On March 3, 2015, the PTAB issued two final written decisions, finding that most of the claims of a vehicle monitoring patent challenged by Toyota Motor Corp. in an America Invents Act inter partes review are obvious in view of prior art. Of the 26 originally issued claims, only eight claims remain after the final written decisions. The patent at issue, U.S. Patent No, 8,532,867, generally relates to sensors that collect and analyze data during the operation of a vehicle. According to the specification, through a combination of multiple memories and a single processor, that data is later used to diagnose the cause of irregularities associated with operating the vehicle. In the underlying lawsuit filed in September 2013, inventor Leroy G. Hagenbuch sued Toyota in the Northern District of Illinois. The district court stayed the case pending the outcome of Toyota’s IPR petitions.
Of the prior art considered when invalidating certain claims, the board highlighted two references, which in combination, describe onboard devices for recording particular conditions when operating a vehicle. In the first decision, IPR2014-00123, the PTAB determined that Toyota proved sufficiently that all but two of the challenged claims are invalid. According to the decision, “Toyota has established, by a preponderance of the evidence, that claims 15–20, 23, and 24 would have been obvious over” the prior art. In a separate final written decision issued that same day, IPR2014-00124, Toyota also proved that claims 1–7 and 10–12 of the ’867 patent are obvious; the auto manufacturer could not establish the same for claims 8, 9, 13 and 14. In both decisions, for those claims that survived, the PTAB focused on particular environmental conditions that the prior art references did not account for as well as the absence of multiple memories to store the data. For all others, “on balance, the evidence of obviousness outweigh[ed] the evidence of nonobviousness.”
Toyota Motor Corp. v. Leroy G. Hagenbuch, Nos. IPR2014-00123, IPR2014-00124 (P.T.A.B. March 3, 2015) (Lee, Kim, Plenzler, JJ.).