UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TOYOTA MOTOR CORPORATION
`Petitioner
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`v.
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`AMERICAN VEHICULAR SCIENCES LLC
`Patent Owner
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`Patent Number: 8,036,788
`Title: VEHICLE DIAGNOSTIC OR PROGNOSTIC MESSAGE
`TRANSMISSION SYSTEMS AND METHODS
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`Case IPR2013-00417
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`_________________________________________________________________
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`PATENT OWNER’S MOTION TO AMEND
`PURSUANT TO 37 C.F.R. § 42.21
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`TOYOTA MOTOR CORPORATION
`Petitioner
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`
`v.
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`
`AMERICAN VEHICULAR SCIENCES LLC
`Patent Owner
`
`
`
`Patent Number: 8,036,788
`Title: VEHICLE DIAGNOSTIC OR PROGNOSTIC MESSAGE
`TRANSMISSION SYSTEMS AND METHODS
`
`
`
`Case IPR2013-00417
`
`_________________________________________________________________
`
`
`PATENT OWNER’S MOTION TO AMEND
`PURSUANT TO 37 C.F.R. § 42.21
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`TABLE OF CONTENTS
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`TABLE OF CONTENTS ........................................................................................... i
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`TABLE OF AUTHORITIES ................................................................................... ii
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`I.
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`II.
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`INTRODUCTION .......................................................................................... 1
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`LISTING OF SUBSTITUTE CLAIMS ......................................................... 1
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`III. CLAIM CONSTRUCTION ........................................................................... 5
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`IV. SUPPORT FOR THE PROPOSED CLAIMS ............................................... 7
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`V.
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`PATENTABILITY OF THE PROPOSED CLAIMS .................................... 9
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`i
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`TABLE OF AUTHORITIES
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`
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`Cases
`Paperless Accounting, Inc. v. Bay Area Rapid Transit Sys.,
`804 F.2d 659 (Fed. Cir. 1986) ................................................................................ 9
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`Rules
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`37 C.F.R. § 42.121 ..................................................................................................... 1
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`ii
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`Patent Owner’s Motion To Amend
`IPR2013-00417
`I.
`INTRODUCTION
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`
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`Patent Owner American Vehicular Sciences LLC (“AVS”) submits the
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`following Motion to Amend under 37 C.F.R. § 42.121 in connection with the
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`above-captioned inter partes review of U.S. Patent No. 8,036,788 (“the 788
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`patent”). AVS respectfully submits that its Motion satisfies AVS’s burden of proof
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`that its proposed substitute claims are patentable and supported by written
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`description.
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`II. LISTING OF SUBSTITUTE CLAIMS
`AVS seeks to cancel claims 1, 3, 4, 6, 7, 8, 11, 15, 16 and 18 of the 788
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`patent.1 Proposed substitute claims 22 through 31 are set forth below, with
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`additions to the language of the corresponding issued claim indicated by
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`underlining and any deletions indicated by bracketing. Substitute claims 22 and 24
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`are independent claims to which additional limitations have been added. The
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`remaining substitute claims are dependent claims that are only being amended to
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`reflect the change in dependency.
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`1 For clarity, AVS notes that it is simultaneously filing a Patent Owner’s Response
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`in this inter partes review. AVS’s Patent Owner’s Response requests that the
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`patentability of claim 9 be confirmed. AVS is not seeking to cancel claim 9 and
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`AVS has not proposed a substitute claim for claim 9.
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`1
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`Claim 22 (substitute for claim 1): A method for providing status data for
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`vehicle maintenance, comprising:
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`monitoring for a triggering event on a vehicle during operation of the vehicle
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`on a road having a wireless communications unit, the triggering event relating to a
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`diagnostic or prognostic analysis of at least one of a plurality of different
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`components or subsystems of the vehicle; and
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`initiating a wireless transmission between the communications unit and a
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`remote site separate and apart from the vehicle in response to the triggering event,
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`the transmission including a diagnostic or prognostic message about the at least
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`one component or subsystem;
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`wherein the diagnostic or prognostic message includes an identification of
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`the at least one component or subsystem and an identification of whether the at
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`least one component or subsystem should be either repaired or replaced.
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`Claim 23 (substitute for claim 3) The method of claim [1] 22, wherein the
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`triggering event is a failure, predicted failure or fault code generation of the at least
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`one component or subsystem.
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`Claim 24 (substitute for claim 4) A system for providing status data for
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`vehicle maintenance, comprising:
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`a diagnostic module including at least one sensor for monitoring a plurality
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`of different components or subsystems of the vehicle during operation of the
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`2
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`vehicle on a road, said diagnostic module being arranged to analyze monitoring
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`data provided by said at least one sensor and detect a triggering event relating to a
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`diagnostic or prognostic analysis of at least one of the plurality of different
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`components or subsystems of the vehicle; and
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`a wireless communications unit arranged to interface with a wireless
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`communications network, said communications unit being coupled to said
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`diagnostic module and
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`initiating a wireless
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`transmission between said
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`communications unit and a remote site separate and apart from the vehicle in
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`response to the triggering event, the transmission including a diagnostic or
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`prognostic message about the at least one component or subsystem, wherein the
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`diagnostic or prognostic message includes an identification of the at least one of
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`the plurality of different components or subsystems of the vehicle and an
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`identification of whether the at least one of the plurality of different components or
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`subsystems of the vehicle should be either repaired or replaced.
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`Claim 25 (substitute for claim 6) The system of claim [4] 24, wherein the
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`triggering event is a failure, predicted failure or fault code generation of the at least
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`one component or subsystem.
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`Claim 26 (substitute for claim 7) The method of claim [1] 22, wherein the
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`step of monitoring for the triggering event comprises providing at least one sensor
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`that monitors the at least one component or subsystem.
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`3
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`Claim 27 (substitute for claim 8) The method of claim [7] 26, wherein the at
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`least one sensor is part of a diagnostic module on the vehicle, further comprising
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`configuring the diagnostic module to analyze data obtained by the at least one
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`sensor in order to diagnose operability of the at least one component of subsystem
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`and generate the triggering event based on diagnostic criteria.
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`Claim 28 (substitute for claim 11) The method of claim [1] 22, wherein the
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`step of monitoring for the triggering event comprises providing a plurality of
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`different sensors that monitor the at least one component or subsystem.
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`Claim 29 (substitute for claim 15) The system of claim [4] 24, wherein said
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`diagnostic module is arranged to analyze monitoring data provided by said at least
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`one sensor and detect the triggering event relating to predictive, prognostic
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`analysis of the at least one component.
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`Claim 30 (substitute for claim 16) The system of claim [4] 24, wherein said
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`diagnostic module is arranged to analyze monitoring data provided by said at least
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`one sensor and detect the triggering event relating to diagnostic analysis of the at
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`least one component or subsystem of the vehicle.
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`Claim 31 (substitute for claim 18) The system of claim [4] 24, wherein said
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`diagnostic module comprises a plurality of different, sensors.
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`4
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`Patent Owner’s Motion To Amend
`IPR2013-00417
`III. CLAIM CONSTRUCTION
`For purposes of this Motion to Amend only, AVS does not contest the
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`Board’s construction of claim terms in the originally-issued claims. (Paper 14 at 8-
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`12.) In particular, AVS does not contest the Board’s construction of, and/or
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`commentary regarding, the terms: “component”; “sensor”; “triggering event”; and
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`“diagnostic or prognostic message.”
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`Claim 22 adds the following limitations: “during operation of the vehicle on
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`a road” and “wherein the diagnostic or prognostic message includes an
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`identification of the at least one component or subsystem and an identification of
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`whether the at least one component or subsystem should be either repaired or
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`replaced.” Many of the words appearing in the added language were present in the
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`original claim language and/or have already been construed by the Board, e.g.,
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`“component” and “diagnostic or prognostic message.” Of the remaining words,
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`AVS believes that these words are ordinary words whose meaning can be readily
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`understood. Nevertheless, for the sake of clarity and out of an abundance of
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`caution, AVS offers the following proposed constructions of the words “repaired”
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`and “replaced.”
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`The specification assigns no special meaning to the word “repaired.” The
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`ordinary meaning of the word “repair,” as supported by its dictionary definition, is
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`“to restore to a sound or healthy state.” (Ex. 2006; Ex. 2002 at ¶ 47.) As AVS’s
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`5
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`IPR2013-00417
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`expert, Mr. Kennedy explains, in the context of these claims, e.g., vehicles
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`operating on a road, one of ordinary skill in the art would understand the word
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`“repair” or “repaired” to mean “to restore the identified component to meet
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`original specified design requirements.” (Ex. 2002 at ¶ 47.)
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`The specification likewise assigns no special meaning to the word
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`“replaced.” The ordinary meaning of “replace,” as supported by its dictionary
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`definition, is “to put something new in place of.” (Ex. 2006; Ex. 2002 at ¶ 47.)
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`AVS’s expert explains that in the context of these claims, e.g., vehicles operating
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`on a road, one of ordinary skill in the art would understand the word “replace” or
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`“replaced” to mean “to put something different in place of the identified
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`component that meets the original specified design requirements.” (Ex. 2002 at ¶
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`47.) In the context of these claims “replace” or “replaced” would not be limited to
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`“new” elements because often times in the automotive industry, broken vehicular
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`elements are replaced not with “new” elements, but with refurbished ones. (Id.)
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`Claim 24 adds the following limitations: “during operation of the vehicle on
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`a road” and “wherein the diagnostic or prognostic message includes an
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`identification of the at least one of the plurality of different components or
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`subsystems of the vehicle and an identification of whether the at least one of the
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`plurality of different components or subsystems of the vehicle should be either
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`repaired or replaced.” These claim limitations are substantially similar to the claim
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`6
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`limitations added to claim 22. The constructions set forth above with respect to
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`claim 22 apply to claim 24.
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`IV. SUPPORT FOR THE PROPOSED CLAIMS
`Support for claim 22 can be found in the original-filed application that led to
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`the 788 patent (Ex. 1007). For example, the application repeatedly describes and
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`depicts diagnostic monitoring occurring while the vehicle is operating on the road.
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`(See, e.g., Ex. 1007 at Figs. 3, 5-6; p. 11, 24, 28, 812; Ex. 2002 at ¶ 49.) Moreover,
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`the application describes diagnostic or prognostic messages that contain an
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`identification of the component or subsystem and an identification of whether the
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`component or subsystem needs to be repaired or needs to be replaced. (Ex. 1007 at
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`16-17, 19, 22, 28-31, 72, 78-79.) For example, the specification states that the
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`diagnostic system can “diagnose the vehicle’s own problems,” which includes
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`providing an identification of specific components, e.g., tires, and providing an
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`identification of whether those components need to be, for example, rotated or
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`balanced, on the one hand, or replaced, on the other hand. (Id. at 19, 22.) Mr.
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`Kennedy explains that one of ordinary skill would understand this to mean that a
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`diagnostic or prognostic message is generated and includes identifying the
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`2 Page numbers refer to the page numbers of the exhibit, not the page numbers of
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`the specification.
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`7
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`component and identifying whether the component needs to be repaired or
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`replaced. (Ex. 2002 at ¶ 50.)
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`The application also supports the overall combination recited by claim 22
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`because, for example, the application states that the information discussed above
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`can be sent to a dealer or other service center, e.g., a remote site. (Ex. 1007 at 19;
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`Ex. 2002 at ¶ 50.) Additional support for the original limitations is also in the
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`priority specification. (Ex. 1007 at 16-17, 28-31, 72, 78-79; Ex. 2002 at ¶ 51.)
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`The priority application filed on June 7, 1995 provides similar disclosures
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`regarding the invention recited in claim 22. (Ex. 2007 at 1, 4-6, 10-13, 15, 20-
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`24.)3, 4
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`3 Proposed dependent claim 23 is being amended solely to change the dependency.
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`Support for claim 23 can be found in both applications. (Ex. 1007 at 12-13, 79
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`(disclosing that the “triggering event” can be “failure, predicted failure, or fault
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`code generation”); Ex. 2007 at 4-5, 10-11, 15-19; Ex. 2002 at ¶ 56 n.3.)
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`4 The citations to page numbers in the priority application refer to the handwritten
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`page numbers in the bottom margin. The fact that the application for the 788
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`patent may have provided more detailed information regarding some of the claim
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`limitations does not mean that the priority application is insufficient. See, e.g.,
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`8
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`As discussed above, the limitations added to claim 24 are substantially
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`similar to the limitations added to claim 22. For the same reasons as discussed
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`above with respect to claim 22, support for claim 24 can also be found in the in the
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`original-filed application that led to the 788 patent and the priority application.5
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`V.
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`PATENTABILITY OF THE PROPOSED CLAIMS
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`The prior art cited in Toyota’s Petition and discussed below is the closest
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`prior art of which AVS is aware with respect to the subject matter of the 788
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`patent, including the added limitations of the substitute claims. (See Ex. 2002 at ¶
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`57, 70.) Additionally, according to Toyota’s expert, the prior art cited in Toyota’s
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`Petition is the closest prior art with respect to the subject matter of the 788 patent
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`of which Toyota is aware. (Ex. 2003 at 26:4-9.) AVS also provides the
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`declaration of its expert, Mr. Kennedy, who reviewed the prior art known to AVS,
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`e.g., prior art from this and related inter partes reviews, prior art cited on the front
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`Paperless Accounting, Inc. v. Bay Area Rapid Transit Sys., 804 F.2d 659, 664
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`(Fed. Cir. 1986).
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`5 Proposed dependent claims 25-31 are being amended solely to change the
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`dependency. Support for these claims can be found in both the original and
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`priority applications. (Ex. 1007 at 11-13, 16-19, 21-32, 79-80; Ex. 2007 at 4-5,
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`10-11, 15-19, 22-25; Ex. 2002 at ¶ 56 n.3.)
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`9
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`of the 788 and related patents, and references cited in invalidity contentions
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`submitted by Toyota in the co-pending litigation.
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`Claim 22 amends original claim 1 to recite that the monitoring for triggering
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`events occurs “during operation of the vehicle on a road” and that “the diagnostic
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`and prognostic message includes an identification of the at least one component or
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`subsystem and an identification of whether the at least one component or
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`subsystem should be either repaired or replaced.” Claim 24 likewise amends claim
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`4 to recite that the diagnostic module monitors a plurality of different components
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`or subsystems of the vehicle “during operation of the vehicle on a road” and that
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`“the diagnostic or prognostic message includes an identification of the at least one
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`of the plurality of different components or subsystems of the vehicle and an
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`identification of whether the at least one of the plurality of different components or
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`subsystems of the vehicle should be either repaired or replaced.” As Mr. Kennedy
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`explains, performing this detailed level of diagnosis on-board an automobile was
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`not known in the prior art in June 1995. (Ex. 2002 at ¶¶ 57-64.) Nor would one of
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`ordinary skill in the art have been motivated to modify the prior art to arrive at the
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`invention of claims 22 and 24. (Id. at ¶¶ 63, 66-68, 77-78.)
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`The prior art in 1995 as it related to on-board vehicle diagnostics was
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`primitive. As explained by Mr. Kennedy, in 1995 vehicles had sensors that
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`provided information to the vehicle’s processor for use in operating the vehicle,
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`e.g., in making the engine run. (Ex. 2002 at ¶ 61.) If the processor detected that
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`the sensor output was outside a preset range, the processor could generate a fault
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`code. (Id.) These fault codes provided minimal information—namely, that
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`something was potentially wrong on the vehicle. (Id.) Fault codes were not being
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`used in 1995 to pin-point the specific cause of the problem; rather they were used
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`to narrow the scope of investigation with respect to the potential problem. (Id.)
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`Thus, fault codes were not being used to, for example, identify whether a particular
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`component needed to be repaired or whether the particular component needed to be
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`replaced. (Id. at ¶¶ 61-62) For example, the fault codes could not tell you that you
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`had to replace a certain component, as opposed to repairing that component. (Id.)
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`The closest prior art in the automotive context of which AVS is aware
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`discloses these types of basic automotive “diagnostic” systems. (See Ex. 2008
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`U.S. Patent No. 5,157,160 to Asano (disclosing that “abnormal codes” and data are
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`sent to a remote location for further analysis); Ex. 1002 (disclosing that “diagnostic
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`codes” and data are sent to human expert for further analysis); Ex. 1004 (disclosing
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`detecting an abnormality on the vehicle and sending data to a remote location for
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`further analysis). Indeed, the prior art cited by Toyota and applied by the Board in
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`this inter partes review disclosed these basic automotive fault code “diagnostic”
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`systems. While this prior art disclosed things such as “abnormal codes” and “fault
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`codes,” as Mr. Kennedy explains, these prior art systems would not provide
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`11
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`information about whether the identified component needed to be repaired or
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`whether it needed to be replaced. (Id. at ¶¶ 72-75.) Additionally, while there was
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`some disclosure in the prior art of using a fault detection system to identify a
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`component with a fault, again, those systems would not provide information about
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`whether the identified component needed to be repaired as opposed to being
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`replaced. (Ex. 2010, Wei Bin Zhang, “Vehicle Health Monitoring for AVCS
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`Malfunction Management,” IEEE Vehicle Navigation & Information Systems
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`Conference, 1993); Ex. 2009 (disclosing a diagnostic system for tires that only told
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`you that there was a problem with a tire, not that it had to be repaired as opposed to
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`being replaced); Ex. 2002 at ¶¶ 62, 76.)
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`AVS is also not aware of diagnostic systems in 1995 in other applications
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`that could identify whether any particular component needed to be either repaired
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`or replaced. (Ex. 2002 at ¶ 78.) But even if such diagnostic systems existed, it
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`would not have been obvious to use those systems in automotive applications.
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`(Id.) As Mr. Kennedy explains, one of ordinary skill in the art in the automotive
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`industry would not have looked to complex vehicular applications, e.g., airplanes,
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`trains, when trying to solve an automotive problem. (Id.) That is because systems
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`used on-board airplanes and trains are designed to operate in very different
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`environments under very different considerations. (Id.) Thus, it would not have
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`been within the ordinary creativity or basic skill set of those of ordinary skill in the
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`12
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`art to look to complex aerospace or locomotive systems and modify those systems
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`for use on automobiles.
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`Nor would it have been obvious for one of ordinary skill in the art to modify
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`the closest automotive prior art to arrive at the invention claimed in claims 22 and
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`24. As explained by Mr. Kennedy, in 1995, processors were very expensive and
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`processing and memory capacity on-board a vehicle was very limited. (Id. at ¶¶
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`58-59, 64, 66-68, 77.) His opinions were confirmed by others. (See, e.g., Ex. 1002
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`at 1:24-32 (discussing “on-board computing power limitations”).) As a result, in
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`1995, those of ordinary skill in the art were not motivated to come up with
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`solutions that involved adding such elements to the vehicle or that involved
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`increasing the processing capacity of the processor on-board the vehicle. (Ex.
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`2002 at ¶¶ 66-68, 77.) To develop an invention that could specifically identify
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`components and identify whether they needed to be either repaired or replaced
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`would have required adding elements to an automobile and would have necessarily
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`required processing capacity on-board the vehicle that was not available in 1995.
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`(Id.)
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`The added features of the substitute claims would not have been within the
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`ordinary skill in the art in terms of the ordinary creativity in 1995, e.g., a system
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`on-board the vehicle that would be able to generate the specific type of diagnostic
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`information of an identification of whether a component needed to be either
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`13
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`repaired or replaced. (Id. at ¶¶ 63, 66-68, 77.) Moreover, the added features of
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`claims 22 and 24 were not known in the art in June 1995, in either automotive or
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`other applications, to AVS’s knowledge. (Id. at ¶¶ 70-78.) Nor as Mr. Kennedy,
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`explains would a person of ordinary skill in the art have access to reference books
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`in 1995 that would have taught a diagnostic system that could determine whether a
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`specific component need to be repaired or whether a specific component needed to
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`be replaced. (Id. at ¶ 63.) Rather reference books and conventional practice would
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`have taught the basic fault code analysis that is described above. (Id.) A person of
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`ordinary skill in the art in 1995 would not have been motivated to come up with
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`the specific diagnostic system and method recited in claims 22 and 24. (Id. at ¶¶
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`63, 66-68, 77.) Rather, those of ordinary skill in the art were motivated to think in
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`terms of having a vehicle generate only basic faults codes because of, for example,
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`the limited processing capacity of processors on-board the vehicle in 1995. (Id.)
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`The invention of claims 22 and 24 was a significant advancement over the
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`prior art. (Id. at ¶ 65, 69.) Despite the limitations in the art, the inventor of the 788
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`patent figured out a way to move past the basic fault code diagnosis that was
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`occurring on automobiles in 1995. His invention was a significant and useful
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`advance over the prior art because having the vehicle conduct its own detailed
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`diagnostic assessment allows for a more real-time diagnosis of the vehicle’s
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`problems. (Id.) This in turn allows for the vehicle maintenance to be completed in
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`14
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`a more efficient and timely manner such that vehicle breakdowns can be avoided.
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`(Id.)
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`In light of the above, AVS respectfully submits that proposed claims 22 and
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`24 are patentable over the prior art. None of the prior art (including the closest
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`prior art) recites an invention as recited by claims 22 and 24. Moreover, such an
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`invention was not known in the prior art and would not have been an obvious
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`modification over the prior art. Rather, providing a detailed diagnosis on-board the
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`vehicle was a significant improvement over the prior art. AVS respectfully submits
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`that dependent claims 23 and 25-31 are patentable over the prior art for the same
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`reasons.
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`
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`Dated: March 24, 2014
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`
`
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`McANDREWS, HELD & MALLOY, LTD.
`500 West Madison St., 34th Floor
`Chicago, IL 60661
`Telephone: (312) 775-8000
`
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`Respectfully submitted,
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`
`
`By: /Thomas J. Wimbiscus/
`Thomas J. Wimbiscus
`Reg. No. 36,059
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`15
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`Patent Owner’s Motion To Amend
`IPR2013-00417
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`CERTIFICATE OF SERVICE
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`I hereby certify that Patent Owner’s Motion to Amend Pursuant to 37 C.F.R.
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`
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`§ 42.21 in connection with Inter Partes Review Case IPR2013-00417 and Exhibtis
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`2002 through 2010 was served on this 24th day of March by electronic mail to the
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`following:
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`
`A. Antony Pfeffer
`apfeffer@kenyon.com
`Thomas R. Makin
`tmakin@kenyon.com
`Matt Berkowitz
`mberkowitz@kenyon.com
`ptab@kenyon.com
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel: 212-425-7200
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`MCANDREWS HELD & MALLOY, LTD.
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`Telephone: 312-775-8000
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`
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`Facsimile: 312-775-8100
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`
`
`
`/Thomas J. Wimbiscus/
`Thomas J. Wimbiscus
`Registration No. 36,059
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`CUSTOMER NUMBER: 23446
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`Date: March 24, 2014
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