UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`VALEO NORTH AMERICA, INC., VALEO S.A., VALEO GMBH,
`VALEO SCHALTER UND SENSOREN GMBH,
`AND CONNAUGHT ELECTRONICS LTD.
`Petitioners
`
`v.
`
`MAGNA ELECTRONICS, INC.
`Patent Owner
`
`_______________
`
`Case IPR2014-01208
`U.S. Patent No. 7,991,522
`
`________________
`
`Before JAMESON LEE, PHILLIP J. KAUFFMAN, and MATTHEW R.
`CLEMENTS, Administrative Patent Judges
`
`PETITIONER’S DEMONSTRATIVES
`
`
`
`1
`
`
`
`
`
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`VALEO NORTH AMERICA, INC., VALEO S.A., VALEO GMBH,
`VALEO SCHALTER UND SENSOREN GMBH,
`AND CONNAUGHT ELECTRONICS LTD.
`Petitioners
`
`v.
`
`MAGNA ELECTRONICS, INC.
`Patent Owner
`
`_______________
`
`Case IPR2014-01208
`U.S. Patent No. 7,991,522
`
`________________
`
`Before JAMESON LEE, PHILLIP J. KAUFFMAN, and MATTHEW R.
`CLEMENTS, Administrative Patent Judges
`
`PETITIONER’S DEMONSTRATIVES
`
`
`
`1
`
`
`
`
`
`
`
`Valeo North America, Inc., et al.
`v.
`Magna Electronics, Inc.
`
`IPR2014-01208
`Trial Hearing
`October 1, 2015
`
`PETITIONERS’ DEMONSTRATIVES
`
`1
`
`
`
`Patent No. US 7,991, 522 (“The ’522 Patent”)
`
`2
`
`Ex. 1001
`
`
`
`Instituted Grounds
`
`CLAIMS
`2, 3, 5, 7, 11, 12, 28,
`32–35, 37, 40, 44–46
`18, 21, 25, 26
`
`22
`
`19, 23, 24
`
`GROUND OF UNPATENTABILITY
`Obvious over Nissan and Hitachi
`
`Obvious over Nissan, Hitachi, and
`Gutta
`Obvious over Nissan, Hitachi, and
`Gutta
`Obvious over Nissan, Hitachi, and
`Broggi
`
`Paper 13
`
`3
`
`
`
`The ’522 Patent – Claim 44
`
`44. An imaging system for a vehicle, said imaging system comprising:
`
`an imaging array sensor comprising a plurality of photo-sensing pixels, wherein said
`imaging array sensor is disposed at least partially within an exterior rearview mirror
`assembly at a side of a vehicle equipped with said imaging system;
`
`wherein, when said imaging array sensor is disposed at least partially within the
`exterior rearview mirror assembly, said imaging array sensor has a field of view
`exterior of the equipped vehicle, and wherein said imaging array sensor is operable
`to capture an image exterior of the equipped vehicle;
`
` a
`
` control for processing said captured image;
`
`
`wherein said control is operable to determine that said imaging array sensor is
`misaligned when said imaging array sensor is disposed at least partially within the
`exterior rearview mirror assembly at the side of the equipped vehicle; and
`
`wherein said captured image comprises data and wherein said control, responsive to
`a determination of misalignment of said imaging array sensor, is operable to adjust
`said data to at least partially compensate for the determined misalignment of said
`imaging array sensor.
`Ex. 1001
`
`4
`
`
`
`Claim 44 and Nissan
`44. An imaging system for a vehicle, said imaging system comprising:
`
`
`Ex. 1001
`
`5
`
`Nissan (Ex. 1003), FIG. 6
`
`
`
`Claim 44 and Nissan
`Claim 44 cont’d
`an imaging array sensor comprising a plurality of photo-sensing
`pixels, wherein said imaging array sensor is disposed at least partially
`within an exterior rearview mirror assembly at a side of a vehicle
`equipped with said imaging system;
`
`
`Ex. 1001
`
`Nissan Ex. 1003
`“The vehicle-mounted camera 2 is built in to a left-hand door mirror
`of the car.” ¶ [0032]
`
`6
`
`
`
`Claim 44 and Nissan
`Claim 44 cont’d
`wherein, when said imaging array sensor is disposed at least partially
`within the exterior rearview mirror assembly, said imaging array
`sensor has a field of view exterior of the equipped vehicle, and
`wherein said imaging array sensor is operable to capture an image
`exterior of the equipped vehicle;
`
`Ex. 1001
`
`Nissan Ex. 1003
`“Specifically, the turn signal position detection unit 33 first detects a
`difference between the actual image of the left front of the car
`captured when the left turn signal is on and the actual image of the
`left front of the car captured when the left turn signal is off (steps S2-
`4). ¶44.
`
`7
`
`
`
`Nissan
`
`8
`
`Nissan (Ex. 1003),
`FIGs. 8a-8c
`
`
`
`Claim 44 and Nissan
`Claim 44 cont’d
`a control for processing said captured image;
`
`Ex. 1001
`
`Nissan Ex. 1003
`“the optical axis misalignment detection program is executed by the
`CPU 6 of the control unit 5 and the control unit 5 functions as a turn
`signal position detection unit (image processing means) 33, a turn
`signal position misalignment evaluation unit
`(optical axis
`misalignment judging means) 34” ¶36.
`
`
`9
`
`
`
`Claim 44 and Nissan
`Claim 44 cont’d
`wherein said control is operable to determine that said imaging array
`sensor is misaligned when said imaging array sensor is disposed at
`least partially within the exterior rearview mirror assembly at the
`side of the equipped vehicle; and
`Nissan Ex. 1003
`“[T]he turn signal misalignment evaluation unit 34 compares the
`position where the left turn signal ought to be observed as shown in
`the template image … against the position of the left turn signal in
`the actual image as detected by the turn signal position detection
`unit 33, and judges … whether or not optical axis misalignment has
`occurred in the vehicle mounted camera 2.Ӧ 45
`
`
`Ex. 1001
`
`
`
`10
`
`
`
`Claim 44 and Hitachi
`Claim 44 cont’d
`wherein said captured image comprises data and wherein said
`control, responsive to a determination of misalignment of said
`imaging array sensor, is operable to adjust said data to at least
`partially compensate for the determined misalignment of said
`imaging array sensor.
`
`Ex. 1001
`
`Hitachi Ex. 1012
`“[W]hen the image data correction amount is calculated in Step S10,
`that result is assessed in Step S14 as to whether or not it is only a
`case of translational displacement, as shown in Fig. 7(a). If the result
`.
`is Yes, instead of image data correction, the used image area A1 and
`the initial mark 3A position X are changed, as shown in Fig. 7(b).”
`¶54 (Emphasis Added).
`
`
`11
`
`
`
`Hitachi
`
`12
`
`Hitachi (Ex. 1013),
`FIG. 3
`
`
`
`Hitachi
`
`13
`
`Hitachi (Ex. 1013),
`FIG. 6 (Annotated)
`
`
`
`Hitachi
`
`14
`
`Hitachi (Ex. 1013),
`FIG. 6 (Annotated)
`
`
`
`Obvious to Modify Nissan – Petitioners’ Expert Testimony
`
`15
`
`Ex. 1010 (excerpt)
`
`
`
`Obvious to Modify Nissan – Petitioners’ Expert Testimony
`
`16
`
`
`
`Obvious to combine Nissan and Hitachi
`
`17
`
`Ex. 1010 (excerpt)
`
`
`
`Claim 18 and Gutta
`
`Claim 18
`wherein said control processes said captured image to detect an
`object exterior the equipped vehicle.
`
`Ex. 1001
`
`Gutta Ex. 1005
`“[o]bjects in the field of view of the cameras are identified by the
`object identifier, and the relative distance of each object from the
`vehicle is determined.” 3:23-30
`
`18
`
`
`
`Claim 21 and Gutta
`
`Claim 21
`wherein said control is operable to alert the driver of the equipped
`vehicle that an object is detected exterior to the equipped vehicle
`
`Ex. 1001
`
`Gutta Ex. 1005
`“[T]he system can provide the driver with an indication that it is now
`safe to change lanes to the left or the right in response to the driver
`activating the turning signal, based on the information provided by
`the cameras, object identifier and distance determiner. … [T]he
`system can have the capability to automatically disable the turning
`signal, in addition to providing an indication…to advise the driver
`that it is unsafe to change lanes.” 2:22-31
`
`19
`
`
`
`Claim 22 and Gutta
`Claim 22
`“The imaging system of claim 1,wherein said control is operable to
`alert the driver of the equipped vehicle that an object is detected at
`the side of the equipped vehicle in one of (a) the driver of the
`equipped vehicle actuating a turn signal toward the side of the
`equipped vehicle at which the object is detected,…”
`Gutta Ex. 1005
`“[T]he system can provide the driver with an indication that it is now safe
`to change lanes to the left or the right in response to the driver activating
`the turning signal, based on the information provided by the cameras,
`object identifier and distance determiner. It is also foreseen that the
`system can have the capability to automatically disable the turning signal,
`in addition to providing an indication to the driver on the display, so as to
`advise the driver that it is unsafe to change lanes.” 2:22-31
`
`
`Ex. 1001
`
`20
`
`
`
`Claim 25 and Gutta
`Claim 25
`“The imaging system of claim 1, wherein said imaging array sensor
`has a field of view at least partially sideward of the equipped vehicle,
`said imaging system comprising a side object detection system for
`detecting an object at a side of the equipped vehicle.”
`
`Gutta Ex. 1005
`“[T]he system can provide the driver with an indication that it is now
`safe to change lanes to the left or the right in response to the driver
`activating the turning signal, based on the information provided by
`the cameras, object identifier and distance determiner. … [T]he
`system can … advise the driver that it is unsafe to change lanes.”
`2:22-31.
`
`Ex. 1001
`
`
`
`21
`
`
`
`Claim 26 and Gutta
`Claim 26
`“wherein said imaging array sensor comprises a CMOS imaging array
`sensor.”
`
`
`Ex. 1001
`
`Gutta Ex. 1005
`“cameras for use as the first and second side image cameras 12, 14
`and the rear image camera 16 are disclosed in Schofield, …
`incorporated herein by reference.” 3:19-22
`
`Schofield discusses use of CMOS arrays of photo-sensing pixels. Ex.
`1010 Att. G at p.1, lines 10-11.
`
`
`22
`
`
`
`Claim 19 and Broggi
`
`Claim 19
`“said control is operable to distinguish between an object in the field
`of view of said imaging array sensor and a shadow of an object.”
`
`
`Ex. 1001
`
`Broggi Ex. 1006
`“The shadow under the car is searched for in order to find the box
`base. It is defined as a horizontal edge, but since other shadows, like
`bridges’ ones, could be present on the road as well, and the
`algorithm looks for a high concentration of edges above the
`horizontal edge; if no base can be detected, the column is discarded.
`p. 312.
`
`23
`
`
`
`Broggi distinguishes between object and shadow of object
`
`24
`
`Ex. 1034
`
`
`
`Claim 23 and Broggi
`
`Claim 23
`“wherein said control applies an edge detection algorithm to process
`data of said captured image”
`
`
`Ex. 1001
`
`Broggi Ex. 1006
`
`Broggi detects vehicles in images by finding symmetry using edge
`detection, and discloses edges modules for finding vertical and
`horizontal edges in images of vehicles. Ex. 1006 at Abstract and p.
`311.
`
`25
`
`
`
`Claim 24 and Broggi
`
`Claim 24
`“The
`imaging system of claim 23, wherein an algorithmically
`executed filtering mechanism at least substantially ignores detected
`edges that are not indicative of a significant object in order to at
`least one of … (b) reduce false signals”
`
`Ex. 1001
`
`Broggi Ex. 1006
`“An interesting column is defined as having a high symmetry in: (i) the
`image that contains the result of Sobel binarization or in, (ii) the image
`that contains the AND between symmetry of horizontal and vertical
`edges. … In correspondence to these columns the vertical edges
`symmetry is checked to obtain the expected vehicle width … if a high
`value of symmetry is present for small widths too, it means that the
`algorithm has detected a small object; in this case the column is
`discarded.” p. 312
`
`
`26
`
`
`
`Broggi Declaration (Ex.1033)
`
`27
`
`Ex. 1006, Ex. 1033
`
`
`
`Broggi
`
`• Ex. 1010 - First Declaration of Dr.-Ing. Frahm stating that Broggi is prior
`art to the ’522patent and published on June 14-17, 2004;
`
`
`• Ex. 1025 - First Declaration of Gerard P. Grenier, custodian of records of
`IEEE, stating that IEEE records confirm that Broggi was presented at 2004
`IEEE Intelligent Vehicles Symposium from June 14-17, 2004;
`
`
`• Ex. 1028 - Second Declaration of Gerard P. Grenier stating that Broggi
`was published and presented at the 2004 IEEE Intelligent Vehicles
`Symposium from June 14-17, 2004;
`
`• Ex. 1029 - Declaration of Christopher Butler establishing the public
`accessibility of Broggi (Ex. 1006) online at least by October 2004
`
`• Ex. 1033 – Declaration of author Alberto Broggi stating that Broggi was
`presented at the IEEE Intelligent Vehicles Symposium (June 14-17, 2004)
`
`
`
`
`28
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) on Magna
`
`Electronics, Inc., by providing a copy of Petitioners’ Demonstratives were served
`
`via email to the following counsel of record for patent owner:
`
`
`
`Timothy A. Flory, Esq. (Lead Counsel)
`Terence J. Linn (Back-up Counsel)
`Gardner, Linn, Burkhart & Flory, LLP
`2851 Charlevoix Drive SE, Suite 207
`Grand Rapids, MI 49546
`Flory@glbf.com
`linn@glbf.com
`
`David K.S. Cornwell (Back-up Counsel)
`Salvador M. Bezos (Back-up Counsel)
`Sterne, Kessler, Goldstein & Fox PLLC
`1100 New York Avenue NW
`Washington, DC 20005
`Davidc-PTAB@skgf.com
`sbezos-PTAB@skgf.com
`
`
`Dated: September 29, 2015
`
`
`
`
`
`Respectfully submitted,
`
`/Tammy J. Terry/
`Tammy J. Terry
`Reg No. 69,167
`Terry@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713-228-8600
`Fax: 713-228-8778
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