Takeaway: A patent owner can rely on express definitions in the specification for claim construction.

In its Decision, the Board denied institution of inter partes review, because the Board determined that the information presented in the Petition did not show that there was a reasonable likelihood that Petitioner would prevail in establishing the unpatentability of any of claims 28-38 of the ’588 Patent. The ’588 Patent is directed to a system adapted to control a vehicle’s headlamps in response to sensing the headlight of oncoming vehicles and taillights of leading vehicles.

The Board started with claim construction. Petitioner had proposed specific construction of five claim terms, and Patent Owner had proposed a specific construction for two claim terms. The Board determined that only the one term that both Petitioner and Patent Owner proposed constructions needed to be interpreted for purposes of this decision. Petitioner proposed that the claim term “spatial filtering” should be construed to mean “categorization of data that involves an assessment of information obtained from both a first pixel or group of pixels and a second pixel or group of pixels, wherein the first pixel or group of pixels is adjacent or closely related to the second pixel or group of pixels.” Patent Owner asserted that this construction is wrong because it did not include a spectral signature component. The Board agreed with Patent Owner and determined that “spatial filtering” was expressly defined in the Specification to consider no only whether a particular pixel, or pixel group, is detecting a light source having a particular spectral signature, but also what adjacent, or closely related, pixels or pixel groups, are detecting.

The Board then turned to the asserted grounds of unpatentability, beginning with the assertion by Petitioner that the independent claims would have been obvious based on a combination of three references. The Board determined that Petitioner did not provide sufficient evidence showing that the references disclose or suggest “spatial filtering” as that term was construed.

TRW Automotive US LLC v. Magna Electronics Inc., IPR2014-00265
Paper 15: Decision Denying Institution of Inter Partes Review
Dated: June 26, 2014
Patent 8,222,588 B2
Before: Justin T. Arbes, Barry L. Grossman and Beverly M. Bunting
Written by: Grossman
Related Proceedings: Magna Electronics Inc. v. TRW Automotive Holding Corp., No. 1:12-cv-00654-PLM (W.D. Mich.)