patents in suitUS 10,894,503
• Mercedes-Benz USA, LLC v. Yechezkal Evan SperoAll claims unpatentable
  PTAB · Jan 14, 2025 · IPR2023-01034 · APJ Jason W Melvin · IPR · Final written decision

  Claims 1–33 are unpatentable: claims 1–8, 10–19, 21–30, 32, and 33 as obvious over Alden and Kobayashi; claims 9, 20, and 31 as obvious over Alden, Beam, and Kobayashi.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “II. ANALYSIS A. LEVEL OF ORDINARY SKILL IN THE ART Petitioner asserts that an ordinarily skilled artisan “would have had an undergraduate degree in mechanical engineering, electrical engineering, automotive engineering, optical engineering, applied physics, computer science, or similar disciplines, along with two years of experience working with intelligent vehicle systems, automotive control systems, or lighting control systems.” Pet. 8–9 (citing Ex. 1003 ¶ 33). Patent Owner does not dispute that level of ordinary skill in the art. PO Resp. 6. We adopt the undisputed level of ordinary skill in the art for purposes of this decision and refer to people with that skill as skilled artisans.” slip op. at 6

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner

    “B. CLAIM CONSTRUCTION The parties agree that no express claim construction is required at this stage. Pet. 8; PO Resp. 7. We agree with the parties and therefore do not further construe the claims for this decision. Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms 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)).” slip op. at 7

  • Expert testimonyPetitioner expert creditedDecided for petitioner
  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner

    “relies on Kobayashi, submitting that it would have been obvious to “use map data to identify road curvature when adapting the LEDs of Alden to ‘direct light into the corner.’” Pet. 23–24 (quoting Ex. 1005 ¶ 36). Petitioner reasons that Alden discloses detecting road curvature through roadside reflectors and steering-wheel sensors, and Kobayashi discloses an additional way to detect road curvature. Id. at 24. Petitioner continues that, because Kobayashi discloses using map data to control vehicle headlights, skilled artisans would have had reason to adopt its teachings in Alden’s system “to maximize successful detection in different environments.” Id. at 24–25 (citing Ex. 1003 ¶ 70). Petitioner relies on Kobayashi also for determining a light change to increase light in the direction of road curvature and shaping light based on the road curvature. Id. at 27. Finally, Petitioner relies on Kobayashi for the requirement to control the light sources both based on the determined light change and also prior to the vehicle reaching the road curvature. Id. at 30.” slip op. at 10

  Patent outcomesUS 11,208,029 unpatentable
  Claim construction§ 103 obviousness
  Patents in suitUS 11,208,029
• Mercedes-Benz USA, LLC v. Yechezkal Evan SperoAll claims unpatentable
  PTAB · Dec 10, 2024 · IPR2023-01040 · APJ Jason W Melvin · IPR · Final written decision

  Claims 48–87 are unpatentable: Alden anticipates most challenged claims, while claims 49 and 51 are obvious over Alden and Beam, and claims 52, 60, 68, 76, and 84 over Alden and Kobayashi.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “similar disciplines, along with two years of experience working with intelligent vehicle systems, automotive control systems, or lighting control systems.” Pet. 9 (citing Ex. 1003 ¶ 33). Patent Owner does not dispute that level of ordinary skill in the art. PO Resp. 6. We adopt the undisputed level of ordinary skill in the art and refer to people with it as skilled artisans.” slip op. at 7

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “enablement for Alden’s system detecting road curves. Pet. Reply 21. As Petitioner points out, Alden uses both intensity and a detected object’s location (including distance) to inform its response. Ex. 1005 ¶¶ 27–28. Petitioner’s expert testifies that the same physical system used to accommodate oncoming vehicles could be used to detect roadside reflectors and direct light into road curves. Ex. 2041, 78:16–80:24. Further, Petitioner’s expert testifies that skilled artisans would adjust the intensity and distance thresholds to distinguish roadside reflectors from oncoming vehicles. IPR2023-01039, Ex. 1003 ¶ 150. Based on Alden’s disclosures, we credit Petitioner’s expert’s testimony that Alden’s system would detect and accommodate road curvatures as claimed by the ’551 patent. Ex. 1003 ¶¶ 132–134. Although Patent Owner argues that Alden’s system could not do so while also accommodating oncoming vehicles, that position is based on the argument that “the system can’t tell the difference between signs and headlights.” PO Surreply 21–23. Patent Owner contends that “detected intensity is a function of both distance and emission intensity” so a threshold couldn’t distinguish headlights from signs. Id. at 24–25. That position ignores that Alden uses triangulation to calculate each object’s distance, as discussed, which would allow it to distinguish different types of objects using an intensity threshold. We agree with Petitioner’s expert that Alden’s system can distinguish the two, as discussed.” slip op. at 33

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther

    “sufficiently clear to impart a requirement on “classifying” such that a system must choose from multiple classes or types of objects. The parties do not appear to dispute that “classifying the object” includes arranging or grouping the object according to some system or principle. Thus, there is no need to further construe the claims for purposes of this decision.” slip op. at 10

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

    “We agree with Petitioner. Alden’s system does not simply dim its headlights where it detects spots of light. Rather, it performs a multistep process in which those spots are detected, analyzed with triangulation to determine distance, and then used to determine dimming zones. Ex. 1005 ¶¶ 27–28. Alden discloses that its sensor “detects the two headlights” of an oncoming vehicle when “[e]lectrons corresponding to the position and intensity of light are categorized by a logic and CPU 71 and stored in a memory 72.” Id. ¶ 27. Petitioner’s expert noted that Alden’s description “move[s] from lights – thresholding lights to objects, and then calculate[s] distance of each thresholding object using triangulation.” Ex. 2041, 109:23–110:2. That testimony supports our view that Alden first detects lights, uses those detected lights to identify and classify an oncoming car, then dims the headlight output to prevent glare. Alden’s dimming decision particularly indicates that it classifies pairs of detected headlights as oncoming vehicles. The CPU makes “assumptions about the space that may potentially be occupied by the driver of the sensed vehicle” and identifies an area of the segmented headlight to dim that is “significantly larger than the headlight dots that were initially received.” Ex. 1005 ¶ 27. Patent Owner agrees that Alden dims “selected surrounding sectors” around detected light (PO Resp. 30), and the way Alden selects those sectors indicates that it identifies vehicles. It does not simply expand an area around each detected light; it dims an area to encompass the driver of the identified vehicle. Ex. 1005 ¶ 27, Fig. 3. By treating a pair of corresponding detected lights collectively for dimming, Alden indicates that it classifies pairs of detected lights as vehicles.” slip op. at 23

  Patent outcomesUS 9,955,551 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousness
  Patents in suitUS 9,955,551
• Mercedes-Benz USA, LLC v. Yechezkal Evan SperoAll claims unpatentable
  PTAB · Dec 9, 2024 · IPR2023-01039 · APJ Jason W Melvin · IPR · Final written decision

  Claims 8, 10–18, and 24–47 are unpatentable: Alden anticipates claims 24–27, 29–35, 37–43, and 45–47; the remaining claims are obvious over the stated combinations.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “undergraduate degree in mechanical engineering, electrical engineering, automotive engineering, optical engineering, applied physics, computer science, or 3 The Leahy-Smith America Invents Act (“AIA”), Pub. L. No. 112-29, 125 Stat. 284 (2011), effective March 16, 2013, amended the applicable statutes. Because the application from which the ’551 patent issued was filed before this date, the pre-AIA versions of §§ 102 and 103 apply. 4 US 2003/0137849 A1, filed Jan. 22, 2002 (Ex. 1005). 5 US 6,049,749, issued Apr. 11, 2000 (Ex. 1006). 6 US 2002/0057572 A1, published May 16, 2002 (Ex. 1007). 7 WO 2001/70538 A2, published Sept. 27, 2001 (Ex. 1008). similar disciplines, along with two years of experience working with intelligent vehicle systems, automotive control systems, or lighting control systems.” Pet. 9 (citing Ex. 1003 ¶ 33). Patent Owner does not dispute that level of ordinary skill in the art. PO Resp. 6. We adopt the undisputed level of ordinary skill in the art and refer to people with it as skilled artisans.” slip op. at 7

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached

    “The problem with Patent Owner’s claim-construction position is that neither the dictionary definition nor the ’551 patent’s specification establish any degree of proof, verification, or confirmation that an object has been correctly identified. The specification discloses that “techniques known in the art” may be used “to classify, identify or locate the contents” visible to a camera sensor. Ex. 1001, 44:67–45:9. That does not establish any certainty obtained by the preexisting techniques. The specification states that the system can “illuminate distant overhead and roadside signs” and can use “[i]mage recognition via a camera” so that the illumination beam may “follow the retroreflective sign as the vehicle moves.” Id. at 51:59–67. That disclosure does not speak to any degree of confirmation or certainty. The specification’s other disclosures are no different. Id. at 52:19–27 (disclosing automated control over lighting and referencing “automatic dimming of high beam due to detection of oncoming vehicles”), 52:66–53:4 (“Using color and pattern recognition techniques it is possible to determine what is a sign.”), 63:9–12 (“Using real time image processing methodologies with image and scene recognition technology known in the art, room or outdoor area elements, objects and people are identified.”), 64:46–49 (“Using machine vision technology known in the art such as neural networks training and other pattern recognition techniques the vision system has sensor, algorithmic and computation means for identifying devices or objects.”), 69:54–57 (“In a preferred embodiment of the invention the logical controller 454 receiving image input from the camera 453 and running pattern recognition software will identify what is the visual task a person is trying to perform.”), 75:48–62 (“Using programmed scene recognition algorithms, the luminaire’s computer vision system comprised of the camera sensor 496 and logical controller 494 identifies the food on the plate, looks-up in storage the recommended CCT and powers each of the different colored LED chips aimed thereon at the correct power level in order to provide the optimal color illumination.”), 76:33–39 (“[A] camera vision system has algorithmic means to identify and track the position of people and objects and the logical controller has motion control means for re-aiming the light sources towards targeted elements and changing the power level to the LED chips.”). None of those disclosures addresses a requirement for confirming or verifying an identification that the system makes; nor does any address a particular accuracy requirement in identifying an object. Based on the specification using “identify” without any requirement that identifying an object requires confirmation or verification of the object’s true identify, we do not adopt Patent Owner’s proposed construction. Although the construction itself similarly does not expressly require the confirmation or verification that Patent Owner seeks to impose, we understand that to be Patent Owner’s intent, and accordingly do not adopt the proposed construction. The parties dispute no other aspect of “identify,” and we therefore need not expressly construe the term.” slip op. at 9

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

    “Because Alden describes its segmented headlights as implementing a process using two-dimensional signals for two-dimensional dimming functionality, we find that Figure 5 depicts a section of an embodiment that contains more than a single row of lighting elements. Stated otherwise, Alden’s disclosures are consistent with each other and are directed to a two-dimensional approach to sensing, control, and illumination. Further, we agree with Petitioner that Patent Owner has not addressed the legal standard for lack of enablement. Pet. Reply 2. In particular, to overcome the presumption that prior-art disclosures are enabled, Patent Owner must show ordinarily skilled artisans would require undue experimentation to practice the disclosed invention. See Amgen Inc. v. Hoechst Marion Roussel, Inc., 314 F. 3d 1313, 1354–55 (Fed. Cir. 2003); In re Antor Media Corp., 689 F. 3d 1282, 1287– 88 (Fed. Cir. 2012). We do not agree with Patent Owner that Alden lacks a presumption of enablement (see PO Surreply 7–8), because we determine that Petitioner’s contentions rely on Alden’s disclosures regarding its invention as a whole. Other than arguing that Figure 5 discloses a single-row embodiment that is unusable with Alden’s other disclosures, Patent Owner has made no attempt to show Alden lacks enablement. Patent Owner has not addressed what experimentation skilled artisans would require to practice an invention using Alden’s Figure 5 segmented headlight with the remainder of Alden’s system as disclosed in Figures 2, 3, and 4, and Alden’s corresponding textual description. We therefore determine that Patent Owner has not shown Alden to lack enablement for its disclosed invention.” slip op. at 20

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableMotivation foundUnpatentable

    “Petitioner asserts that skilled artisans would have had reason to incorporate Kobayashi’s teachings that its controller receives “road map information” from a “road profile calculating means” and uses it to adjust the headlamp’s illumination. Pet. 63–64. Petitioner reasons that it would be obvious to “apply these teachings to Alden to use map data to identify road curvature when adapting the LEDs of Alden to ‘direct light into the corner.’” Id. at 64 (citing Ex. 1003 ¶ 122). And Petitioner asserts that skilled artisans had reason to do so because it would “maximize successful detection in different environments” such as where the road lack reflectors. Id. at 65 (citing Ex. 1003 ¶ 123). Other than as discussed above regarding Alden’s disclosures, Patent Owner does not contest Petitioner’s showing for claims 28, 36, and 44. We have considered the full record, including evidence and arguments presented by Petitioner and Patent Owner on whether the combination of Alden and Kobayashi discloses each limitation of claims 28, 36, and 44, and whether skilled artisans would have had reason to combine the references’ teachings as asserted. Based on the full record, we conclude that Petitioner has proven that claims 28, 36, and 44 would have been obvious over Alden and Kobayashi. Pet. 62–65.” slip op. at 34

  Patent outcomesUS 9,955,551 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousness
  Patents in suitUS 9,955,551

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