Invalidity dossier
US 10593205
GPS and warning system
Current assignee: Navog LLC
Added 9/29/2026, 7:28:45 AM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll verify current docket and USPTO status before summarizing.
Let me check for any Federal Circuit (CAFC) 2026 activity.
US Patent 10,593,205 — Verification Summary
Search scope note: I searched Google Patents (full text), the Stanford NPE Litigation Database, Justia/PACER docket mirrors, and litigation-intelligence summaries. I did not locate any Court of Appeals for the Federal Circuit (CAFC) 2026 docket naming US 10,593,205. All identified activity is at the district-court level. I cannot rule out an unindexed or very recent CAFC filing, so treat that as "none found," not "confirmed none."
Bibliographic Data (from the patent document itself — authoritative)
| Field | Value |
|---|---|
| Patent number | US 10,593,205 B1 |
| Title | GPS and warning system |
| Application no. | US 15/376,545 |
| Filing date | 2016-12-12 |
| Priority | Provisional Ser. No. 62/266,644, filed 2015-12-13 |
| Issue/grant date | 2020-03-17 |
| Inventor | Timothy Jones (assignment records render it "Jones, Timothy L") |
| Original assignee | Individual |
| Current assignee | NAVOG LLC (assignment of assignors' interest recorded 2025-10-10) |
| Claims | 10 total (2 independent) |
| Anticipated expiration | 2036-12-12 |
| Status | Active; 4th-year maintenance fee paid 2024-03-05 (micro entity, with late surcharge) |
Discrepancy flagged (do not auto-correct): One secondary source (an Ex Parte complaint analysis of Navog v. Garmin, 0:25-cv-60328) states the patent "claims priority to a 2013 provisional application" and lists the priority date as 2013-12-13. The patent's own CROSS-REFERENCE section and Google Patents' record both say December 13, 2015, which is the value I rely on. The "2013" appears to be an error in that secondary source.
Abstract (verbatim)
"A GPS and warning system is a GPS monitoring and alarm system that would warn truckers, bus and RV drivers, approaching underpasses, bridges, viaducts, tunnels, and other structures of insufficient clearance for their vehicle. With the vehicle height entered into the GPS and warning system, as well as including the actual measurements of each and every structure along with GPS coordinates, the intent is to safely alert, and reroute the driver, should the vehicle be approaching a structure with low clearance."
Independent Claims — Plain-Language Overview
Claim 1 — the system (apparatus) claim. A GPS-and-warning system for an automobile, made of five cooperating structural elements:
- (a) a main body with a hollow interior volume;
- (b) a computer module inside that volume, programmable with information about existing roads, bridges, viaducts, and underpasses;
- (c) a GPS module inside that volume, supplying location information for those roads/structures;
- (d) at least one warning mechanism electrically connected to the computer module, emitting a loud audible sound to warn the driver of impending danger; and
- (e) a display screen on the outer surface of the main body, electronically connected to the computer module, showing the driver visual information — specifically the height of an approaching bridge or underpass, and alternate routes to avoid dangers.
Functionally, the computer module must (i) process the stored structure information and current location, (ii) decide when to send an electronic signal to the warning mechanism, and (iii) trigger the warning when the device comes within a predetermined distance of a dangerous road, bridge, viaduct, or underpass.
Claim 6 — the combination claim. Recites the same system, but claimed as the combination of (a) an automobile having an engine and a passenger compartment, plus (b) the GPS-and-warning system located within the passenger compartment. The device elements (i)–(v) and the "predetermined distance" trigger are substantively identical to claim 1.
Dependent claims (2–5, 7–10): cover (2/7) the stored information including longitudinal/latitudinal coordinates and underpass clearance measurements; (3/8) adding a flashing light to the warning mechanism; (4/9) the computer module preventing vehicle operation until the device is turned on and activated (an ignition-interlock feature); and (5/10) a power source inside the hollow volume connected to the computer, GPS, and warning components.
Claim-drafting note: in the specification and figures the disclosure describes warning motorists about tunnels and refers to commercial trucks, buses, and RVs, yet the claims are limited to an "automobile" and to roads/bridges/viaducts/underpasses. That claim-to-specification mismatch is a live issue in the pending litigation.
Enforcement / Litigation Context (district courts, 2024–2026)
The patent is being asserted by Navog LLC, characterized in third-party reporting as a patent-assertion entity (NPE) and "an entity of Eric Zautner." Identified cases naming this patent:
| Case | Venue | Filed |
|---|---|---|
| Navog LLC v. Panasonic Corp. of North America, 6:24-cv-00258 | W.D. Tex. | 2024 |
| Navog LLC v. TomTom Int'l BV, 2:24-cv-00365 | E.D. Tex. | 2024 |
| Navog LLC v. Verizon Communications / Verizon Connect, 2:24-cv-00366 | E.D. Tex. | 2024 |
| Navog LLC v. Garmin International, 0:25-cv-60328 | S.D. Fla. | 2025-02-19 |
| Navog LLC v. Samsara Networks, 1:25-cv-00333 | D. Del. | 2025 |
| Navog LLC v. TeleType Co., 1:25-cv-10394 | D. Mass. | 2025 |
| Navog LLC v. Powerfleet, Inc., 1:26-cv-00032 | D. Del. | 2026-01-12 |
| Navog LLC v. Trucker Path, Inc., 1:26-cv-00033 | D. Del. | 2026-01-12 |
| Navog LLC v. Omnitracs, LLC, 4:26-cv-00254 | N.D. Tex. | 2026-03-06 |
Several of these (Panasonic, Verizon, TomTom, TeleType) were resolved by voluntary dismissal; the TeleType dismissal was without prejudice (FRCP 41(a)(1)(A)(i)) while the others were with prejudice. Third-party reporting indicates no claim-construction ruling, invalidity holding, or IPR institution on the patent as of these filings. Unified Patents ran a $2,000 PATROLL prior-art contest (Feb 25 – Apr 1, 2025) seeking art on at least claim 1, which indicates active validity challenge interest but is not itself a validity determination.
Uncertainty caveats: (1) Litigation details above derive from secondary aggregators (Stanford NPE database, dockets.justia.com, PatSnap, Ex Parte analysis) rather than my direct PACER review, so case statuses may have advanced since their last retrieval dates. (2) I found no CAFC 2026 docket for this patent; absence of evidence here should not be read as a definitive negative. (3) Claim construction positions attributed to parties are advocates' arguments, not court holdings.
Generated 9/29/2026, 12:54:27 PM
Cases on file (13)
Group view →Specific litigation cases in our database that name US patent 10593205. The free-form analysis below may also discuss cases beyond this list.
Lawsuits filed per year
- Navog LLC v. Omnitracs, LLCfiled Mar 6, 20264:26-cv-00254N.D. Tex. (O'Connor)terminated Mar 26, 2026dismissed
Defendants: Omnitracs, LLC
- Navog LLC v. Powerfleet, Inc.filed Jan 12, 20261:26-cv-00032D. Del. (Williams)pending
Defendants: Powerfleet, Inc.
- Navog LLC v. Trucker Path, Inc.filed Jan 12, 20261:26-cv-00033D. Del.pending
Defendants: Trucker Path, Inc.
- Navog LLC v. Samsara Networks Inc.filed Mar 18, 20251:25-cv-00333D. Del. (Williams)terminated Apr 3, 2025voluntary dismissal
Defendants: Samsara Networks Inc.
- Navog LLC v. Garmin International, Inc.filed Feb 19, 20251:25-cv-20787S.D. Fla. (Leibowitz)active
Defendants: Garmin International, Inc.
- Navog LLC v. TeleType Co., Inc.filed Feb 17, 20251:25-cv-10394D. Mass. (Stearns)dismissed without prejudice
Defendants: TeleType Co., Inc.
- Navog LLC v. Panasonic Corp. of North Americafiled May 16, 20246:24-cv-00258W.D. Tex.voluntary dismissal
Defendants: Panasonic Corp. of North America
- Navog LLC v. RM Acquisition, LLCfiled May 16, 20241:24-cv-04023N.D. Ill.unresolved
Defendants: RM Acquisition, LLC
- Navog LLC v. Trimble Inc.filed May 16, 20241:24-cv-01378D. Colo.terminated Jul 23, 2024closed
Defendants: Trimble Inc.
- Navog LLC v. Sygic a.s.filed May 16, 20242:24-cv-00364E.D. Tex. (Gilstrap/Payne)open (unverified)
Defendants: Sygic a.s.
- 2:24-cv-00365E.D. Tex.dismissed with prejudice
Defendants: TomTom International BV
- 2:24-cv-00366E.D. Tex.dismissed with prejudice
Defendants: Verizon Communications Inc., Verizon Connect Inc.
- 1:25-cv-01395D. Del.unidentified
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search for current litigation records on this patent across the sources you named.
Let me pull the remaining dockets listed in the patent's litigation record and check for any appeal activity.
Method and source caveats
I searched the sources you named plus adjacent databases: Unified Patents (PATROLL contest page + litigation portal entries embedded in the patent's Google Patents record), Justia Dockets, RPX Insight, UniCourt, CourtListener/RECAP, PACER Monitor, PatSnap Eureka summaries, and the Stanford NPE Litigation Database — all keyed to US 10,593,205 (app. 15/376,545) only. I did not directly query PACER/CourtListener for a Federal Circuit docket; I found no CAFC appeal naming this patent or its owner. Two docket numbers in the record remain unidentified as to defendant (below). Everything here is tied to 10,593,205; no similar numbers are reported.
Two corrections to the previously generated section:
- The prior summary listed Garmin, 0:25-cv-60328 (S.D. Fla.) as one case. That docket was administratively closed for "Wrong Venue selected by Filer" and renumbered 1:25-cv-20787 — same case, not two. Clerk's notice: "Case administratively closed – WrongVenue selected by Filer. CASE HAS BEEN RENUMBERED, the new case number is 1:25-cv-20787." (PatSnap, Justia case list)
- The prior summary omitted four cases: RM Acquisition (Rand McNally), Trimble, Sygic, and an unidentified E.D. Tex. 2026 docket. It also characterized Verizon/TomTom as "voluntary dismissals" — both were actually joint stipulations dismissed WITH prejudice (a consensual resolution, not a Rule 41(a) plaintiff's exit).
Known litigation involving US 10,593,205
Plaintiff in every identified case is Navog LLC (NM corporation, principal place of business Albuquerque, NM; described by Unified Patents as an NPE and "entity of Eric Zautner"). Current assignee per USPTO assignment records: Navog LLC (recorded 2025-10-10).
| # | Case | Court | Case No. | Filed | Status |
|---|---|---|---|---|---|
| 1 | Navog v. Panasonic Corp. of North America | W.D. Tex. | 6:24-cv-00258 | 2024-05-16 | Voluntary dismissal (per prior analysis) |
| 2 | Navog v. RM Acquisition, LLC (Rand McNally) | N.D. Ill. | 1:24-cv-04023 | 2024-05-16 | Not resolved in my sources; RPX flagged local-rule noncompliance |
| 3 | Navog v. Trimble Inc. | D. Colo. | 1:24-cv-01378 | 2024-05-16 | Closed 2024-07-23 (RPX) |
| 4 | Navog v. Sygic a.s. | E.D. Tex. (Gilstrap/Payne) | 2:24-cv-00364 | 2024-05-16 | Last docket activity 2025-03-10; no dismissal order found |
| 5 | Navog v. TomTom International BV | E.D. Tex. | 2:24-cv-00365 | 2024 | Dismissed WITH prejudice by joint stipulation; each side bears own costs |
| 6 | Navog v. Verizon Communications Inc. / Verizon Connect Inc. | E.D. Tex. | 2:24-cv-00366 | 2024 | Dismissed WITH prejudice by joint motion |
| 7 | Navog v. TeleType Co., Inc. | D. Mass. (Stearns) | 1:25-cv-10394 | 2025-02-17 | Dismissed WITHOUT prejudice, FRCP 41(a)(1)(A)(i) |
| 8 | Navog v. Garmin International, Inc. | S.D. Fla. (Leibowitz) | 0:25-cv-60328 → 1:25-cv-20787 | 2025-02-19 | Live; renumbered docket, no merits ruling |
| 9 | Navog v. Samsara Networks Inc. | D. Del. (Williams) | 1:25-cv-00333 | 2025-03-18 | Voluntary dismissal; terminated 2025-04-03 |
| 10 | Navog v. Powerfleet, Inc. | D. Del. (Williams) | 1:26-cv-00032 | 2026-01-12 | Pending; answer deadline extended 2026-02-13 |
| 11 | Navog v. Trucker Path, Inc. | D. Del. | 1:26-cv-00033 | 2026-01-12 | Pending (docket last retrieved 2026-01-12) |
| 12 | Navog v. Omnitracs, LLC | N.D. Tex. (O'Connor) | 4:26-cv-00254 | 2026-03-06 | Terminated 2026-03-25/26 — defendant answered + counterclaimed (Fish & Richardson), then joint stipulation of dismissal |
Unidentified dockets carried in the patent's own litigation record (defendants not confirmed in my searches):
- D. Del. 1:25-cv-01395
- E.D. Tex. 2:26-cv-00043
Both appear in the litigation list on the patent's Google Patents page. Navog is a documented serial filer of companion suits in paired venues, so these are likely additional accused GPS/navigation or telematics defendants, but I will not guess at parties.
Notable details per case
TomTom (2:24-cv-00365) — Verbatim order: "the above-captioned case has been resolved and request dismissal of the above-captioned action WITH prejudice… Each party is to bear its own costs, expenses, and attorneys' fees." Defendant-side counsel included Whitmyer IP Group and Cherry Johnson Siegmund James. (PatSnap)
Verizon (2:24-cv-00366) — Joint motion granted verbatim; with-prejudice dismissal, each party bears own costs, no § 285 fee award. (PatSnap)
TeleType (1:25-cv-10394) — "Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), Plaintiff hereby dismisses this action without prejudice. Defendant has not yet answered the Complaint." Filed February 17, 2025; dismissed ~92 days later. Claims against TeleType are not extinguished.
Garmin (1:25-cv-20787) — Complaint filed 2025-02-19 in S.D. Fla. against Garmin International, Inc. (a Kansas corporation, place of business 513–515 Lincoln Road, Miami Beach, FL); plaintiff counsel Beusse Sanks PLLC. Accused product charted: Garmin dēzl 580 LMT-S. Pleaded direct, induced, and willful infringement (knowledge predicated solely on service of the complaint). This is the only case on this patent where I found a public claim-construction issue teed up — "predetermined distance" (whether a dynamically variable alert distance satisfies the limitation). That is advocates' framing from the pleadings, not a court ruling. (Complaint text via RPX, complaint analysis)
Omnitracs (4:26-cv-00254) — Fastest resolution on the docket: filed 2026-03-06, answered with a counterclaim 2026-03-23, joint stipulation of dismissal 2026-03-25, case terminated 2026-03-26. The dismissal terms (with or without prejudice) are not visible in the excerpt I retrieved — flagging that as unknown rather than assuming.
Samsara (1:25-cv-00333) — Notice of voluntary dismissal filed 2025-03-19, one day after filing; so-ordered by Judge Williams 2025-04-03.
Trimble (1:24-cv-01378) — RPX shows closed 2024-07-23, ~69 days after filing. Judge recusal (Varholak) reassigned to Chief Judge Brimmer before closure. Dismissal terms not confirmed.
Sygic (2:24-cv-00364) — E.D. Tex. before Judge Gilstrap; complaint filed 2024-05-16. RPX reports latest docket entry 2025-03-10 and 356 days in litigation; UniCourt listed status "Open" as of mid-2024. Whether this case remains pending or was dismissed after March 2025 is unverified.
Non-litigation validity challenge (context, not litigation)
- Unified Patents PATROLL contest, $2,000 prize, seeking prior art on at least claim 1 of US 10,593,205; start 2025-02-25, end 2025-04-01. Unified characterizes the patent as asserted against "Garmin, TeleType Co., and Sygic." (PATROLL, Unified News)
- I found no IPR, PGR, or ex parte reexamination instituted against this patent, and no CAFC appeal docket.
What I could not verify (stated plainly)
- Case 1:24-cv-04023 (RM Acquisition/Rand McNally) — I found the filing and RPX's local-rule observation but no termination record.
- Sygic current status after March 2025.
- Omnitracs dismissal terms (with/without prejudice).
- D. Del. 1:25-cv-01395 and E.D. Tex. 2:26-cv-00043 — defendants unidentified.
- Legal status of the patent — Google Patents shows "Active," 4th-year maintenance fee paid 2024-03-05 (micro entity, late surcharge). No reexamination certificate noted.
- No CAFC activity found for this patent in 2026 — absence of evidence, not a confirmed negative.
- Most docket details above come from secondary aggregators (Justia, RPX, UniCourt, PACER Monitor, PatSnap, Stanford NPE DB) rather than my direct PACER retrieval, so statuses may have advanced past each source's last-retrieved date.
The substantive claim-scope exposure remains where the prior section flagged it: the claims recite an "automobile" while every accused product is a truck/commercial navigation device, and the term "predetermined distance" is the only claim term with an identified construction dispute. No court has construed either term.
Consistency note: the prior section's table for this patent is otherwise accurate as to filing years and venues, but should now be read with the Garmin renumbering correction, the switch of Verizon/TomTom from "voluntary dismissal" to "with-prejudice joint stipulation," and the addition of RM Acquisition, Trimble, and Sygic.
Generated 9/29/2026, 1:01:13 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: Navog LLC
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the canonical "no PTAB activity" default with targeted searches before writing the analysis.
Let me run a few more targeted checks for any petition that may have followed the 2025 PATROLL contest, plus any reexam or Federal Circuit appeal.
No IPR/PGR/CBM proceeding is on file for this patent, and four rounds of searching (Google Patents full text, the PATROLL contest page, Unified Patents' own news archive, Stanford NPE database/PACER mirrors) surfaced no petition. Below is the analysis built on that negative finding, plus the practical consequences of it.
Proceedings overview
Total AIA trial proceedings on US 10,593,205: zero (0 active; 0 instituted; 0 claims invalidated; 0 claims sustained; 0 settled; 0 institution denied). All 10 claims — independent claims 1 and 6 and dependents 2–5 and 7–10 — are completely untested at the PTAB, which means a defendant gets neither the windfall of canceled claims nor the defensive certainty of a hardened patent: you are facing a never-challenged patent whose only validity vetting was the examiner's original prosecution, and no § 315(e) estoppel has been created by anyone.
No proceedings to enumerate
Per the structured "PTAB proceedings on file" block (USPTO ODP, canonical): "The USPTO ODP API returns no AIA trial proceedings for this patent as of the most recent ingest."
I attempted to falsify that default with web search and could not. Specifically, I found no petitioner, no petition number, no institution decision, no FWD, and no Federal Circuit appeal docket for this patent. I am reporting absence of evidence, and I am explicitly not asserting this is a confirmed negative — a petition filed in the last several weeks may simply not be indexed yet. Note also that no proceeding number appears anywhere in the record above, and I will not manufacture one.
What I did find that is adjacent but is not an AIA trial on this patent (do not confuse these with IPRs on the '205 patent):
| Item | What it is | Relevance |
|---|---|---|
| Unified Patents PATROLL contest, US 10,593,205 (start 2025-02-25, end 2025-04-01, $2,000) | Crowd-sourced prior-art bounty, not a filed proceeding | Strongest available lead set for invalidity; Unified solicited art on "at least claim 1" and explicitly excluded art already cited during prosecution. PATROLL contest page; Unified news post |
| Unified Patents' ex parte reexaminations against other NPE patents (e.g., U.S. 8,593,349 on 2025-02-21) | Ex parte reexam at the CRU — not a PTAB trial, not indexed in the ODP AIA-proceedings data | Demonstrates Unified's alternative playbook when it declines an IPR; reexams hit an all-time high of 726 requests in 2025 per Unified's 2025 in Review |
| The $2,000 contest expiring 2025-04-01 with no IPR following | Inference, not fact | Either no qualifying submission was received, or Unified (which is not a party to the Navog litigations) chose not to spend on a challenge — consistent with the PTAB institution climate described below |
Contradiction check against the earlier-generated sections: none found in the PTAB analysis. Two additions to flag rather than contradictions: (1) Unified's notices state the '205 patent "has been asserted against Garmin, TeleType Co., and Sygic" — Sygic does not appear in the case table in the earlier sections, so that assertion (venue/case number unknown to me) is unaccounted for; (2) the S.D. Fla. Garmin docket 0:25-cv-60328 was administratively closed as "wrong venue selected by Filer" and renumbered 1:25-cv-20787, which matches the Google Patents litigation list but is worth stating because the older docket number is the one cited in the complaint-analysis source. Neither affects the PTAB conclusion.
Strategic summary
Claim status: all 10 claims UNTESTED. No AIA trial has reached an institution decision, let alone an FWD, so there is nothing to quote and no claim to link to as "canceled." Independent claims 1 and 6, and dependents 2–5 and 7–10, retain their full issued scope. The only validity filter they have ever passed is ex parte prosecution — where the examiner had before him the 27 references listed on the face of the patent, including the most on-point one, US 2004/0201495 A1 (Lim, "Digital coded horizontal overhead obstacles warning system for vehicles"). That matters for strategy: any IPR ground built on Lim or the other of-record references runs straight into § 325(d) and the Advanced Bionics two-part framework, whereas the PATROLL contest's stated exclusion of prosecution-cited art tells you Unified was hunting for new art precisely to avoid that problem.
Estoppel landscape: because no IPR or PGR has ever been instituted or decided, no § 315(e)(2) estoppel exists against anyone today. The estoppel traffic runs the other way for you: if you file an IPR and lose, § 315(e)(2) bars you (and your privies) from asserting in district court any ground you raised or reasonably could have raised in that IPR — a broad, near-total bar on § 102/§ 103 defenses. Compounding that, the USPTO's October 2025 proposed rules would require petitioners to abandon all § 102/§ 103 defenses in all other forums simply to be eligible for institution (per Unified's 2025 in Review, above). Meanwhile, § 315(b) may already have closed the IPR door on the older defendants: the one-year clock runs from service of the complaint. On the filing dates in the earlier sections (Panasonic 2024; TomTom, Verizon 2024; TeleType 2025-02-17; Garmin 2025-02-19; Samsara 2025-03-18), each of those defendants was served — at the latest — before 2025-09-29, i.e. more than a year before today's date of 2026-09-29. I cannot confirm actual service dates (I have filing dates from aggregators, not returns of service), and service frequently lags filing, so treat this as a high-priority item to verify for your own case rather than a settled bar. Only the 2026 defendants (Powerfleet and Trucker Path, both 2026-01-12; Omnitracs, 2026-03-06) are plainly still inside the window. PGR is unavailable — § 321(c) set a nine-month post-grant deadline that ran out on 2020-12-17. CBM is doubly unavailable — the transitional program sunset in 2020 and this patent is a technological invention, not a financial-services claim. IPR, or ex parte reexam, are the only realistic Office vehicles.
Pattern signals: no petitioner has ever filed against this patent — not a single one, across a nine-case, three-year campaign by Navog LLC (an entity of Eric Zautner per Unified). The patent owner has therefore never had to defend a claim in an adversarial validity forum. The mirror image is also telling: Navog has avoided merits adjudication in the district courts as well. TomTom and Verizon exited by with-prejudice dismissal, Panasonic likewise, and TeleType by Rule 41(a)(1)(A)(i) dismissal without prejudice before any answer — meaning Navog preserved the right to refile against TeleType while avoiding any ruling. That is a classic hold-and-settle pattern: rapid, cost-bearing-neutral exits, no Markman order, no invalidity holding, and no IPR on the docket in over three years of assertions. Unified Patents is in the chain as a defensive aggregator that laid bait but did not bite — the PATROLL contest expired with no resulting PTAB filing that I can find. For an accused infringer, the practical read is that Navog's claims have never been stress-tested, but also that no defendant has yet been willing to fund the test — which makes an early, well-funded, non-barred IPR with new (not-of-record) art the highest-leverage move available.
Recommended next steps
Do not expect to find a proceeding — there is none. Confirm independently by running the patent number in USPTO PTAB E2E / PTAB Center (
https://ptacts.uspto.gov/ptacts/) and in CourtListener (https://www.courtlistener.com/?q=10%2C593%2C205) before you tell a client or a court that no AIA trial exists. My conclusion is grounded in the ODP canonical block plus search; it is not a substitute for a direct PTAB E2E docket pull.Pull your § 315(b) service date first — it decides everything else. One year from service of a complaint alleging infringement of the '205 patent. If you are inside the window, calendar the petition now; if you are outside it, your remaining options are (a) joinder under § 315(c) to an existing instituted IPR — but § 315(b)'s last sentence exempts joinder requests from the time bar only if there is a timely-filed, instituted petition to join, and none exists here; or (b) ex parte reexamination, which has no § 315(b) bar, no estoppel, can be filed anonymously by a third party, and — per Unified's own 2025 data — is where challengers are now going in record numbers (726 requests in 2025, up 66.1%). Reexam cannot cancel claims with the finality of an FWD, but a reexam certificate canceling claims 1–10 would end the campaign.
Budget for discretionary denial, not just for the merits. Even with good art, the '205 patent presents a rough discretionary-denial profile: it has been in force since 2020-03-17 (about six and a half years — squarely within the Director's "settled expectations" rationale, which was invoked in the decision excerpt I retrieved at
IPR2025-00408), it has never been adjudicated, and there is parallel litigation in up to five districts. Assume you will need to address Fintiv, General Plastic, Advanced Bionics/§ 325(d), and a Sotera-style stipulation up front, and assume the Director — who since 2025 has personally taken institution determinations — will be the decision-maker on institution.Get the PATROLL submissions. The $2,000 contest that ran 2025-02-25 to 2025-04-01 specifically sought art on at least claim 1, excluding prosecution-cited art. Whether or not a winner was announced publicly, the contest parameters tell you the art universe Unified considered viable. Pair any candidate references against the 27 references already of record — principally US 2004/0201495 A1 (Lim) — and pin down whether your ground is genuinely new before you file, because § 325(d) is the single most likely reason an otherwise-good petition never gets instituted.
Anchor the parallel § 112 defense now, in case IPR is foreclosed. As the earlier sections note, the claims recite an "automobile" while the specification's stated purpose is warning "truckers, bus and RV drivers" about "tunnels" — structures and vehicles that appear nowhere in the claim language (claim 1 covers "roads, bridges, viaducts, and underpasses"; no tunnel). That mismatch is a written-description/claim-scope argument you can preserve regardless of whether you are time-barred at the PTAB, and it costs nothing to plead.
If you are inside the window and do file, treat estoppel as a one-way door. A final written decision — win or lose — triggers § 315(e)(2) against you on every ground raised or reasonably raisable. Decide before filing whether you can afford to give up your district-court § 102/§ 103 case, especially since the pending proposed rules would make that give-up a precondition to eligibility anyway. The corollary: because no estoppel burdens anyone today, your non-IPR invalidity theories are fully preserved right now — protect that optionality until you have a verified service date and a verified art set.
Generated 9/29/2026, 1:01:21 PM
Ownership chain (1)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2025-10-10 · Assignment
transfer-to-asserter
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research the assignment chain, correspondent of record, and asserter-directory details before building the timeline.
Let me dig for the reel/frame and correspondent details, plus Navog's asserter-directory profile.
Let me try to pull the recorded assignment's reel/frame and correspondent directly.
I was unable to complete all planned lookups before hitting the retrieval limit, so I want to be precise about what is verifiable versus what I could not retrieve. The critical caveat up front: the reel/frame number and the correspondent of record for the Navog assignment were not surfaced in any source I could access. I will not invent them.
Inventors
| Inventor | Employer at time of filing | Basis |
|---|---|---|
| Timothy Jones (assignment records render it "Jones, Timothy L") | Not determinable — no employer identified | Sole named inventor on US 10,593,205; app. 15/376,545 |
- The patent issued to an individual applicant with no corporate co-applicant and no recorded pre-issue assignment. Google Patents lists the original assignee only as "Individual." That means, on the face of the record, Jones owned the grant personally from issuance (2020-03-17) until the Navog transfer.
- No inventorship-departure pattern is determinable. With a single inventor who is also the original owner, the "all inventors left the assignee within 12 months" tell cannot arise.
- One breadcrumb on commercial intent: the specification's Field of the Invention refers to entering vehicle height "into the Sure Pass database," which reads as an intended product/brand name. I could not verify that any "Sure Pass" product was ever sold. Flagging it as a lead, not a finding.
Original assignee
- Entity named on the issued patent: none above the individual. The grant issued to Timothy Jones as an individual (Google Patents "Original Assignee: Individual"; no assignment appears on the patent's face or in its pre-issue legal events).
- Product embodying the claims: no evidence of a shipped commercial product was found in any source I searched. The device is described as a self-contained in-vehicle GPS/low-clearance warning unit, but I found no product literature, no "Sure Pass" product listing, and no corporate assignee that could have manufactured it.
- Primary line of business: not determinable — the record shows a solo inventor, not an operating company.
- Current status: no evidence of acquisition, dissolution, or bankruptcy as to Jones. Rights were transferred to Navog LLC (recorded 2025-10-10). This is an inventor-to-asserter chain, not an operating-company-to-asserter chain.
Assignment timeline
Important limitation. I could confirm one post-issuance recordation from the Google Patents legal-events block, which reproduces the Assignment Center event as: "2025-10-10 — Assigned to NAVOG LLC — reassignment — ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: JONES, TIMOTHY L." That summary does not expose the reel/frame, the execution date, or the correspondent. I was not able to retrieve the underlying Notice of Recordation, and I will not fabricate those fields.
- YYYY-MM-DD (executed) — not retrievable / recorded 2025-10-10 — Reel NNNNNN/NNNN — not retrieved
- Conveyance: Assignment ("Assignment of Assignors' Interest")
- Assignor: Jones, Timothy L
- Assignee: Navog LLC (NM corporation; principal place of business pleaded as 1209 Mountain Rd PL NE STE N, Albuquerque, NM 87110)
- Correspondent: not retrieved. The Google Patents legal-events summary omits the correspondent, and no secondary aggregator I checked publishes it. Because the correspondent is the single most diagnostic field you asked for, this must be pulled directly from the Assignment Center record (see verification link below) — I cannot state a name without inventing one.
- Context: transfer-to-asserter (individual inventor → single-purpose enforcement LLC).
No other recorded assignments were found. Specifically:
- No pre-issue assignment from Jones to any employer or company.
- No security agreement, merger, change of name, license, release, or correction recorded against this patent in the sources I could reach.
- Chain-of-title anomaly worth flagging: Navog began suing on this patent in May 2024 (Panasonic 6:24-cv-00258, RM Acquisition 1:24-cv-04023, Trimble 1:24-cv-01378, Sygic 2:24-cv-00364, TomTom 2:24-cv-00365, Verizon 2:24-cv-00366), yet the only recorded transfer is dated 2025-10-10 — roughly 17 months after the first complaints, in which Navog pleaded it "is the assignee of all right, title and interest." Either (a) the assignment was executed in 2024 and merely recorded late, (b) the document was executed and back-dated/confirmatory, or (c) Navog sued on equitable/beneficial title before recordation. This is a standing and chain-of-title question you should resolve from the face of the assignment document, not from the indexing summary.
- Micro-entity timing note: the 4th-year maintenance fee was paid 2024-03-05 under micro-entity status (with late-payment surcharge), i.e. before Navog's 2025-10-10 recordation. That is consistent with Jones still owning the patent in early 2024; it also means the micro-entity certifications should be checked against the true ownership dates if the assignment was in fact executed in 2024.
Timeline diagram
timeline
title Ownership of US 10593205
2015 : Provisional filed by inventor
2016 : Utility application filed as individual
2020 : Patent issued to Timothy Jones
2024 : Navog files first infringement suits
2025 : Assignment recorded to NAVOG LLC
NPE / troll-pattern signals
Shell-entity transfer — present. The patent moved from individual inventor Jones to Navog LLC by assignment recorded 2025-10-10. Supporting evidence beyond the name: Navog is a single-purpose enforcement vehicle — it pleads itself as holder of "the exclusive right and standing to prosecute" and describes a licensing/enforcement posture; its pleaded address is a suite-style mail address ("1209 Mountain Rd PL NE STE N, Albuquerque, NM 87110"); and no Navog product was found in commerce. (Note: the LLC name lacks the "IP/Holdings/Ventures" suffix, so the call rests on conduct, not naming.) Caveat: the reel/frame was not retrievable, so cite the 2025-10-10 recordation date as the anchor, pending a direct reel/frame pull.
Known asserter in the chain — present. Navog LLC does not appear on the enumerated classic lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation, Spangenberg). However, it is surfaced by two independent asserter directories: Unified Patents ("owned and asserted by Navog LLC, an NPE and entity of Eric Zautner") and the Stanford NPE Litigation Database, which categorizes Navog's assertions under "Acquired patents" / "Non Practicing Entity." That is directory-sourced, not name-sourced, evidence.
Repeat correspondent across the chain — unclear. I could not retrieve the assignment correspondent of record, so I cannot assess recurrence on the one recorded link. What I can report is a repeat-player litigation-counsel bench, which is a related but distinct signal: Navog's complaints across the campaign carry Rabicoff Law LLC (Isaac Phillip Rabicoff) and DNL Zito (Benjamin Charles Deming) in the TomTom matter, Dickinson Wright PLLC (Christopher E. Hanba) in TeleType, and Beusse Sanks PLLC (Terry Marcus Sanks) in Garmin. Rabicoff Law in particular is a recognized high-volume patent-plaintiff firm. This is per PatSnap/PACER summaries (secondary sources), and it is counsel of record in litigation — not the assignment correspondent. Do not treat it as satisfying signal 3 until the Assignment Center correspondent field is confirmed.
Cascading transfers — not present. Only one recorded transfer exists; there is no chain of successive LLCs, no shared correspondent address across multiple links, and no sub-24-month cascade. The 2025 assignment is a single hop.
Pre-litigation transfer — not present as recorded; inverse anomaly present. The signal as defined (executed assignment within 6 months before the first suit) is not established, because the first suits were filed 2024-05-16 and the recorded assignment is 2025-10-10 — after suit. The inverse is the finding: post-filing recordation, which raises the title question described above.
Bankruptcy fire-sale — not present. No evidence the inventor or any assignee filed Chapter 7/11, and no sale-in-proceedings. The transferor is a natural person.
Privateering — not present. There is no operating company in the chain transferring to an NPE to assert against competitors. The transferor is the individual inventor and there is no SEC-docketed, Patent Progress, or EFF coverage tying this patent to a corporate sponsor.
Defensive aggregator — not present. The chain ends at Navog, an asserter. It does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. Notably, Unified Patents targeted this patent with a $2,000 PATROLL prior-art bounty (2025-02-25 to 2025-04-01) rather than acquiring it — the opposite of neutralization.
Verdict
NPE — high confidence.
Two strong signals: (i) shell-entity transfer — the sole recorded assignment moves the patent from individual inventor Jones, Timothy L to Navog LLC, recorded 2025-10-10, an enforcement-only LLC with a suite-style Albuquerque address and no product in commerce; and (ii) known asserter in the chain — Navog is independently classified as an NPE/acquired-patent asserter by both Unified Patents (an "entity of Eric Zautner") and the Stanford NPE Litigation Database, and is the sole plaintiff across a nine-plus-case campaign on this patent. The anomaly that Navog sued beginning 2024-05-16 but the ownership record only shows the 2025-10-10 transfer reinforces the arranged-for-assertion character of the chain and is itself a title issue worth pursuing.
Two items I could not verify and that you should treat as open, not settled: the reel/frame, the execution date, and the correspondent of record on the 2025-10-10 assignment (these require a direct pull — the indexing summary in the sources I reached omits all three). Verify at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (search patent 10593205; the parallel index is https://assignment.uspto.gov/patent/index.html), and cross-check the face of the recorded document against the Google Patents legal-events entry at https://patents.google.com/patent/[US10593205B1](/patent/US10593205B1)/en.
Consistency note against the earlier-generated sections: nothing here contradicts them; this section fills a gap they left. The prior sections correctly identified Navog LLC as current assignee with a 2025-10-10 assignment record, but they did not surface (a) that the original owner was an individual inventor, not a company — so there is no operating-company assignee anywhere in this chain, and (b) that the recorded assignment post-dates the first 2024 infringement filings by ~17 months. Point (b) is the one that may matter: if the assignment was executed only in 2025, the well-pleaded-in-2024 "assignee of all right, title and interest" allegation in the Panasonic, RM Acquisition, Trimble, Sygic, TomTom, and Verizon complaints is a standing question, not just a formality.
Generated 9/29/2026, 1:01:58 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll verify the key references and check for any PATROLL-submitted art before building the § 102 analysis.
Let me verify the remaining substantive references most likely to bear on the clearance-warning claims.
Prior-Art Analysis — US 10,593,205 B1 ("GPS and warning system")
Anchor: US Patent No. 10,593,205 B1 (app. 15/376,545, filed 2016-12-12, priority to provisional 62/266,644 filed 2015-12-13). All searching and analysis below was keyed to exactly that number and application; I deliberately excluded near-numbers (e.g., 10,593,205 vs. 10,953,205 / 10,392,205-class neighbors). This section builds on — and does not repeat — the earlier bibliographic, litigation, and PTAB sections.
Date note / discrepancy flag: The task header states "Current Date: April 26, 2026," whereas the earlier-generated sections were prepared against a 2026-09-29 date and the tool environment timestamps reads at 2026-09-29. That 5-month gap does not change the prior-art universe here (all art predates the 2015 priority), but it does mean the § 315(b) service-date discussion in the PTAB section should be re-checked against whichever "today" you adopt.
1. The controlling § 102 framework for this patent
Because the application was filed after 2013-03-16, the AIA governs. The relevant provisions are § 102(a)(1) (patented, described in a printed publication, or in public use before the effective filing date) and § 102(a)(2) (US patents/applications "effectively filed" before the effective filing date).
Two points drive every entry below:
- Anticipation requires a single reference disclosing every limitation, arranged as claimed. For claim 1 that means all of: a main body forming a hollow interior volume; a computer module located within that volume; a GPS module located within that volume; a warning mechanism electrically connected and emitting a loud audible sound; a display screen upon an outer surface showing the height of an approaching bridge or underpass and alternate routes; plus the processing and predetermined-distance trigger logic. Claim 6 adds the automobile-with-passenger-compartment wrapper.
- A dependent claim incorporates its parent. Claims 2–5 cannot be anticipated by a reference that does not disclose all of claim 1; likewise claims 7–10 vs. claim 6. So a reference that discloses only, say, a flashing light (claim 3) or an ignition interlock (claim 4) is not a § 102 anticipation of anything — it is § 103 material.
Bottom line up front: None of the references of record is a single-reference § 102 anticipation of any of claims 1–10. The of-record set is overwhelmingly § 103 (obviousness) material, and — critically — even the closest references fail on the same element: a GPS module co-located with a programmable computer module inside a single hollow-bodied unit. That is consistent with the patent issuing in 2020 over all 27 references.
2. The most relevant prior art (ranked)
| Rank | Reference | Why it matters |
|---|---|---|
| 1 | US 2004/0201495 A1 (Lim) | Closest to the purpose: overhead-obstacle/low-bridge clearance warning, in-vehicle display of bridge height, audible + flashing alert, warns 2–5 miles out. |
| 2 | US 2015/0179069 A1 (Cellco/Verizon) | Compares bridge clearance height vs. vehicle height, alerts the driver, and displays bridge height + an alternate-route arrow. |
| 3 | US 2013/0147955 A1 (Denso) | Warning system that determines danger based on the size of the host vehicle relative to a detected road object. |
| 4 | US 2016/009276 A1 (Alcatel-Lucent) | "In-the-road, passable obstruction avoidance." |
| 5 | US 2016/0351050 A1 (Aisin AW) | Warning guidance fed into vehicle navigation systems. |
| 6 | US 2005/0164673 A1 & US 2007/0138347 A1 (Ehlers) | On-board vehicle information systems feeding road/hazard data to the operator. |
| 7 | US 2013/0048403 A1 (Doinoff) | Ignition interlock — the only of-record art aimed at the "prevent operation until activated" feature of claims 4/9. |
| 8 | US 5,220,507 A (Motorola) | Multiple/alternate navigation routes — relevant to the "alternate routes" limitation. |
| 9 | US 2008/0162034 A1 (GE) | Automatic geo-fence generation — relevant to "predetermined distance" triggering. |
| 10 | US 6,748,325 B1 (Fujisaki) | Navigation system with route guidance. |
3. Reference-by-reference analysis (all 27 of-record citations)
Columns follow the Google Patents citation-table semantics: Priority date / Publication date. All 27 are marked "*" (cited by the examiner). "§ 102 candidacy" states whether the reference alone can anticipate a claim, and if not, which independent-claim element it fails.
| # | Reference | Priority | Published | Assignee/Inventor | Subject (brief) | § 102 candidacy |
|---|---|---|---|---|---|---|
| 1 | US 5,220,507 A | 1990-11-08 | 1993-06-15 | Motorola | Land-vehicle multiple navigation route apparatus | None — no clearance warning, no GPS-in-body, no display of bridge height. § 103 art for "alternate routes." |
| 2 | US 6,650,995 B2 | 2001-02-26 | 2003-11-18 | Motorola | Method of optimizing traffic content | None. Traffic-broadcast art. |
| 3 | US 2002/0120390 A1 | 2001-02-26 | 2002-08-29 | Bullock | Optimizing traffic content | None. Family of #2/#4/#5. |
| 4 | US 2002/0120388 A1 | 2001-02-26 | 2002-08-29 | Motorola | Optimizing traffic content | None. |
| 5 | US 6,463,382 B1 | 2001-02-26 | 2002-10-08 | Motorola | Optimizing traffic content | None. |
| 6 | US 6,748,325 B1 | 2001-12-07 | 2004-06-08 | Iwao Fujisaki | Navigation system | None — conventional nav; no clearance/height data, no warning mechanism, no hollow-body integration. |
| 7 | US 2003/0125846 A1 | 2002-01-02 | 2003-07-03 | Yu (IBM) | Distributing information to a vehicle operator | None — info delivery, no clearance. |
| 8 | US 6,865,476 B1 | 2003-02-12 | 2005-03-08 | Jokerst, Sr. | Nautical waypoints and routes data sets | None — marine route data; no clearance warning. |
| 9 | US 2004/0201495 A1 | 2003-04-11 | 2004-10-14 | Hee Chuan Lim | Digital coded horizontal overhead obstacles warning system for vehicles | Closest of-record; still not anticipatory. Discloses in-vehicle display of bridge height, audible warning, flashing indicator — but no GPS module providing structure location, no programmable road/structure database in the unit, no alternate-route output. Gap on claim 1 elements (b),(c),(e-alt routes). |
| 10 | US 2005/0164673 A1 | 2003-12-23 | 2005-07-28 | Gregory Ehlers | Info to an operator of an emergency response vehicle | None — road/hazard info delivery; no GPS-in-body clearance system. § 103 material. |
| 11 | US 2007/0138347 A1 | 2004-12-16 | 2007-06-21 | Gregory A. Ehlers | Info to an operator of a vehicle | None — same family; § 103 material. |
| 12 | US 9,193,375 B2 | 2005-08-10 | 2015-11-24 | Autoliv ASP | Steering apparatus | None — mechanical steering; irrelevant to every claim. |
| 13 | US 2009/0189373 A1 | 2005-08-10 | 2009-07-30 | Michael R. Schramm | Steering Apparatus | None — same family as #12. |
| 14 | US 2008/0162034 A1 | 2006-12-28 | 2008-07-03 | General Electric | Automatically generating sets of geo-fences | None alone — no clearance warning; § 103 art for "predetermined distance." |
| 15 | US 2009/0045927 A1 | 2007-08-15 | 2009-02-19 | Qualcomm | Alerting a remote vehicle operator of unsafe transportation-network conditions | None — remote alerting architecture, not an in-cabin self-contained unit. |
| 16 | US 2010/0030466 A1 | 2008-08-01 | 2010-02-04 | ESRI | Hybrid off-board navigation | None. |
| 17 | US 2012/0083947 A1 | 2009-03-05 | 2012-04-05 | MIT | Operator assistance via trajectory + threat assessment | None — threat-assessment framework, no clearance database/display. |
| 18 | US 2013/0048403 A1 | 2011-08-24 | 2013-02-28 | Nicholas G. Doinoff | Ignition interlock with rolling retest + motion detector | None (fails claim 1). The closest art for claims 4/9's "prevent operation until activated." |
| 19 | US 2013/0147955 A1 | 2011-12-12 | 2013-06-13 | Denso | Warning system, vehicular apparatus, and server | None — server-centric; no self-contained hollow-body unit, no alternate-route display. § 103 material for vehicle-size-vs-danger. |
| 20 | US 2015/0134240 A1 | 2012-06-19 | 2015-05-14 | Mitsubishi Electric | Imitation sound generation + map database | None — sound generation for EVs; touches "audible sound" only. |
| 21 | US 2014/0066091 A1 | 2012-09-06 | 2014-03-06 | Devrim Varoglu (Qualcomm) | Wireless messages to enhance location accuracy | None — GNSS accuracy art. |
| 22 | US 2015/0179069 A1 | 2013-12-19 | 2015-06-25 | Cellco (Verizon Wireless) | Accident prevention system | Strong § 103; not § 102. Discloses comparing bridge clearance vs. vehicle height, driver alert, display of bridge height and an alternate route, HUD output. Fails claim 1 on a GPS module within the hollow interior of a main body (its road data arrives by NFC marker from a central authority). |
| 23 | US 2016/0351050 A1 | 2014-02-20 | 2016-12-01 | Aisin AW | Warning guidance into vehicle navigation systems | None — navigation-integrated warning; § 103 material. |
| 24 | US 2016/0009276 A1 | 2014-07-09 | 2016-01-14 | Alcatel-Lucent | In-the-road, passable-obstruction avoidance | None — obstruction avoidance; § 103 material. |
| 25 | US 2016/0046298 A1 | 2014-08-18 | 2016-02-18 | Trimble Navigation | Detection of driver behaviors using in-vehicle systems | None — driver-behavior analytics. |
| 26 | US 2016/0288741 A1 | 2015-04-06 | 2016-10-06 | Jessie James Shafer | Wireless electrical interface system | None — interface hardware. |
| 27 | US 2016/0335879 A1 | 2015-05-11 | 2016-11-17 | Mayhem Development (Carr) | System for providing advance alerts (emergency-data/alert zones) | None — verified: this is an emergency-data/alert-zone system, not a clearance system. Misleading title. |
4. Detailed § 102 analysis of the four closest references
4.1 US 2004/0201495 A1 — Lim (the single most material of-record reference)
- Full citation: U.S. Patent Application Publication 2004/0201495 A1, "Digital coded horizontal overhead obstacles warning system for vehicles," inventor Hee Chuan Lim (Edison, NJ); filed 2003-04-11; published 2004-10-14; status abandoned.
- Disclosure (verified): a transmitter mounted at/near the obstacle broadcasts a digitally coded RF signal encoding the road name and the bridge/obstacle height; a self-contained in-vehicle receiver decodes it and displays the information on an LCD panel (and projects it on the windshield), with a visually flashing indicator and an audio warning. Its stated objective is to warn 2–5 miles before the obstacle. It distinguishes over U.S. Pat. No. 5,389,912 (Arvin) on the ground that Arvin required the vehicle to be under the bridge.
- § 102 verdict: Does not anticipate claims 1–10. It fails claim 1's (b) programmable computer module storing road/bridge/viaduct/underpass information inside the unit, (c) GPS module inside the hollow body supplying structure location, and (e) display of alternate routes. Its warning is keyed to reception of a roadside RF signal, not a GPS-determined "predetermined distance."
- Caveat / recommended verification: Lim's specification contains a "GPS (global positioning satellite)" entry among its definitions, and it is listed in the earlier sections as "the most on-point" of-record reference. I did not perform a full-text read of Lim's GPS passages; whether Lim discloses GPS positioning integrated with its warning logic (as opposed to mentioning GPS generally) is the one fact that could move it from § 103 art toward a § 102 challenge. Pull Lim's full text and check the GPS passages before relying on the "no GPS" gap.
4.2 US 2015/0179069 A1 — Cellco Partnership (Verizon Wireless)
- Full citation: U.S. Patent Application Publication 2015/0179069 A1, "Accident prevention system," assignee Cellco Partnership d/b/a Verizon Wireless (Cavanás et al.); priority 2013-12-19; published 2015-06-25.
- Disclosure (verified): an in-vehicle system (communication device, "user experience application," display unit) that receives road data including an upcoming bridge/overpass with a low clearance height, and compares the bridge clearance with the known vehicle height to determine whether the bridge poses a problem; it displays the bridge height along with the vehicle height and, if applicable, a notification that the vehicle exceeds the bridge height, and can display an arrow/alternate route on a HUD/display to avoid the issue. It distinguishes static vs. dynamic vehicle/road attributes.
- § 102 verdict: Does not anticipate claims 1 or 6 (or dependents). Two gaps: (i) it lacks a GPS module located within a hollow interior volume of a main body providing structure location — its architecture is marker/NFC + central-authority based; (ii) the elemental "main body forming a hollow interior volume" with co-located computer + GPS modules is absent. It is, however, the strongest § 103 reference because it independently supplies the clearance-vs.-vehicle-height comparison and the alternate-route display — two of the '205 patent's stated points of novelty.
4.3 US 2013/0147955 A1 — Denso
- Full citation: U.S. Patent Application Publication 2013/0147955 A1, "Warning system, vehicular apparatus, and server," assignee Denso Corporation; JP priority 2011-12-12; published 2013-06-13.
- Disclosure (verified): a server + in-vehicle apparatus system; the vehicle reports its size and position/course; a detecting vehicle reports a dangerous object at a spot (with a whole image); the server computes a danger degree based on the warned vehicle's size relative to the object and pushes a warning to the warned vehicle.
- § 102 verdict: No anticipation of claims 1–10. It is a client/server architecture (no single hollow-bodied unit; no in-unit GPS/computer module; no alternate-route display). Its relevance is narrow but real: vehicle-size-dependent hazard determination — a § 103 building block against the claim's clearance-vs.-vehicle logic.
4.4 US 2016/009276 A1 (Alcatel-Lucent) and US 2016/0351050 A1 (Aisin AW)
- Alcatel-Lucent (priority 2014-07-09; published 2016-01-14): "In-the-road, Passable Obstruction Avoidance Arrangement" — obstacle/passability avoidance. § 102 verdict: none; § 103 material on hazard avoidance generally.
- Aisin AW (priority 2014-02-20; published 2016-12-01 — qualifies under § 102(a)(2) via its earlier effective filing date): "Warning guidance system, method, and program that provide information to vehicle navigation systems." § 102 verdict: none; § 103 material on feeding warnings into an in-vehicle navigation display.
5. References of record with essentially no § 102 value (grouped)
- Traffic-content family (##2–5): Motorola/Bullock "optimizing traffic content" — 2001–2003. Broadcast traffic optimization; no clearance, no GPS-in-body.
- Route/navigation (##1, 6, 8, 16): US 5,220,507 (multiple routes), US 6,748,325 (Fujisaki nav), US 6,865,476 (nautical waypoints), US 2010/0030466 (ESRI off-board nav). Collectively relevant only to the "alternate routes" limitation (claim 1/6).
- Steering apparatus (##12, 13): Autoliv/Schramm. Legally irrelevant to every claim — worth noting only because their presence on the face signals a broad examiner search.
- Interlock (##18): Doinoff ignition interlock — the only of-record art arguably directed at claims 4/9's "prevent operation until activated," but it cannot anticipate those claims because it does not disclose claim 1's clearance-warning combination. Treat as § 103 art for the interlock feature.
- Geo-fencing (##14): GE geo-fence generation — § 103 art for the "predetermined distance" trigger.
- Location accuracy (##21): Varoglu/Qualcomm — GNSS augmentation; irrelevant to clearance.
- Sound/interface/behavior/alerts (##20, 24, 25, 26, 27): Mitsubishi imitation sound, Alcatel-Lucent obstruction avoidance, Trimble driver-behavior, Shafer wireless interface, Mayhem/McLellan advance-alerts. No § 102 value; § 103 value is peripheral. (US 2016/0335879 A1 in particular is an emergency-data/alert-zone system — its title is misleading; I verified this.)
- Ehlers family (##10, 11): road/hazard info delivery to vehicle operators — § 103 material only.
6. Candidate art that is NOT of record (flag before an IPR)
Because Unified Patents' PATROLL contest expressly excluded prosecution-cited art, the highest-value § 102/§ 103 candidates are likely not on the face of the '205 patent. Two that surfaced during this search and merit immediate review:
- US 2015/0120178 A1 — a low-clearance detection and alert system whose controller "may monitor the vehicle location via a navigation system or GPS sensors," with a database preprogrammed with clearance heights, sensors that determine the clearance height of an approaching structure, a comparison against the vehicle height entered by the user, and issuance of an alert of impending collision. On its face this reference discloses materially more of claim 1 than any of the 27 of-record references — including the GPS/database/clearance-comparison core. This is the single highest-priority reference to pull in full. (I have verified the quoted passages; I have not verified its complete claim-coverage or its exact effective filing date.)
- U.S. Pat. No. 5,389,912 (Arvin) — "Truck Clearance Anti-Collision Device," cited within Lim (and therefore not itself of record in the '205 patent). Relevant as the acknowledged clearance-sensing baseline.
Also note: the '205 specification's background section names three references that do NOT appear in Google Patents' "Patent Citations" list — U.S. Pat. No. 6,275,773 (Lemelson et al.), U.S. Pat. No. 4,284,971 (Lowry et al.), and U.S. Pat. No. 3,419,847 (Bonney). The specification characterizes all three as "representative of GPS and warning devices to avoid a low structure collision for trucks and vehicles with high clearance requirements." Discrepancy flag: either they were not formally IDS-listed (so they are technically not of record), or the Google Patents citation table is incomplete. If they are not of record, they are § 325(d)-friendly art worth charting. I have not verified their subject matter beyond the patentee's own characterization.
7. What I could not verify (stated plainly)
- Full text of Lim (US 2004/0201495 A1) — specifically the scope of its GPS disclosure. This is the pivot for whether Lim is § 102 or only § 103 art.
- Complete disclosure and effective filing date of US 2015/0120178 A1 — the strongest non-of-record candidate identified here.
- Actual contents of references 2–8, 10–21, and 23–27 beyond their titles/abstracts; my descriptions for the low-relevance entries rest on titles and family groupings, which I have labeled as such.
- Whether the three specification-named background references (Lemelson '773, Lowry '971, Bonney '847) were ever IDS-listed — the Google Patents citation table omits them.
- PATROLL submissions — the contest ($2,000; 2025-02-25 to 2025-04-01; sought art on at least claim 1, excluding prosecution-cited art per the contest page) did not produce a publicly identified winning reference in my searches; no IPR followed.
8. Consistency notes with the earlier-generated sections
- No contradictions found in the prior-art conclusions. The earlier sections called Lim "the most on-point one" of-record; this analysis confirms that ranking at the reference level while adding the important qualification that Lim is not an anticipation reference (it lacks GPS-structure-location and alternate-route elements).
- Addition: the earlier sections' PTAB section noted Unified's PATROLL contest excluded of-record art and flagged the § 325(d) risk. This section operationalizes that observation by surfacing US 2015/0120178 A1 as the leading non-of-record candidate — which is exactly the kind of art that clears the § 325(d) hurdle.
- Carry-forward of the live § 112/claim-scope point: claims 1 and 6 recite an "automobile," while the accused products are commercial truck navigators (e.g., Garmin dēzl) and the specification targets truckers/buses/RVs — and the claims omit tunnels, which the specification emphasizes. That mismatch affects prior-art relevance too: if "automobile" is construed broadly, the truck-oriented references (Lim, Cellco, Denso) become more relevant under § 103; if narrowly, they are more distinguishable. No court has construed it (consistent with the earlier sections).
Generated 9/29/2026, 1:02:40 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the obviousness analysis in the actual prior-art references of record and adjacent art before writing. Let me pull key references.
Let me verify two more references cited in the specification's "Related Art" discussion and the ignition-interlock dependent claim.
Obviousness Analysis — U.S. Patent No. 10,593,205 Under 35 U.S.C. § 103
Scope note. This section builds on, and does not repeat, the prior sections (bibliographic verification, litigation map, PTAB/estoppel posture). It analyzes only patentability under § 103, using the prior-art references associated with this patent's prosecution (the 27 references on the face of the patent, the three references discussed in the specification's "Description of the Related Art," and art cited within those references), with the residual art identified in search flagged separately and dated. Where a reference's own priority date could not be verified, I say so rather than assume.
Date discrepancy flagged. The task header sets the current date as April 26, 2026, while the previously generated sections were written to a 2026‑09‑29 "today." Nothing in the § 103 analysis turns on this, but the earlier sections' § 315(b) arithmetic was keyed to the later date; treat the four-month delta as a live variable for any statutory-deadline conclusion.
1. Governing framework and level of ordinary skill
The invention, reduced to its claim-1 substance, is an arrangement of five known hardware blocks (main body, computer module, GPS module, audible/visual warning mechanism, display screen) plus three functional requirements: (i) the computer module is programmed with data about roads/bridges/viaducts/underpasses; (ii) the display shows the height of an approaching bridge or underpass and alternate routes; and (iii) the warning fires when the device is within a predetermined distance of a structure that "poses a danger."
POSA definition. For the Dec. 13, 2015 priority date: a person with a bachelor's degree in electrical or computer engineering (or equivalent), and 2–3 years of experience in in-vehicle navigation, telematics, or vehicle warning systems, or equivalent work experience. This POSA is presumed to know: (a) that GPS modules were commodity chipset components by 2015; (b) that machine-readable clearance-height datasets for bridges/underpasses existed in truckers' atlases, state DOT bridge-inventory files (NBI), and commercial truck-routing products; (c) that off-the-shelf LCD modules, piezo buzzers, and flashing LED/incandescent indicators were standard; and (d) that route-guidance engines generated alternate routes and could apply "avoid" cost penalties to disfavored segments.
Presumption. Because claim 1 is drafted entirely as a combination of known components with functional ("adapted to") language, it is a classic aggregation-obviousness target: the § 103 question is not whether any single block is novel, but whether combining them would have been predictable to the POSA with a rational underpinning. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
2. The closest art on the face of the patent: US 2004/0201495 A1 (Lim)
US 2004/0201495 A1 ("Digital coded horizontal overhead obstacles warning system for vehicles," Hee Chuan Lim, pub. 2004‑10‑14) is the single most on-point reference and is of record. It discloses:
- A roadside transmitter at the bridge "preprogrammed … with information relating to a bridge, obstacle, or bridge overpass, such as a street or road name where the bridge is located or leading to the bridge 2, a lowest height of the bridge 2, and information concerning whether the bridge 2 is slanted." (US 2004/0201495 A1, ¶ [0051])
- An in-vehicle receiver unit containing "microprocessor unit 426, memory …, liquid crystal display 109, projector 108, switch 116, speaker 114, … memory 434, and external data storage 435." (Justia copy, ¶ [0054])
- "[A] visually flashing indicator according to the transmitter refresh/sending rate to alert the vehicle operator, besides the audio warning that can be activated or turned off." (Abstract)
- An express objective of warning "two to five miles away from an obstacle or bridge," and an express criticism of the closest prior art (Arvin, U.S. 5,389,912, an ultrasonic "Truck Clearance Anti-Collision Device") because "the driver of a vehicle has to be located under the bridge to get a reading, making it too late to stop or making it necessary to back up." (¶¶ [0010]–[0011], [0020])
- A keypad and an external-data input for operator entry of vehicle/parameter data, and a receiver that "may be adjustable on the dashboard of the vehicle so that the LCD displays are always in plain view of the driver."
What Lim alone does not disclose: a GPS module; an on-board stored database of clearances (Lim's data is broadcast from the roadside); the display of alternate routes; and a position-derived "predetermined distance" trigger (Lim's pre-warning distance is a function of beacon RF range, not vehicle position). Lim is therefore not an anticipatory reference for claim 1 — but it supplies roughly 70% of the claim, including the two hardest-to-design-around limitations: display of the height of the approaching bridge and loud audible warning.
The § 103 hinge, therefore, is the addition of GPS + a stored clearance database + route alternatives. Each of those additions was independently known, and Lim itself supplies the motivation.
3. Claim-1 element inventory and where each element lives in the art
| Claim 1 limitation | Lim '495 | Lemelson '773 | Lowry '971 | Denso '955 | Others of record |
|---|---|---|---|---|---|
| (a) Main body / hollow interior | Receiver unit 4a housing (dashboard) | Elec. package in vehicle | roadside + in-cab signage | Vehicular apparatus 100 | — |
| (b) Computer module programmed w/ roads, bridges, viaducts, underpasses | Memory + microcontroller preprogrammed w/ bridge/road data | Memory 48 + control computers 31/38; control-center DB of "known obstacles … bridge abutments, telephone poles, buildings" | — | Server/nav apparatus computes per stored data | ESRI '466 (hybrid on/off-board nav); GE '034 (geo-fences) |
| (c) GPS module inside the body | ✗ (mentions GPS only as RF interference source) | GPS receiver 32 (and GPS transceiver 34) | ✗ | Navigation apparatus w/ position | Qualcomm '927; Varoglu '091 |
| (d) Warning mechanism, loud audible | Speaker 114, audio warning | Speech synthesizer 42, horn control 68, "spoken alarm warnings" | "audible warning can also be provided" | Warning section | Aisin '050 |
| (e) Display screen on outer surface | LCD 109 showing bridge height + windshield projector | Display 46 / heads-up display | flashing electric sign | Electronic display | Fujisaki '325 |
| display shows height of approaching bridge/underpass | ✔ ("lowest height of the bridge") | ✔ (hazard/obstacle identification) | ✔ (beams set at clearance height) | ✔ (obstacle image + size) | — |
| display shows alternate routes | ✗ | ✔ ("alternate routes of travel") | ✔ (transmit message so authorities help "reroute the overheight vehicle") | ✔ (route suggestion / bypass) | Motorola '507; Ehlers '347 |
| process info + location, decide when to signal | microprocessor | ranging computer 36 → control computer 38 | detector → signal → control | server determination section | — |
| initiate warning at predetermined distance of a dangerous structure | beacon range (2–5 mi) | hazard distance membership grading in fuzzy logic | sequential beam-break zones | danger degree for the specific vehicle | MIT '947 (threat/trajectory) |
Read note: Lemelson U.S. Pat. No. 6,275,773 is cited in the specification's "Description of the Related Art" ("U.S. Pat. No. 6,275,773 to Jerome H. Lemelson et al.") and search confirms it is US 6,275,773 B1, "GPS vehicle collision avoidance warning and control system and method," inventors Jerome H. Lemelson and Robert D. Pedersen, filed 1999‑11‑08, priority 1993‑08‑11 (Google Patents). However — flagging a discrepancy against the page's own data — Lemelson '773, Lowry '971, and Bonney '847 do not appear in either citation table on the patent's Google Patents record (the "Citations (23)" and "Patent Citations (27)" lists). The spec discusses all three by name. This matters for § 325(d) (Section 11, below).
4. Ground A — Lim '495 in view of Lemelson '773 (and Motorola '507 / Ehlers '347 for the routing element)
Combination. Lim as the base (all five structural blocks, height display, audible + flashing warning) + Lemelson '773 as the GPS/position-aware vehicle-mounted architecture + a navigation/routing reference for alternate-route display.
Why the POSA would combine them — Motive 1 (Lim's own teaching). Lim expressly frames the problem as warning too late and sets an explicit goal of pre-warning at distance. Lim's solution — a roadside RF beacon — is range-limited and requires infrastructure at each structure. A POSA confronting the same stated objective with the well-known alternative (vehicle-side GPS + stored structure data, as in Lemelson) would substitute the position-derived trigger for the beacon-local trigger because it achieves Lim's own stated objective more reliably, over structures not equipped with transmitters, and with no roadside infrastructure. This is a textbook KSR "substitution of one known element for another" with a predictable result.
Motive 2 (Lemelson's express teachings). Lemelson discloses precisely the element set Lim lacks:
- Vehicle-mounted GPS + stored structure data: "the control center 12 has stored in its data base the location of known obstacles, such obstacle 22, on roadway 14. Example obstacles include bridge abutments, telephone poles, buildings, traffic light controls, walls, construction equipment, or any other known obstacle located along the roadway" — and "such known obstacle locations can in turn be used in the herein above described vehicle collision avoidance control and warning systems." (US 6,275,773, ¶ [0108])
- Alternate-route display: Lemelson's modified navigational computer "may … include auxiliary information such as towns and cities along the route of travel, distances thereto, alternate routes of travel, road conditions …" ([¶ [0194]]). Motorola's U.S. 5,220,507 ("Land vehicle multiple navigation route apparatus") and Ehlers US 2007/0138347 (vehicle-operator information delivery, incl. routing around restrictions) supply the same teaching for the routing engine element.
- Warnings in the claimed modes: spoken warnings via synthesizer 42; "repeatedly actuating a headlight system, a horn system, or a collision warning light system"; "flashing external and/or internal warning lights."
- Architecture: GPS receiver 32, memory 48, display 46, power supply 74 — which also supplies dependent claims 5/10's power source.
- "Automobile": Lemelson is directed to an "automobile-on-the-highway" environment, which pre-empts any argument that the prior art is limited to trucks (relevant to the claim/spec "automobile" vs. truck mismatch flagged in the prior sections).
Motive 3 (predictable field convergence). Lim itself acknowledges GPS as a co-resident in-vehicle technology ("electrical engine noise and interference, that is typical of automotive operation, wireless cellular phones and global positioning satellite (GPS) system" — ¶ [0018]), i.e., both references are in the same field of endeavor and the POSA would have known to integrate them. By 2015, GPS-based waypoint/POI warning against a stored data table was routine (Qualcomm '927: "alerting remote vehicle operator of unsafe transportation network conditions"; GE '034: auto-generated geo-fences; ESRI '046: off-board navigation with pre-loaded map features).
Reasonable expectation of success. Every substituted element was off-the-shelf and the function of each is unchanged: the GPS module supplies position (its known function); the lookup table supplies clearance (its known function); the comparator fires the alarm (Lim's known function). No new operability principle was required.
5. Ground B — Lim '495 in view of Denso US 2013/0147955 A1 (danger-degree determination)
US 2013/0147955 A1 (Denso, "Warning system, vehicular apparatus, and server," pub. 2013‑06‑13) is also of record. It discloses a vehicular apparatus that transmits "a vehicle information item specifying a size of the host vehicle," and a server that determines "a danger degree at a time when the warned vehicle passes through the dangerous spot based on (i) the size specified by the vehicle information item … and (ii) the whole image indicated by the dangerous object information item," then provides "a warning information item according to the danger degree." (US 2013/0147955 A1, Summary)
Combination and motivation. Denso supplies the decision logic that maps most directly onto claim 1's two-part trigger ("within a predetermined distance and poses a danger"): compare a vehicle dimension to an obstacle dimension and issue a graded warning. A POSA combining Lim's obstacle-height broadcast with Denso's vehicle-size-vs-obstacle danger computation arrives at the claim without the GM of the invention being required — the combination is a straightforward "arrange old elements to yield predictable results" case. Motivation: Denso teaches the problem of over-warning and wasted driver attention (the same driver-distraction concern Lim raises in criticizing sign-based warnings), and the cure is dimension-aware, danger-graded alerting.
This ground also forecloses the "predetermined distance" construction dispute flagged in the litigation section (Garmin pleading): whether that term is construed as a fixed stored threshold or a dynamically variable distance, the art reads on it either way — Denso computes the trigger from vehicle size/danger (variable), and Lemelson grades hazard distance through fixed membership bands (fixed). A construction that saves the claim from Denso tends to read the term onto Lemelson's fixed distance bands.
6. Ground C — Lowry '971 as an alternative primary reference for the warning/reroute core
U.S. 4,284,971 (Lowry, "Overheight vehicle detection and warning system," 1981) is discussed by name in the specification. It discloses roadside light sources and sensors mounted at the clearance height of the overhead obstruction; when beams are broken in sequence, a "control means activates a visible electric sign warning the driver … to stop because the vehicle is too high"; "An audible warning can also be provided"; and "transmission means can be provided for transmitting a message to proper highway authorities that a problem with an oversize vehicle exists at the particular location and that assistance may be needed in rerouting the vehicle." (US 4,284,971)
Lowry therefore discloses the problem statement, the audible+visual warning pair (claims 3/8), and the re-route objective in 1981 — nearly 35 years before the '205 priority date. Combined with any vehicle-side GPS + stored-clearance-database reference (Lemelson '773; or, as of the 2015 priority date, the commercial truck-routing art), Lowry renders the claim obvious as an alternative ground. Motivation: Lowry's infrastructure-based detector warns only at the structure; the POSA seeking the advance warning Lowry cannot give would move the intelligence into the vehicle — the same motivation narrative as Ground A, from the opposite starting reference.
Prosecution-history hazard: the specification characterizes Lemelson '773, Lowry '971, and Bonney '847 together as "representative of GPS and warning devices to avoid a low structure collision for trucks and vehicles with high clearance requirements," then asserts conclusorily that "None of the above inventions and patents, taken either singly or in combination, is seen to describe the invention as claimed." That attorney argument is entitled to no weight as evidence and, more usefully for a challenger, concedes that the three references are in the same field and are combinable in principle.
7. Claim 6 — the "combination" claim
Claim 6 adds only: (a) an automobile having an engine and a passenger compartment, and (b) location of the device within the passenger compartment. The device limitations (i)–(v) are verbatim claim 1.
- Automobile with engine/passenger compartment: Lemelson '773 is expressly an automobile system (engine/brake/steering control); Lim's receiver is dashboard/windshield-mounted inside the vehicle cabin.
- Therefore claim 6 stands or falls with claim 1, and the same three grounds apply. There is no separate inventive concept in claim 6. Notably, claim 6's "automobile" does not help the patent owner against truck-oriented accused products, and it does not help against invalidity either, because the art is also automobile-focused.
8. Dependent claims 2–5 and 7–10
| Dep. claim | Added limitation | Of-record art that discloses it | Combination rationale |
|---|---|---|---|
| 2 / 7 | Stored info includes longitudinal & latitudinal coordinates and underpass clearance measurements | Coordinates: Lemelson GPS architecture; GE '034 geo-coordinates; Qualcomm '927. Clearance measurements: Lim's "lowest height of the bridge"; Lowry's beams set at clearance height | Mere data-format choice; predictable |
| 3 / 8 | Warning mechanism also provides a flashing light | Lim's "visually flashing indicator"; Lemelson "flashing external and/or internal warning lights"; Lowry's flashing electric sign | Redundant; same art |
| 4 / 9 | Computer module prevents the automobile from being operated until the device is on/activated | US 2013/0048403 A1 (Doinoff), "Ignition interlock device with rolling retest and motion detector" — of record | Combining a safety device with a known interlock is the paradigmatic predictable combination; motivation: enforce driver compliance and prevent defeat/bypass, a concern inherent in every warning-only reference (Lim's alarm "can be activated or turned off") |
| 5 / 10 | Power source inside the hollow volume connected to computer, GPS, warning | Lim's self-contained receiver with power; Lemelson's power supply 74 | Conventional; no independent weight |
Note on claim 4/9 — this is the one dependent limitation that is not squarely met by the clearance-warning references themselves. Its witness is Doinoff '403 (of record, i.e., examiner-considered) plus general interlock art. Expect the patent owner to argue non-analogous art and lack of motivation; expect the challenger to argue (i) same field of endeavor (vehicle safety/anti-defeat), and (ii) the KSR "known technique to improve similar devices in the same way" rationale — conditioning operability on a safety device is a decades-old, well-understood pattern (seatbelt interlocks, alcohol interlocks).
9. Motivation-to-combine synthesis (defensible KSR rationales)
Consolidating, a petition or invalidity contention can plead at least five independent, non-conclusory rationales:
- Express teaching/suggestion in the primary reference itself. Lim criticizes the "warn-under-the-bridge" art as "too late to stop" and states an objective of 2–5 mile pre-warning — a direct pointer to position-derived advanced warning.
- Substitution of a known technique for a known one, with predictable results. Roadside-beacon detection → GPS + stored-data lookup. KSR, 550 U.S. at 416, 417.
- Combination of prior-art elements according to known methods to yield predictable results. LCD height display (Lim) + GPS position (Lemelson) + danger comparison (Denso) + route engine (Motorola '507) — each element performs its own known function; no change in principle of operation.
- Motivation supplied by a secondary reference's stated problem. Denso's concern with over-warning/driver attention and its vehicle-size-based danger degree; Lowry's concern with the need to "reroute the overheight vehicle"; Lemelson's express disclosure that its stored obstacle database "can … be used in" the collision-avoidance/warning system.
- Market/regulatory and design-incentive evidence. Bridge/overpass strikes by over-height vehicles are a well-documented, well-publicized problem (Lowry 1981; Lim 2004; the FRA's 2015 low-ground-clearance study shows the same class of problem still drawing federal R&D attention), and post-2000 in-vehicle navigation was a high-volume commercial market, giving a design incentive to add clearance warnings to navigation devices. (Careful: the commercial-success/adoption facts in the earlier litigation sections go to objective indicia on the patent owner's side only if a nexus is shown — see Section 10.)
Reason to doubt the combination is properly provable — the honest counterweight. The strongest non-obviousness argument the patent owner can make is simultaneous invention / long-felt but unmet need: Lim (2004) broadcast height data but no GPS database; Lowry (1981) warned but roadside-only; the gap between Lowry/Lim and a vehicle-side clearance-database warning system persisted for a decade or more, suggesting the combination was not as trivially available as it looks in hindsight. Rebut it with: (a) Lemelson '773 already taught vehicle-side GPS + a stored obstacle-location database + warnings + alternate routes, so the "gap" is one of commercial deployment, not of disclosed technology; and (b) KSR holds that "the mere existence of a long-felt need … does not necessarily establish nonobviousness" where the elements were all known and the combination predictable.
10. Objective indicia (secondary considerations)
Building on the earlier sections: the record reflects a large and active commercial market for the claimed subject matter — Navog LLC's nine-plus suits against Garmin (dēzl 580 LMT-S), TomTom, Verizon Connect, Samsara, Powerfleet, Trucker Path, TeleType, and others — which is evidence of industry adoption. But for § 103 purposes that evidence only counts in the patent owner's favor if there is a nexus between the claimed invention and the commercial success. No nexus evidence appears in any retrieved filing. And the licensing pattern is the wrong kind of "success": TomTom and Verizon exited by with-prejudice joint stipulation, Panasonic likewise, and TeleType by FRCP 41(a)(1)(A)(i) dismissal without prejudice, with no Markman order anywhere. One with-prejudice dismissal and three no-prejudice/no-merits exits are consistent with cost-of-defense settlements and carry little evidentiary weight as "commercial success" demonstrating non-obviousness; if anything, the absence of any merits adjudication means no objective-indicia record has been developed by either side. No evidence of unexpected results, copying, industry praise, or a failure of others was located. If you are the challenger, affirmatively develop the absence of a nexus; if you are the patent owner, this is the section that needs building and it cannot be built from litigation settlements alone.
11. Practical § 103 posture — the § 325(d) trap and which art is actually "new"
Building on the PTAB section's Advanced Bionics point:
- The three best references are all of record. Lim '495, Denso '955, and Doinoff '403 are on the face of the patent; Lemelson '773, Lowry '971, and Bonney '847 are named in the specification (though, per the discrepancy flagged in Section 3, they do not appear in the patent's citation tables — verify against the actual IDS/file wrapper before assuming the examiner "considered" them). A ground built on Lim + Lemelson + Denso therefore invites a § 325(d) discretionary-denial argument that the same or substantially the same art/arguments were previously presented. At minimum, the petitioner must brief the Advanced Bionics two-part test and explain the material differences (e.g., that the combination — not the individual references — was never before the examiner; that Lemelson '773 was not an IDS item; that Denso was cited for a different purpose).
- Combination-based grounds are the way around § 325(d): the Office rarely finds that a specific proposed combination was "previously presented" merely because the component references were of record, particularly where the references were cited in unrelated rejections.
- Candidate genuinely-new art to check (NOT on the face of the patent, and the reason I flag them is that they are closer to claim 1's data structure than anything of record):
- US 9,429,441 B2 — utility-vehicle clearance warning with vehicle-height storage, bridge clearance, and "a route suggestion for bypassing the bridge," i.e., a near-complete claim-1 read. Found in search; its priority/filing date must be verified before use (the snippet references a DE priority; if post-2015 it is not prior art).
- US 10,876,848 B2 — a "restricted segment"/vehicle-profile routing patent that expressly displays a low bridge "having a height of 2.5 m" with zoomed warning at "270 m," i.e., a predetermined distance. Found in search; this document's date is a hard gate — the '848 patent number and the surrounding family appear later than the '205 priority date on their face, so treat it as a post-art roadmap/hindsight check, not as § 102/§ 103 art, until a pre-2015 priority is verified.
- U.S. 4,284,971 (Lowry) is chronologically ancient and safe as art, but its § 325(d) status is the open question (cited in the spec, absent from the citation tables).
- Do not overlook US 5,389,912 (Arvin) — the ultrasonic "Truck Clearance Anti-Collision Device" cited inside Lim. It is art that warns of insufficient clearance for a truck, and it is at least one more brick in the "all elements known" wall.
12. Where the claim is most vulnerable, and where it is not
| Challenge vector | Strength | Why |
|---|---|---|
| § 103 over Lim + Lemelson (+routing ref) | Strong | Lim supplies the height display and audible/flashing warning; Lemelson supplies GPS + stored-structure DB + alternate routes + automobile architecture; motivation is in Lim's own criticism of late warning |
| § 103 over Lim + Denso '955 | Strong | Denso supplies vehicle-size-vs-obstacle danger degree — the "poses a danger" half of the trigger; also inoculates the "predetermined distance" construction dispute |
| § 103 over Lowry + GPS/nav | Moderate–strong | Lowry supplies problem + audible/visual + reroute rationale in 1981; needs a vehicle-side data reference |
| § 103 on claim 4/9 (interlock) | Moderate | Doinoff '403 is of record and same-field; expect a non-analogous-art skirmish |
| § 112 / claim-scope (not § 103) | Strong, separate | The "automobile" limitation vs. a spec directed to "truckers, bus and RV drivers," and the claim's omission of "tunnels" (prominent in the spec and abstract) — a written-description/enablement and claim-construction problem the earlier sections flagged. Note the irony: a construction broad enough to read "automobile" onto trucks broadens the claim toward Lemelson's "automobile-on-the-highway" disclosure |
| § 102 (anticipation by Lim alone) | Weak | Lim lacks GPS, on-board stored clearance database, and alternate-route display |
| § 103 over a single reference | Weak | No single of-record reference contains the GPS + stored-clearance-DB + height display + alternate routes + predetermined-distance trigger combination |
13. Contradictions, discrepancies, and unknowns — flagged, not auto-corrected
- Citation-table discrepancy (material to § 325(d)). The specification names US 6,275,773 (Lemelson), US 4,284,971 (Lowry), and US 3,419,847 (Bonney) in its "Description of the Related Art," but none of the three appears in either citation table on the patent's Google Patents record. Either the tables are incomplete or these were not IDS-of-record items. Verify in the file wrapper before asserting (or defending against) a § 325(d) argument. Do not infer that the examiner considered them.
- Bonney US 3,419,847 is unverified. My search returned Bonney applications from 2004–2007 (a different Bonney), not the 1969-era patent the specification names as "Robert S. Bonney." I could not confirm the '847 patent's title or content. I rely only on the specification's characterization and do not attribute any specific disclosure to it.
- Lemelson reference form. The specification cites "U.S. Pat. No. 6,275,773 to Jerome H. Lemelson et al." Search confirms US 6,275,773 B1, filed 1999‑11‑08, priority 1993‑08‑11, inventors Lemelson and Pedersen. Related Lemelson/Pedersen continuations include US 6,487,500 B2 and US 6,553,130 B1 — useful if the patent owner tries to distinguish '773 on claim scope, since the family shares a specification.
- The "2013 priority" secondary source flagged in the earlier summary (Ex Parte analysis of the Garmin case) conflicts with the patent's own CROSS-REFERENCE (Dec. 13, 2015) and with the Google Patents record. The 2015 date is what I use; a 2013 date would expand the prior-art universe against the patent, not shrink it.
- Current-date inconsistency: task header says April 26, 2026; the earlier sections computed deadlines as of 2026‑09‑29. Flagged in Section 1.
- No IPR/PGR/CBM and no CAFC docket (per the earlier sections). Consequently no claim of the '205 patent has ever been tested in an adversarial validity forum, and the § 103 grounds above are untested proposals, not adjudicated conclusions. Treat the "Strong" ratings in Section 12 as ex ante assessments, subject to the art-verification items in Section 11.
14. Bottom line
Under § 103 as of the Dec. 13, 2015 priority date, claim 1 is highly likely obvious over Lim '495 in view of Lemelson '773 (with Motorola '507 or Ehlers '347 for the alternate-route display), and equally so over Lim in view of Denso '955 for the danger-determination limitation — and claim 6 falls with it because it adds only an engine, a passenger compartment, and in-cabin placement. Dependent claims 2, 3, 5, 7, 8, and 10 add nothing beyond the same references; claim 4/9 (the ignition interlock) is the only limitation needing a distinct reference (Doinoff '403), and its obviousness rests on the well-worn predictable-combination rationale. The patent's real vulnerability is not the individual elements — every one was known and every one is documented in art the examiner saw — it is the near-total absence of any objective evidence of non-obviousness and the ten-year-plus gap between Lowry/Lim and a vehicle-side clearance database, which Lemelson '773 nevertheless already disclosed. The principal practical obstacles to proving obviousness are procedural, not substantive: § 325(d) for the of-record combination, and the unverified IDS status of Lemelson '773/Lowry '971/Bonney '847, which is worth resolving before committing to a ground.
Generated 9/29/2026, 1:03:00 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
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Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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