Invalidity dossier

US 12190609

Method and system for map construction

Current assignee: TuSimple, Inc., CreateAI Holdings, Inc.

Added 9/29/2026, 4:22:51 AM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by TuSimple, Inc. +1Automotive (A)

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

I'll verify current docket/litigation details before summarizing.

Let me run a couple of targeted checks on litigation/PTAB and any Federal Circuit activity.

US Patent 12,190,609 B2 — Analyst Summary

Bottom line: All identifiers verified literally as US 12,190,609 B2 (application 18/360,556). No auto-correction applied. No Federal Circuit appeal involving this patent number surfaced in my searches; one active district court matter is associated with the patent family.


Bibliographic data

Field Value
Patent number US 12,190,609 B2 (also published as US 2023/0410536 A1)
Title Method and system for map construction
Application no. 18/360,556
Filing date 2023-07-27
Issue/grant date 2025-01-07
Earliest priority 2019-02-26 (assumed priority date; statutory/anticipated expiration 2039-02-26)
Inventors Minhao Jiang; Hsin Lu; Genmao Shi; Ziqi Liu
Original assignee TuSimple, Inc. (San Diego, CA)
Current assignee (per Google Patents) CreateAI Inc — assignment record of 2025-12-03, change of name from TuSimple, Inc., effective 2025-07-24
Continuity Continuation of 17/405,397 (issued as US 11,721,112), which is a continuation of 16/286,287 (issued as US 11,170,230)
Representative CPC G01C 21/32 (structuring/formatting of map data); G06V 20/56; G01C 21/3815; G06T 2207/30256
Claim count 20 (3 independent)

Abstract (verbatim): "A method of retrieving a map includes receiving a grid data of the map comprising lane segments, wherein the grid data includes an array of grids each associated with a list including none or at least one of the lane segments intersecting the respective grid; receiving coordinates of a location; identifying a first grid including the location based on the grid data; identifying a target grid that has an associated list including at least one of the lane segments as first lane segment; and outputting the first lane segment."

⚠️ Note a real internal mismatch: the abstract and the specification's disclosed "map feature extraction circuit" (FIGS. 12–13; grid lookup, search radius, nearest-lane-segment retrieval) describe grid-based map retrieval, but the issued claims of '609 are directed to outline/lane-geometry construction, not grid retrieval. The grid-retrieval subject matter appears to be the subject of sibling family members. Taken literally, the '609 claim set does not read on its own abstract.


Plain-language overview of the independent claims

Claim 1 — Method of map construction. Two core steps: (a) build one outer outline that encloses multiple lanes of a road, using a set of segments that run along the lanes or the road; then (b) identify the individual outline of each lane from those same segments plus the enclosing outer outline. The segments are defined as coming from partitioning polylines that describe the road's shape, with segments constructed at the polylines' start point, end point, or turning point.

Claim 9 — System. A processor plus a memory holding instructions that cause the same two operations (construct enclosing outline from the segments; identify each lane's individual outline), with the identical segment-derivation limitation (partitioned polylines, segments at start/end/turning points).

Claim 14 — Non-transitory computer-readable storage medium. The same two operations and the same segment-derivation limitation, expressed as executable instructions.

Dependent-claim flavor (for context, not independent): claims 2–8 add bidirectional arrow-marked segments, counterclockwise/clockwise angle-comparison selection of a next "target" segment (max angle for CCW outline tracing, min angle for lane segment tracing), arrow removal as segments are consumed, and lane-segment definition by four circumscribing segments; claims 10–13 add closed-space outline, waypoint-based vehicle operation, lane geometry data/lane content generation, and no-crossing segments; claims 15–20 add removal of dead-end segments, merging segments joined at only one end, lane-segment circumscription, same-lane vs. different-lane boundary overlap rules (perpendicular vs. parallel overlap), and conversion to a lane graph.


Litigation / docket status

  • CreateAI, Inc. v. Bot Auto, Inc. et al., No. 4:25-cv-03371 (S.D. Tex., filed 2025-07-21) — patent infringement. The case is captioned on Google Patents' litigation flag for this family and is confirmed by third-party dockets (RPX, Ex Parte, CreateAI's 2Q2025 financials) as TuSimple, Inc./CreateAI, Inc. v. Bot Auto, Inc.
  • Uncertainty: the publicly summarized complaint allegations I found reference asserted patents '776, '270, and '284 (with knowledge attributed via former employee Xiaoling Han). I did not find authoritative confirmation that 12,190,609 itself is asserted in that case — only that the family is litigation-flagged. Treat "the '609 patent is asserted in 4:25-cv-03371" as unconfirmed.
  • Related state-court dispute: CreateAI Holdings, Inc. (f/k/a TuSimple Holdings, Inc.) v. Bot Auto TX Inc. — trade-secret (TUTSA) injunction appeal, Fifteenth Court of Appeals, briefs filed 2025. Separate from the patent case.
  • CAFC 2026: a targeted search returned no Federal Circuit docket or opinion referencing 12,190,609. I cannot affirmatively rule out a pending appeal on this record.

Method / confidence notes

  • Bibliographic data, abstract text, full claim text, and continuity chain are taken from the authoritative full patent text supplied and corroborated by Justia, PatentGuru, and a USPTO-derived news item (which confirms issue date 2025-01-07 and assignee TuSimple Inc., San Diego).
  • The CreateAI assignment (effective 2025-07-24, recorded 2025-12-03) comes from the Google Patents legal-events record. Given the stated current date of April 26, 2026, this is a past event, but I flag that my search results did not independently corroborate it.
  • I could not access USPTO PatentCenter or a live CAFC docket directly; the searches were general web searches. Anything described as "no results" reflects search coverage limits, not a certified absence.

Generated 9/29/2026, 4:31:01 AM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 12190609. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll search for litigation involving US patent 12190609 across patent litigation sources.

The general searches returned mostly noise. Let me search the litigation-specific sources for this patent.

I found the key case. Let me verify details from the litigation-specific sources.

Litigation Involving U.S. Patent No. 12,190,609

Yes — litigation is known. U.S. Patent No. 12,190,609 ("Method and System for Map Construction"; assignee CreateAI, Inc., formerly TuSimple, Inc.) is asserted in the following case:

Case 1 — CreateAI, Inc. v. Bot Auto, Inc. et al.

Field Detail
Plaintiff CreateAI, Inc. (current assignee of the '609 patent; successor by name change to TuSimple, Inc.)
Defendant(s) Bot Auto, Inc. et al. (i.e., Bot Auto, Inc. and related entities — Bot Auto TX, Inc.)
Jurisdiction U.S. District Court for the Southern District of Texas (Houston Division), Case No. 4:25-cv-03371
Filing date July 21, 2025
Cause of action Patent Infringement (Nature of Suit 830)
Outcome / current status Pending / open — no judgment or disposition identified

Grounding:

  • The Google Patents record for US 12,190,609 itself reports a "US case filed in Texas Southern District Court" with case number 4:25-cv-03371 and flags the patent family (ID 72140369) as "Family has litigation" (Darts-IP).
  • The RPX Empower litigation database lists "4:25-cv-03371 | CreateAI, Inc. v. Bot Auto, Inc. et al," S.D. Tex., Filed 07/21/2025 ("Docket updated daily").
  • A complaint analysis of docket 4:25-cv-03371 confirms that U.S. Patent No. 12,190,609 "Method and System for Map Construction" is among the patents asserted, describing the '609 Patent claims (outline circumscribing a plurality of lanes → individual lane outlines) as being practiced by the Defendants' autonomous trucking vehicles ("Accused Products"). The same complaint also asserts other CreateAI/TuSimple patents (e.g., U.S. Patent Nos. 11,577,776 and 11,5xx,270 relating to redundant steering).
  • Ex Parte's docket page (ai-lab.exparte.com) confirms: CreateAI Inc v. Bot Auto Inc, S.D. Tex., filed 07/21/25, status "Open."

Related but distinct proceeding (NOT a '609 patent case)

A separate trade-secrets action, CreateAI Holdings, Inc. (f/k/a TuSimple Holdings, Inc.) v. Bot Auto TX Inc., Trial Court Cause No. 24-BC11A-0007 (Texas Business Court, Harris County — 11th Division), on interlocutory appeal at the Fifteenth Court of Appeals as No. 15-25-00001-CV, is frequently found alongside the '609 case. This is a TUTSA (Texas Uniform Trade Secrets Act) misappropriation suit against former CTO/CEO Xiaodi Hou and Bot Auto; it does not assert the '609 patent as a patent-infringement claim, though the parties and accused technology overlap. The trial court denied CreateAI's temporary injunction (Dec. 28, 2024), and CreateAI appealed. It is discussed here only to avoid conflating it with the patent case.


Caveats / confidence notes

  • Case number, parties, jurisdiction, and filing date for 4:25-cv-03371 are drawn from litigation-specific databases (RPX Empower, Ex Parte docket, plus the Google Patents / Darts-IP litigation flag) and are consistent across sources — high confidence.
  • Asserted-patent detail (that the '609 patent is specifically asserted, and the additional patents) comes from a third-party complaint analysis; I could not independently open the PACER/CourtListener complaint PDF for this docket within this session, so treat the precise claim-by-claim mapping as moderate confidence.
  • Outcome: I found no judgment, settlement, dismissal, or PTAB proceeding (IPR/PGR) involving the '609 patent. As of the current date it appears pending. I did not locate any CAFC appeal involving the '609 patent. I cannot confirm the absence of other, more recent filings beyond what these databases returned.
  • Per the strict interpretation rule, I have used the patent number 12,190,609 exactly as given and note that unrelated search hits (e.g., EP application 12190609, a UL fire-test code, and a UK companies-registry number "12190609") are not this patent and were disregarded.

If you need a definitive litigation history (all districts, PTAB, and appeals), the authoritative next steps would be a PACER docket pull for 4:25-cv-03371 and a Darts-IP family report for family ID 72140369.

Generated 9/29/2026, 4:30:57 AM

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: TuSimple, Inc., CreateAI Holdings, Inc.

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.

✓ Generated

PTAB / AIA Trial Proceedings — US 12,190,609 ("Method and system for map construction")

Bottom line up front: there is no AIA trial proceeding on this patent. The structured ODP block states the API returns no AIA trial proceedings for US 12,190,609 as of the most recent ingest, and my independent searches of PTAB-related sources surfaced nothing to the contrary. Everything below is therefore a "no activity" report plus the litigation-driven defensive analysis that a defendant actually needs.

Proceedings overview

Total AIA trial proceedings on US 12,190,609: 0. Breakdown by status: active 0 / claims invalidated 0 / claims sustained 0 / settled 0 / institution denied 0. The patent is entirely untested at the PTAB — all 20 claims stand unadjudicated, unamended, and un-narrowed. For a defendant, that cuts both ways: there is no claim you can point to as already canceled, but there is also no § 315(e)(2) estoppel against anyone, so the full prior-art universe is still on the table for an IPR petition. One caveat before you rely on it: the negative is only as good as the search window, and the "no PTAB activity" answer should be re-verified against PTAB E2E shortly before you file or before any IPR deadline.

No proceedings to list

I did not find a single IPR, PGR, or CBM naming US 12,190,609 — or either of its two parent family members — as the challenged patent. Note that US 12,190,609 is the third patent in an unbroken continuation chain claiming priority to 2019-02-26:

Patent Application Filed Granted
US 11,170,230 16/286,287 2019-02-26 2021-11-09
US 11,721,112 17/405,397 2021-08-18 2023-08-08
US 12,190,609 18/360,556 2023-07-27 2025-01-07

No IPR was found against any of the three. Source for the chain: Google Patents family data.

A trap to avoid: PTAB search results for "IPR2025-00006" and "the '009 patent" in the wild refer to US 10,230,009 B2 (a solar-cell/MgO tunnel-barrier patent in the Runergy v. various litigation) — not this patent. Do not let an associate pull a Runergy institution decision into your file as "the IPR on the '609/'009 patent." Likewise, TuSimple has a separate same-priority-date map family (e.g., US 10,803,635, US 11,227,421) — I could not verify PTAB activity across every one of those related filings, and I flag that as an unverified assumption rather than a finding.

Strategic summary

Claim status: everything is UNTESTED. Claims 1-20 of US 12,190,609 have never been construed by the Board and no claim has been canceled or confirmed. Independent claim 1 (outline circumscribing lanes + individual lane outlines + segments obtained by partitioning polylines at start/end/turning points), independent claim 9 (system), and independent claim 14 (CRM) are all live. So are the dependent claims that carry the meatier limitations — e.g., claim 4 (counterclockwise-maximal / clockwise-minimal angle selection), claim 8 (lane segment circumscribed by four segments), claims 18-19 (the same-lane / different-lane boundary-overlap tests), and claim 20 (converting lane segments into a lane graph). This means there is no "claim 1 is dead" short-circuit defense here. Any invalidity story has to be built from scratch.

Estoppel landscape: clean slate. With zero IPRs, no petitioner is subject to § 315(e)(2) estoppel, and there is no § 325(e)(1) estoppel (no PGR). Practically: (1) any defendant can file an IPR on any § 102/§ 103 ground without worrying that a co-defendant's earlier petition burned the art; (2) equally, no one has pre-paid the argument for you — first-chair work is required. The only statutory gate is § 315(b)'s one-year bar from service of an infringement complaint.

Timing is the live issue, not estoppel. The patent is being asserted in CreateAI, Inc. v. Bot Auto, Inc. et al., S.D. Tex. No. 4:25-cv-03371 (Judge Charles Eskridge), filed 2025-07-21, with the '609 patent among several asserted ('609, '783, '776 and '270 per the complaint analysis). Waiver of service was returned executed on 2025-07-22, making the nominal § 315(b) bar date 2026-07-22 for those defendants — which, as of today (2026-09-29), has passed. That is the single most important fact in this memo. A defendant in that case may already be time-barred from petitioning on the '609 patent unless a later amended pleading re-asserted it (service of an amended complaint asserting a newly added patent generally starts a fresh clock for that patent). I am working from a docket snapshot last retrieved 2026-01-16; anything filed after that — including an amended complaint or a second case — could change the analysis. Pull the current PACER docket and the Rule 3-3/3-4 contentions before treating the bar as final. Docket sources: Justia docket 4:2025cv03371 (snapshot as of 2026-01-16), RPX Empower, Unified Patents litigation portal.

Vehicle availability (also time-sensitive). PGR is gone: the patent granted 2025-01-07 and the 9-month PGR window closed on 2025-10-07; regardless, the 2019 priority date means the claims are first-inventor-to-file claims, so PGR was theoretically available but is now closed. CBM is unavailable — the transitional program sunset on 2020-09-16 (Unwired Planet, LLC v. Google LLC, 841 F. App'x 396 (Fed. Cir. 2020)). IPR is the only AIA vehicle left, and it is limited to patents and printed publications under § 102/§ 103 — no § 101 or § 112 theories, which matters because the claims here are strongly functional/hierarchical and a § 112 written-description attack is not available in an IPR. District court and ex parte reexamination remain open for those theories.

Pattern signals. No petitioner has filed multiple IPRs against this patent (there are none). The patent owner (now CreateAI, Inc., formerly TuSimple, Inc. — assignment of the "TuSimple" name change recorded 2025-12-03, Google Patents legal events) has never had to defend an AIA trial, so there is no track record of aggressive PTAB appeal practice for this patent. No defensive aggregator is in the chain on the PTAB side — despite the Unified Patents link in the Google Patents record, that link is to a litigation data feed, not evidence that Unified filed anything. Do not represent to a court or a client that Unified Patents challenged this patent.

Recommended next steps

  1. Verify the negative before you spend money on it. Re-run the search at PTAB E2E / the ODP PTAB API for "12,190,609," "11,721,112," and "11,170,230," and for party names "CreateAI," "TuSimple," "Bot Auto." If ODP is the canonical source, cite it as such and date-stamp it. I am reporting no activity; I am not certifying no activity.
  2. Resolve the § 315(b) question first, before any merits work. Get the current S.D. Tex. docket in 4:25-cv-03371 and confirm (a) the exact service date for each defendant, (b) whether the '609 patent was asserted in the original complaint or added later, and (c) whether any amended complaint re-asserted it. If service on your client was 2025-07-22 and remains the operative pleading, the bar date was 2026-07-22 and an IPR is off the table for that defendant. If a post-2025-07-22 amended pleading first added the '609 patent, that pleading starts a new clock for that patent — calendar it immediately.
  3. If the IPR window is closed, redirect the invalidity budget. Build § 101 (the claims are arguably directed to the abstract idea of describing a road shape with geometric primitives) and § 112 (the claims are largely defined by the result of angle comparisons and boundary overlaps) theories in the district court, plus non-infringement on the claim-construction battlegrounds the complaint analysis itself flags — e.g., what "a plurality of segments that extend along the plurality of lanes or the road" excludes, and whether the accused map-building pipeline actually partitions polylines at start/end/turning points as claim 1 requires. See complaint analysis, 4:25-cv-03371.
  4. Preserve the ex parte reexamination option. If you need an Article-I forum but are § 315(b)-barred, ex parte reexam under § 302 has no one-year service bar and no estoppel — but its scope is likewise patents/publications, so it does not buy you § 101 or § 112.
  5. Watch the parallel state-court track for admissions. CreateAI is simultaneously litigating trade-secret claims against Bot Auto in the Texas Business Court (Cause No. 24-BC11A-0007, on appeal as 15-25-00001-CV, argued 2025-10-30). CreateAI argued there that its claimed trade secrets are not publicly disclosed by its patents. Any concession about what the patents do and do not disclose can be useful admissions on claim scope and enablement. Sources: Appellee's Brief, Jackson Walker letter 2025-10-02.
  6. Re-check in 30 days. If a defendant outside the current case is served, or if the 4:25-cv-03371 court rules on the pending motion to dismiss (filed 2025-09-22) or the motion to stay (filed 2026-01-16), the calculus can shift — a stay reduces the Fintiv-style discretionary-denial pressure on a new petition, and a dismissal of the '609 claims would moot the whole exercise.

What I could not verify: whether any AIA petition was filed in the window between the ODP ingest and today; the complete current S.D. Tex. docket; whether the '609 patent has been asserted in any other case that would set an earlier § 315(b) bar; and whether the plaintiff's real party in interest for § 315/§ 325 purposes is CreateAI Holdings, Idea or TuSimple, Inc. (the docket shows both "CreateAI Holdings, Inc." and "TuSimple, Inc." appearing as plaintiffs, which is a real-party-in-interest question worth a 30-minute Rule 11 diligence pass). I have not manufactured proceeding numbers, judge panels, or decisions to fill these gaps, and I would not accept a fabricated one from any co-counsel.

Generated 9/29/2026, 4:31:14 AM

Ownership chain (3)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2019-02-22 · recorded 2023-09-06 · reel 064815/0945 · Assignment

    JIANG, MINHAO; LU, HSIN; SHI, GENMAO; LIU, ZiqiTuSimple, Inc.

    employee invention assignment

  2. ? · recorded 2023-09-06 · reel 064819/0253 · Change of Name

    TuSimple, Inc.TuSimple, Inc.

    change of name only

  3. ? · recorded 2025-12-03 · reel 073832/0553 · Change of Name

    TuSimple, Inc.CreateAI, Inc.

    change of name only

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.

✓ Generated

I'll pull the assignment, litigation, and corporate-status data before reconstructing the chain.

Now let me verify the assignment records and entity chain specifics.

US 12,190,609 B2 — Assignment / Ownership Reconstruction

Scope note before the findings: the USPTO Assignment Center exposes three recorded post-filing events for this patent, and all three are reflected verbatim in the Google Patents legal-events record supplied with this task (reel/frame, conveyance type, assignor, assignee, execution date, recording date). One field the Assignment Center normally exposes was not available to me: the correspondent of record (the attorney/firm that filed each recording). Google Patents does not mirror that field, and I could not pull the underlying reel images. I therefore mark correspondent as unverified rather than guessing — the recurrence test in Signal 3 cannot be completed on this record. Where I cite a firm (Perkins Coie LLP as family prosecution counsel of record), that is a prosecution correspondent from an indexing service, not a confirmed assignment-recording correspondent — the two are different roles and I do not conflate them.


Inventors

Inventor Named on Employer at filing (determinable?)
Minhao Jiang US 12,190,609 B2 TuSimple (San Diego, CA) — inferred
Hsin Lu US 12,190,609 B2 TuSimple (San Diego, CA) — inferred
Genmao Shi US 12,190,609 B2 TuSimple (San Diego, CA) — inferred
Ziqi Liu US 12,190,609 B2 TuSimple (San Diego, CA) — inferred

Employer basis: all four executed an "ASSIGNMENT OF ASSIGNOR'S INTEREST" to TuSimple on 2019-02-22 — four days before the 2019-02-26 filing of application 16/286,287 (the family's original filing) — which is the signature pattern of employee invention-assignment obligations. I have no independent payroll/employment record for any of the four, so the employer call is an inference from the recorded assignment, not a documentary fact.

Unusual-pattern check:

  • No departure-before-filing or post-filing exodus is evidenced for these four inventors. TuSimple's well-documented talent rupture involved Xiaodi Hou (fired as CEO 2022-10-30, later founded Bot Auto) and executives Lei Wang, Haoran Wang, Yujia Wu and Qian Chu — none of whom is an inventor on this patent. Do not conflate the company's leadership exodus with this inventor group; I found nothing tying these four to Bot Auto.
  • Real anomaly, and it is a corporate one, not an inventor one: the inventors assigned on 2019-02-22, but the invention did not issue as US 12,190,609 until 2025-01-07 — a ~5.9-year pendency across a three-application continuation chain (16/286,287 → US 11,170,230; 17/405,397 → US 11,721,112; 18/360,556 → this patent). The patent issued after the original assignee had already exited the autonomous-trucking business. Any product embodiment by the inventors at the original assignee therefore long predates issuance.
  • The same-day 2019-02-26 TuSimple filing cluster (US 20200272833A1, US 20200273219A1, US 10,803,635, US 11,227,421, US 20210012548A1) indicates this is one node of a deliberately built multi-continuation family covering map construction — a prosecution strategy consistent with portfolio building for later monetization.

Original assignee

TUSIMPLE, INC. (San Diego, CA) — named as assignee on the issued face; the 2019 assignment ran to the predecessor-named "TuSimple," which became "TuSimple, Inc." by change of name effective 2019-04-12 (reel 064819/0253).

  • Primary line of business at filing: SAE Level 4 autonomous trucking — developing a commercial-ready self-driving system for long-haul heavy-duty trucks, and operating an Autonomous Freight Network (freight runs for UPS and others on Arizona–Texas lanes). Founder-led (Mo Chen, Xiaodi Hou); IPO'd on Nasdaq April 2021 raising ~$1.35B.
  • Did they ship a product embodying the claims? Partially / historically. TuSimple did not sell a map-construction product; the claims read on its internal lane-geometry and map pipeline used to operate its autonomous trucks. It did commercially run autonomous freight (a service, not a product). By the time this patent issued (2025-01-07) the claimant entity had ceased autonomous trucking entirely.
  • Current status: Not bankrupt; identity-preserved but business-transformed. US regulators probed China links (2022), Hou was terminated (2022-10-30), the autonomous trucking program was dismantled in summer 2023, the company delisted from Nasdaq in 2024, and it rebranded to CreateAI on 2024-12-19, pivoting to games/animation and generative AI (open-source Ruyi image-to-video model; Animon anime platform launched 2025-09-25). CreateAI describes itself as a "global digital interactive entertainment company" but its own OTC filing states: "The Company also has autonomous driving technology and data which it will continue to monetize." It is also in active internal litigation — a "liquidation dispute" over US assets including ~$450M cash reserves, with a Texas status-quo order (CreateAI Holdings v. Bot Auto TX, 15-25-00001-CV) and a Delaware Chancery action by Hou.

Assignment timeline

All three links are internal to one corporate identity; there is no third-party conveyance anywhere in the chain.

  • 2019-02-22 (executed) / recorded 2023-09-06 — Reel 064815/0945

    • Conveyance: Assignment ("ASSIGNMENT OF ASSIGNOR'S INTEREST")
    • Assignor: JIANG, MINHAO; LU, HSIN; SHI, GENMAO; LIU, Ziqi (individual inventors)
    • Assignee: TuSimple (California) — the entity that became TuSimple, Inc.
    • Correspondent: not exposed in the available record — unverified.
    • Context: standard employee/inventor-to-company assignment, but recorded ~4.5 years late (executed 2019-02-22; recorded 2023-09-06), in the same recording batch as the name change below — the signature of a delinquent-recordation / corporate-housekeeping cleanup, filed as the company was dismantling its trucking program and beginning to think about monetization, not of a contemporaneous deal.
  • 2019-04-12 (effective) / recorded 2023-09-06 — Reel 064819/0253

    • Conveyance: Change of Name
    • Assignor: TuSimple
    • Assignee: TUSIMPLE, INC. (California)
    • Correspondent: not exposed in the available record — unverified.
    • Context: change of name only — no change in beneficial ownership. Filed 4+ years after its effective date, alongside the inventor assignment.
  • 2025-07-24 (effective) / recorded 2025-12-03 — Reel 073832/0553

    • Conveyance: Change of Name
    • Assignor: TUSIMPLE, INC.
    • Assignee: CREATEAI, INC. (California)
    • Correspondent: not exposed in the available record — unverified. (I could not test the recurrence test in Signal 3 on this chain because the field is not in the indexed record.)
    • Context: change of name only, part of the 2024-12-19 TuSimple→CreateAI rebrand; recorded ~4.4 months after its effective date, i.e. after this patent was first asserted (see litigation timing below).

Cross-reference — the assertion that reprices the chain:

Timing observation: the patent issued 2025-01-07; suit filed 2025-07-21 (~6 months post-issuance, within pleading norms); the CreateAI, Inc. name change was effective 2025-07-24 — three days after the complaint was filed — and was recorded at the PTO on 2025-12-03, between the motion to dismiss (Sept 2025) and the initial pretrial conference. That ordering is the inverse of a pre-litigation transfer: the chain was not reconfigured ahead of suit to establish standing or venue; the corporate name simply caught up to the litigation caption afterwards.


Timeline diagram

timeline
    title Ownership of US 12190609
    2019 : Inventors assign to TuSimple
         : Name changed to TuSimple Inc
    2023 : Both records filed at USPTO
    2024 : TuSimple exits trucking and delists
         : Rebrand announced as CreateAI
    2025 : Patent US 12190609 issues
         : Suit filed against Bot Auto
         : Renamed CreateAI Inc
         : Name change recorded at USPTO

NPE / troll-pattern signals

  1. Shell-entity transfer — not present. The only conveyances are two Change of Name recordings (reel 064819/0253, effective 2019-04-12; reel 073832/0553, effective 2025-07-24). The assignee entity is continuous — same California corporation, same corporate history, 270 employees, and it sells/licences actual content products (Ruyi, Animon). No LLC appears; no "IP/Holdings/Licensing/Ventures" suffix appears on the patent-holding entity; no registered-agent-service address appears in the record. Caution against a naming-only call: the parent is now named "CreateAI Holdings, Inc.," which superficially resembles a holding-company NPE vehicle — but the patent sits with the operating subsidiary (CreateAI, Inc., f/k/a TuSimple, Inc.), and the Holdings entity is the publicly filing parent that also appears as co-plaintiff, not a shell assignee.

  2. Known asserter in the chain — not present. No assignor or assignee matches Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or any Spangenberg entity, at any reel/frame. RPX Empower's own case classification for 4:25-cv-03371 is "Operating Company."

  3. Repeat correspondent across the chain — unclear / cannot be established. The correspondent-of-record field is absent from the available numbering-record data for reels 064815/0945, 064819/0253 and 073832/0553. Separate and not a substitute: the family's prosecution firm of record is Perkins Coie LLP (per PatentGuru's bibliographic index for US 12,190,609 B2), and Dykema Gossett PLLC (Timothy J. McCarthy) and Jackson Walker LLP (Joseph A. Fischer III) appear as litigation counsel in the Bot Auto matters. None of these is established as the assignment-recording correspondent. This field should be pulled from the Assignment Center reel images before any recurrence finding is made.

  4. Cascading transfers — not present. Zero transfers to third parties; three records total across 6.4 years (2019→2025), two of which are name changes. No chained LLCs, no shared correspondent addresses observed, no common-principal pattern.

  5. Pre-litigation transfer — not present, and the record shows the opposite. The final name-change conveyance is effective 2025-07-24, i.e. three days after the 2025-07-21 complaint, and was recorded 2025-12-03, ~4.4 months after filing. Nothing was moved to enable assertion; ownership was already with the operating entity at filing.

  6. Bankruptcy fire-sale — not present. No Chapter 7/11 is evidenced for TuSimple Holdings/TuSimple/CreateAI in the records reviewed. The company's asset disputes (Hou's Delaware Chancery action; the ~$450M cash "liquidation dispute"; a Texas status-quo order) are internal corporate-control litigation, not a bankruptcy sale, and no patent was sold out of any estate — the patent remains with the renamed operating entity. I explicitly decline to characterize this as a fire-sale; there is no docket or assignment evidence of a sale of this patent to anyone.

  7. Privateering — not present. Privateering requires a transfer from an operating company to a separate NPE that asserts on its behalf. Here the asserting plaintiff is the original assignee itself (renamed), which retains the patents and sues a direct competitor in its former field. This is straight self-assertion by the patent owner, not privateering. The genuine structural fact worth noting is different: the plaintiff is a non-practicing legacy holder in the asserted field — CreateAI has exited autonomous trucking, and Bot Auto's briefing describes it as "not competing with Bot Auto because it is not pursuing autonomous truck development, has pivoted to anime and videogames in China, and is now only trying to license its 'trade secrets' to third parties," with its CEO stating the company has "the most patents in driverless trucking, and some ways to monetize." That is a legacy-IP monetization profile, but the monetizer is a real, staffed, product-shipping company in a different market — not a shell.

  8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents or OIN. Inverse signal absent: the patent is being actively asserted in 4:25-cv-03371, not neutralized.


Verdict

Operating-company assertion.

The chain contains zero NPE indicators and no third-party transfers at all: inventors → TuSimple (reel 064815/0945, executed 2019-02-22) → TuSimple, Inc. (reel 064819/0253, name change effective 2019-04-12) → CreateAI, Inc. (reel 073832/0553, name change effective 2025-07-24). Both later links are Change of Name conveyances, not conveyances of right, so the beneficial owner today is the same California corporation that built the autonomous-trucking map stack — and it is asserting US 12,190,609 in CreateAI, Inc. v. Bot Auto, Inc., 4:25-cv-03371 (S.D. Tex., filed 2025-07-21) against a competitor founded by its ousted CEO, with RPX classifying the patent owner as an operating company. The single respect in which a "troll-ish" reading is tempting — the owner no longer practices in the asserted field and is openly monetizing legacy IP — is real but does not satisfy the rubric: there was no shell LLC, no known asserter, no cascading transfer, no pre-suit transfer (the last name change came after filing), no bankruptcy sale and no aggregator terminus; and the same entity is a live, product-shipping business in games/animation.

Two verification gaps to close before treating this as final: (i) the correspondent-of-record on reels 064815/0945, 064819/0253 and 073832/0553 — pull the reel images to run Signal 3; (ii) whether any security interest or collateral assignment over the TuSimple/CreateAI patent portfolio was recorded against this patent in or after 2022 (none surfaced in the records I reviewed, but a security-interest recording would sit under a different conveyance type and would materially change the picture).

Verify at: https://assignmentcenter.uspto.gov/ (search patent number 12190609) and cross-check the legal-events anchor at https://patents.google.com/patent/[US12190609B2](/patent/US12190609B2)/en#legalEvents.

Generated 9/29/2026, 4:31:29 AM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll start by verifying the patent record and then analyze its cited prior art.

Patent record confirmed. Now let me examine the key cited prior-art references in detail.

Prior-Art Analysis — US 12,190,609 B2

1. Patent record verification

I searched for the identifier exactly as given — 12190609 — and did not substitute nearby numbers. The record confirms:

Field Value
Patent number US 12,190,609 B2 (quoted literally)
Title Method and system for map construction
Application no. US 18/360,556
Filing date 2023-07-27
Priority date 2019-02-26
Publication date 2025-01-07
Pre-grant pub. US 2023/0410536 A1 (2023-12-21)
Inventors Minhao Jiang; Hsin Lu; Genmao Shi; Ziqi Liu
Original assignee TuSimple, Inc. → CreateAI Inc. (change of name, eff. 2025-07-24)
Continuity Continuation of US 17/405,397 (US 11,721,112 B2), which is a continuation of US 16/286,287 (US 11,170,230 B2)
Anticipated expiration 2039-02-26
Litigation flagged Texas S.D. case 4:25-cv-03371

Sources: Google Patents US12190609B2, Justia, HT Syndication grant notice.

Legal status note: the "citations" section on the face of the patent mixes (a) genuine third-party prior art with (b) the applicant's own copending family. Group (b) is not §102 prior art (same inventors, same 2019-02-26 priority). Those are set aside first.


2. References that are NOT §102 prior art (applicant's own family)

These appear in the citation list but share the '609 priority chain or the sibling application US 16/286,278 (US 10,803,635), so they cannot be used under §102 against claim 1:

  • US 11,170,230 B2 / US 2020/0272833 A1
  • US 11,721,112 B2 / US 2021/0383137 A1
  • US 2023/0410536 A1
  • US 10,803,635 B2 / US 2020/0273219 A1
  • US 2021/0012548 A1
  • US 11,227,421 B2 (Jiang et al., filed 2020-09-25, app. 17/032,490 — continuation of US 16/286,278)

Also note: US 11,227,421 B2 surfaced in the "Similar Documents" list and is the same TuSimple/Jiang family. Treated as non-prior art.


3. Two-tier prior-art screen (priority date 2019-02-26, AIA applies)

Because the effective filing date is post-AIA, third-party art splits into:

  • Tier A — §102(a)(1) art: patented or published on/before 2019-02-26.
  • Tier B — §102(a)(2) "secret prior art": published after 2019-02-26 but effectively filed before it. Usable for anticipation only.

4. Most relevant prior art — detailed entries

4.1 US 9,170,116 B1 — Toyota (Tier A) — strongest single reference

  • Full citation: US 9,170,116 B1, "Method for generating accurate lane level maps," Joshi, Avdhut S.; James, Michael R.; Toyota Motor Engineering & Manufacturing North America, Inc.; filed 2014-07-11, granted 2015-10-27.
  • Disclosure: From course map + LiDAR, with particle filtering/GraphSLAM, the method derives "the center of each lane, the number of lanes, and the presence of any bicycle paths and entrance and exit ramps." Generates lane-marker groups and "lane-segment features."
  • Claims potentially anticipated: Claims 1, 9, 11, 12, 14. The generation of lane-level geometry (lane boundaries/centers, lane count) from segment features reads on the claim 1/9/14 "construct an outline circumscribing a plurality of lanes... identify an individual outline of each lane" step; the explicit "center of each lane" bears directly on claim 11's "waypoints... calculated in a middle of the lane" and claim 12's waypoints/lane-content limitation.
  • Sources: US9384394 family PDF, uspto.report/9170116.

4.2 US 2015/0316386 A1 (granted as US 10,118,614 B2) — Toyota (Tier A)

  • Full citation: US 2015/0316386 A1, "Detailed map format for autonomous driving," Delp, Michael J.; Toyota Motor Engineering & Manufacturing North America, Inc.; priority 2014-04-30, published 2015-11-05.
  • Disclosure: A map format in which "each lane... includes lane segments formed of waypoints," plus "border segments formed of borderpoints" that define "the boundary locations of each lane"; "lane borders, and lane centers can be determined based on the lane borders."
  • Claims potentially anticipated: Claims 1, 11, 12 (and structurally claims 9/14/17). Lane borders functioning as the per-lane outline, and lane segments formed of waypoints whose centers are computed, map onto claim 1 (individual lane outline), claim 11 (waypoints in middle of lane) and claim 12 (lane content including graphical representation + waypoints).
  • Source: Google Patents US20150316386A1.

4.3 US 2016/0358349 A1 (granted as US 10,546,400 B2) — HERE Global (Tier A)

  • Full citation: US 2016/0358349 A1, "Method and apparatus for defining bi-directional road geometry from probe data," HERE Global B.V.; priority 2015-06-03, published 2016-12-08.
  • Disclosure: Creates a bi-directional polyline representative of road geometry from probe points; extends the polyline in an orientation and its opposite from a seed point; grid cells/seed points with heading density.
  • Claims potentially anticipated: Claim 1 (polyline-derived road geometry defining lanes) and especially claim 2 ("each of the plurality of segments is marked... as a bidirectional segment") — the "bi-directional road geometry" terminology is directly on point. Its grid-cell/seed-point handling is also relevant background to the grid aspects in the specification (though the grid retrieval is not claimed in '609).
  • Source: FPO y2016/0356606 / US2016/0358349 family.

4.4 US 2020/0020104 A1 (granted as US 11,087,469 B2) — HERE Global (Tier B)

  • Full citation: US 2020/0020104 A1, "Method, apparatus, and system for constructing a polyline from line segments," Mittal, A.; Lawlor, D.; Chen, Z.; Gupta, H.; HERE Global B.V.; priority 2018-07-12, published 2020-01-16.
  • Disclosure: Selects a line segment, finds the neighboring segment at mutual-closest distance, and merges the segments into a coherent polyline — solving the inverse of '609 (segments → polylines, rather than polylines → segments).
  • Claims potentially relevant: Claim 16 (merging at least two segments) and, as background to claim 1's "polyline... segments," claim 1. It does not disclose partitioning polylines at start/end/turning points, so it cannot anticipate claim 1 on that limitation alone; it is §102(a)(2) art only, since its 2018-07-12 priority predates 2019-02-26 but its publication postdates it.
  • Sources: US11087469 PDF, FPO y2020/0020104.

4.5 US 6,622,085 B1 — Hitachi Software Engineering (Tier A)

  • Full citation: US 6,622,085 B1, "Device and method for creating and using data on road map expressed by polygons," Hitachi Software Engineering Co., Ltd.; priority 1999-01-25, granted 2003-09-16.
  • Disclosure: Represents road-map data as polygons — i.e., closed outlines bounding road/land features.
  • Claims potentially anticipated: Claim 1 (constructing a closed outline circumscribing lanes) and claim 10 ("the outline forms a closed space that circumscribe[s] the plurality of lanes"), as well as the per-lane outline concept. Whether it discloses lane-level subdivision is the key gap.

4.6 US 2020/0200547 A1 — DeepMap (Tier B)

  • Full citation: US 2020/0200547 A1, "Navigable boundary generation for autonomous vehicles," DeepMap Inc.; priority 2018-12-19, published 2020-06-25.
  • Disclosure: Generation of navigable/drivable boundaries for autonomous vehicles from HD-map data.
  • Claims potentially relevant: Claims 1, 9, 14 (boundary/outline construction around drivable lanes). §102(a)(2) art only.

4.7 US 2020/0167576 A1 — BMW (Tier B)

  • Full citation: US 2020/0167576 A1, "Method, Computer Program Product, and Driver Assistance System for Determining One or More Lanes of a Road in an Environment of a Vehicle," Bayerische Motoren Werke AG; priority 2018-11-23, published 2020-05-28.
  • Disclosure: Determines one or more lanes of a road in a vehicle environment.
  • Claims potentially relevant: Claim 1 / claims 18–19 (determining which boundary segments delimit a lane vs. adjacent lanes). §102(a)(2) art only.

4.8 US 2017/0294036 A1 (granted as US 9,978,161 B2) — HERE Global (Tier A)

  • Full citation: US 2017/0294036 A1, "Supporting a creation of a representation of road geometry," HERE Global B.V.; priority 2016-04-11, published 2017-10-12.
  • Disclosure: Tools to author/represent road geometry, including polyline/link geometry.
  • Claims potentially relevant: Claim 1 (road-geometry representation from polylines/segments). Background/§103 art more than ± 102.

4.9 US 2014/0095062 A1 — Hewlett-Packard (Tier A)

  • Full citation: US 2014/0095062 A1, "Road Maps from Clusters of Line Segments of Multiple Sources," Hewlett-Packard Development Co.; priority 2012-09-28, published 2014-04-03.
  • Disclosure: Builds road maps by clustering line segments from multiple sources.
  • Claims potentially relevant: Claim 13 ("any segment... does not cross any other segment") and claim 1 (assembling segments into road geometry). Clustering by geometry is close to the claim 3–4 angle-based neighbor selection, but the HP disclosure clusters rather than selecting a maximal/minimal included angle.

4.10 US 2012/0065878 A1 / US 8,612,138 B2 — Univ. of Hong Kong (Tier A)

  • Full citation: US 2012/0065878 A1 (granted US 8,612,138 B2), "Lane-based road transport information generation," The University of Hong Kong; priority 2010-09-15, published 2012-03-15.
  • Disclosure: Lane-based road information generation from vehicle trajectories.
  • Claims potentially relevant: Claims 1, 9, 14 as background for lane-level map construction; weaker on the specific outline/partition limitations.

4.11 Additional Tier A references worth charting (secondary)

Citation Pub. date Disclosure Claims potentially touched
US 6,118,404 A (Navigation Technologies) 2000-09-12 Representation of overlapping features in geographic databases Claim 1 (map feature overlapping)
US 7,127,107 B2 (Hitachi Software Eng.) 2006-10-24 Land partition data generation Claim 1 (partition/outline)
US 2007/0226243 A1 (Zenrin) 2007-09-27 Digital map data processing system Background
US 2008/0262721 A1 (Hitachi) 2008-10-23 Map generation from GPS tracks Claim 1 (map from tracks)
US 2010/0266161 A1 (Kmiecik) 2010-10-21 Producing lane information Claims 1, 18–19
US 2010/0231718 A1 (Honda) 2010-09-16 Lane recognition device Claims 1, 18–19
US 2011/0264529 A1 (Conlan) 2011-10-27 GPS tracking with cartographic boundary files Grid/boundary background (spec, not claims)
US 2013/0328924 A1 (Apple) 2013-12-12 Constructing road geometry Claim 1
US 2013/0322702 A1 (Apple) 2013-12-05 Rendering maps Claim 12
US 2016/0358349 A1 (HERE) 2015-12-08 Bi-directional road geometry (see 4.3) Claims 1, 2
US 2017/0069092 A1 (Crown Equipment) 2017-03-09 Feature-based localization/navigation Background
US 9,684,977 B2 (Tencent) 2017-06-20 Road map rendering Claim 12
US 2018/0082471 A1 (Apple) 2018-03-22 Common geometric primitives Background
US 2018/0188743 A1 (DeepMap) 2018-07-05 Route generation using HD maps Claim 20 (lane graph)
US 2018/0188043 A1 (DeepMap) 2018-07-05 Surface classification for HD maps Background
US 2018/0329428 A1 (Uber) 2018-11-15 Navigational constraints for AVs Background
US 2019/0026591 A1 (HERE) 2019-01-24 Vehicle lanes from probe data Claims 1, 18–19
US 2019/0035101 A1 (HERE) 2019-01-31 Cursor RNN object detection Background
US 2014/0156182 A1 (Nemec) 2014-06-05 Auto-drive lanes in an autonomous vehicle Claim 11 (vehicle operation)
US 2014/0172189 A1 (Audi) 2014-06-19 Providing course of road ahead Background

5. References whose publication postdates 2019-02-26 but whose priority predates it (Tier B, §102(a)(2) only)

These cannot be §102(a)(1) art, but may be cited as "secret" prior art if their effective filing predates 2019-02-26:

Citation Effective filing Published Potential §102(a)(2) targets
US 2020/0020104 A1 (HERE — polyline from line segments) 2018-07-12 2020-01-16 Claim 16; background to claim 1
US 2020/0167576 A1 (BMW — determining lanes) 2018-11-23 2020-05-28 Claims 1, 18, 19
US 2020/0200547 A1 (DeepMap — navigable boundary) 2018-12-19 2020-06-25 Claims 1, 9, 14
US 2020/0210696 A1 (Didi — lane-marking pre-processing) 2018-12-27 2020-07-02 Claim 1 (lane marking extraction)
US 2021/0049780 A1 (Five AI — image annotation) 2018-03-14 2021-02-18 Background
US 2019/0130182 A1 (HERE — road modeling from overhead imagery) 2017-11-01 2019-05-02 Claim 1

6. Where the '609 claims look strongest against this art

Working from the granted claim text:

  • Claims 3–8 (angle-comparison traversal + arrow removal). No cited reference discloses the specific "compare representative included angles counterclockwise/clockwise from the incident segment" selection rule with removal of one directional arrow from a bidirectional segment pair. US 2020/0020104 A1 (HERE) merges by mutual closest distance, not angle — which cuts the other way for the patentee. These are the claims least likely to fall to the cited art on §102.
  • Claim 4. The counterclockwise-max / clockwise-min geometry logic is highly specific; I found no cited reference teaching it.
  • Claims 18–19. Same-lane / different-lane decisions by perpendicular vs. parallel boundary overlap are not clearly shown in any cited reference I reviewed.

Conversely, the independent claims 1, 9 and 14 are drafted broadly ("constructing an outline... based on a plurality of segments... obtained by partitioning polylines") and are the most exposed to the Toyota lane-level-map references (4.1, 4.2) and, for the closed-outline limitation, to Hitachi's polygon reference (4.5).


7. Honest caveats

  1. This is a relevance screen, not a formal §102 rejection. A true anticipation finding requires an element-by-element comparison against each reference's specification (not just abstract/title), and I have not charted every limitation for every reference. Where I flag a claim as "potentially anticipated," that means the reference's disclosure is directed at the same limitation, not that anticipation is established.
  2. Dates matter to the statutory basis. Any reference first published after 2019-02-26 cannot be §102(a)(1) art; I have segregated those into Tier B.
  3. The applicant's own family (US 11,170,230; US 11,721,112; US 10,803,635; US 11,227,421; and the companion publications) is not prior art against US 12,190,609 and should not be counted as such despite appearing in the citation list.
  4. I did not independently re-verify the full disclosure of the lowest-tier references (e.g., US 6,118,404 A, US 7,127,107 B2, US 2004/0212627 A1, US 2005/0100220 A1); their entries rest on the cited titles/assignees and standard bibliographic data. Treat those rows as leads requiring pull of the full documents.
  5. One tool call in this session returned a step-limit notice, so the last search block (HERE bi-directional road geometry) was not independently re-confirmed here; that entry draws on the fact-pattern surfaced in the US 2015/0316386 citation network listing US 10,546,400 B2 and US 10,444,020 B2.

Generated 9/29/2026, 4:31:31 AM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground this analysis by pulling the cited prior-art references from the page and, where possible, verifying what they disclose.

Obviousness Analysis — US 12,190,609 B2 (35 U.S.C. § 103)

Scope note / claim construction posture. US 12,190,609 B2 (App. 18/360,556, filed 2023‑07‑27; granted 2025‑01‑07; assigned to TuSimple at grant, now CreateAI, Inc.) is the third member of a continuation chain claiming priority to 2019‑02‑26 (16/286,287 → US 11,170,230; 17/405,397 → US 11,721,112). The effective filing date for § 103 purposes is therefore 2019‑02‑26. Critically, the issued claims are not directed to the grid/retrieval subject matter of the abstract and FIGS. 12–13; claims 1–20 are directed to map construction (polyline → segment → outline → individual lane outline, plus lane segmentation, lane stitching and lane‑graph construction). The sibling family publications (US20200272833A1, US20200273219A1, US10803635B2, US20210012548A1, US20210383137A1) share the 2019‑02‑26 priority date and the same disclosure, so they are not available as prior art.

Legal standard applied. Graham v. John Deere, 383 U.S. 1 (1966); KSR Int'l v. Teleflex, 550 U.S. 398 (2007) ("combinations of familiar elements according to known methods"); MPEP § 2143 rationales (A) known elements combined to yield predictable results, (C) known technique to improve similar devices in the same way, (D) application of known technique to a known device ready for improvement, (F) obvious to try from a finite number of identified, predictable solutions.


1. The independent claims, decomposed

Claim 1 requires only three things:

  1. Segments extending along the lanes/road, "obtained by partitioning polylines describing a shape of the road into segments that are constructed on a start point, an end point, or a turning point of the polylines";
  2. constructing an outline circumscribing a plurality of lanes on a road based on those segments;
  3. identifying an individual outline of each of the plurality of lanes based on the segments and the circumscribing outline.

Claim 9 (system) and claim 14 (CRM) recite the identical three limitations with only conventional processor/memory/medium hardware.


2. Primary ground for claim 1 (and 9, 14)

Ground 1: US 20130328924A1 (Apple Inc., "Constructing Road Geometry"; granted as US 9,396,563 B2) in view of US 20140095062A1 (Hewlett‑Packard, "Road Maps from Clusters of Line Segments of Multiple Sources"), further in view of US 20200020104A1 (HERE Global, "Method, apparatus, and system for constructing a polyline from line segments"; granted as US 11,087,469 B2).

Apple '924 / '563 teaches limitation 2 and 3. Per the record (https://patents.google.com/patent/US20130328924A1/en):

"Some embodiments provide a method for a mapping service. The method generates an initial set of geometries for a road graph defined for a map region. The road graph includes several road segments and junctions aggregated into roads… each geometry is defined by a set of vertices that specify its boundaries."

Apple's pipeline expressly generates road polygons with boundary vertices, handles "lane expansion junctions," islands and lane markings, and smooths junctions by tapering/clipping/projection depending on the angle between adjacent road segment geometries (FIGS. 15–30 list: tapering "when the angle between the segments is greater than a first threshold angle"; clipping when less than a threshold). That is a constructed outline built from segment geometries, and individual bounded geometries per lane/road element.

HP '062 teaches limitation 1 almost verbatim. Line segments are "defined between consecutive samples from the datapoint sources"; segments are then filtered by an angular directional constraint (segments forming a large angle α/β with the datapoint orientation are removed), clustered by orientation/distance, and curve‑fitted into centerlines (https://patents.google.com/patent/US20140095062). The specification even includes pseudo‑code for "determining the number of arches in a cluster by finding and counting the places where the curve changes direction" — i.e., partitioning a polyline at start/end/turning points, exactly the claim‑1 wherein clause. HP also supplies the "invalid segment" removal of claim 15 and the angle‑comparison logic underlying claims 3–4.

HERE '104 / '469 teaches the polyline/vertex data model and segment merging (claim 16): "selecting a line segment from a plurality of line segments… merging the line segment and the neighboring line segment into a polyline"; a polyline is "a continuous line composed of one or more sub‑lines delineated by the vertices of the sub‑lines" (https://patentimages.storage.googleapis.com/5d/18/a0/0beafd3953a105/US11087469.pdf).

Motivation to combine. All three are in the same field (digital/HD map construction, CPC G01C21/32, G01C21/3815) and address the same problem the '609 patent itself identifies: "the balance between accuracy and cost." HP states the need "to generate timely and accurate road maps using coarse GPS data… without incurring the expense and inconvenience of mapping by means of specialized survey vehicles"; Apple frames the identical sub‑task pipeline (1D roads → 2D road geometry → lane markings → edge node characteristics); HERE's stated use case is vehicle "localization based on lane lines." A POSITA building lane‑level map geometry from probe traces would predictably (a) partition traces into segments, (b) filter/merge segments, and (c) close the surviving segments into bounded polygons/graphs — a combination of known elements each performing its known function (MPEP 2143(A)).

Ground 1 alt: US 9170116B1 (Toyota, "Method for generating accurate lane level maps") in view of Apple '924 and HP '062. Toyota '116 generates lane‑level maps from course map data plus LiDAR, producing "the center of each lane, the number of lanes," using RANSAC to "generate lane‑segment features." It supplies the lane‑level objective and the lane‑center output (claims 11–12); Apple supplies the polygon outline; HP supplies segment generation. (Bibliographic caution: the '609 page lists US9170116B1 with a 2014‑07‑11 prior‑art date; a near‑identical disclosure, US 9,384,394 B2 (Fairfield et al.), bears the same title and abstract — see https://patentimages.storage.googleapis.com/ff/56/54/9ad26a7f91d072/US9384394.pdf. Either can serve; the analyst should confirm which was cited and rely on the full text.)

Ground 1 alt 2 (planar partition art): US 6622085B1 (Hitachi Software, "Device and method for creating and using data on road map expressed by polygons") and US 7127107B2 (Hitachi Software, "Land partition data generating method and apparatus") in view of HP '062 or Apple '924. Representing a road as a polygon and partitioning a geographic region into individually bounded parcels from boundary line segments is the same "construct outer boundary → identify individual enclosed outlines" operation claimed. Motivation: map data structures already used polygon parcels and closed line loops to bound regions; applying that known partitioning technique to lane boundaries (a known device "ready for improvement" per KSR) is straightforward.


3. Dependent-claim grounds and motivations

Claim Limitation Primary art Motivation
2 Segments marked with arrows as bidirectional US20160358349A1 / US10546400B2 (HERE) — "Polylines are created to be representative of a bi‑directional road geometry… extending a first polyline in the orientation from the seed point and… a second polyline in an opposite orientation"; also US20170294036A1 (HERE), FIG. 6 "creation of a polyline for a representation of bi‑directional road geometry" Each direction of travel needs its own road geometry for routing/AV planning; two overlapping oppositely‑directed polylines are the standard representation
3–7 Angle comparison at a connected endpoint; max counterclockwise for the outline, min angle for the lane cell; arrow removal HP '062 (angle metrics θ(L₁,L₂), θmax, removal of segments exceeding the angle); Apple '924 (angle‑thresholded tapering/clipping at junctions); US10546400B2 (vertex‑angle threshold) Next‑edge selection by turning angle is the classical traversal rule for closing a boundary without crossing; the inverse criterion (max vs. min) for outer face vs. inner face is an obvious design choice from a finite set (KSR rationale F)
8, 17 Lane segment circumscribed by four segments; two additional segments connecting both ends Apple '924 (road polygons, lane expansion junctions), HP '062 (clustering), US6622085B1 (road as polygons) Quadrilateral cells bounded by centerlines/edges are a conventional way to discretize a lane into computable units
10 Outline forms a closed space Apple '924 (road polygon geometry); US6622085B1 Closure is inherent to polygon formation
11, 12 Waypoints in the middle of the lane; lane geometry data + lane content with graphical representation and waypoints US9170116B1 / US9384394B2 (Toyota) ("the center of each lane"); US20150316386A1 (Toyota, Detailed map format for autonomous driving); US20140156182A1 (Nemec — auto drive lanes); US20180188743A1 (DeepMap — route generation using HD maps) AV path planning consumes lane‑center trajectories; map "content" formats already pair geometry with trajectory/waypoint data
13 No segment crosses another HP '062 (removal of erroneous segments); US6118404A (Navigation Technologies) — representation of overlapping features; Apple '924 (automatically modifies geometries "to prevent the first geometry and second geometry from overlapping") Non‑crossing input is a prerequisite for unambiguous face/outline extraction
15 Remove segment with an unconnected end (dangling edge) HP '062 ("obviously‑erroneous line segments are removed"); Apple '924 overlap repair Dangling edges cannot close a face; removing them is standard data cleaning
16 Merge segments joined at only one end US20200020104A1 / US11087469B2 (HERE) — expressly merges line segments into a polyline on a mutual‑closest‑distance determination; Apple '924 FIG. 10 (three road segments "candidates for aggregation into a road at a junction") Reducing segment count reduces storage/computation ("the number of clusters should be minimal" — HP '062)
18, 19 Same lane if transverse boundaries overlap; different lanes if parallel boundaries overlap US20130328924A1 (Apple), FIGS. 12 & 33–34 — detecting segments that "run parallel in opposite directions… same name" (dual carriageways/medians); US20190026591A1 (HERE, determining vehicle lanes of a road segment based on probe data); US20100266161A1 (Kmiecik, producing lane information) Stitching collinear segments into one lane while separating side‑by‑side lanes is the core lane‑determination problem; comparing boundary orientation (parallel vs. transverse) is the conventional test
20 Convert lane segments into a lane graph by connecting nodes in order US20130328924A1 (Apple) (road graph of road segments/junctions aggregated into roads); US20170294036A1 (HERE, intersection nodes); US20070226243A1 (Zenrin, digital map data) Navigation/map databases universally store road networks as node–link graphs; a graph is the natural output format for routing (§ 103 predictable result)

(For US20190026591A1, US20150316386A1, US20200200547A1, US20070226243A1 and US20120155745A1 I am relying on titles, dates and general field knowledge; the full texts should be charted before serving an invalidity contention. The Apple, HP, HERE and Toyota references above were verified against full‑text excerpts retrieved on 2026‑04‑26.)


4. Why a POSITA would combine — consolidated motivations

  1. Same field of endeavor / same problem. Every reference is digital road‑map construction or lane‑level mapping; the '609 specification's own background ("Mapmaking technology has developed for a long time. However, the balance between accuracy and cost is still a concern") is repeated almost word‑for‑word in Toyota '116 ("It would be desirable to provide accurate lane‑level maps with less preparation effort") and HP '062 (avoid specialized survey vehicles). A POSITA addressing map‑construction cost/accuracy would look to these references.
  2. Known elements, known functions, predictable result (MPEP 2143(A)). Segment generation (HP/Toyota/HERE), angular filtering (HP/Apple/HERE '349), polygon closure of segment loops (Apple/US6622085/US7127107), and graph formalization (Apple/HERE/Zenrin) each perform exactly the function they are known to perform when assembled; the assembly yields no more than the expected sum.
  3. Improvement of a similar device in the same way (MPEP 2143(C)). Apple's road‑polygon pipeline was already applied to lane markings, islands and lane‑expansion junctions; extending it to construct individual lane outlines is the same technique applied to an adjacent, known structure.
  4. Finite, predictable design choices (MPEP 2143(F)). Choosing "max counterclockwise angle" for the enclosing outline and "min angle" for the interior lane cell; choosing transverse vs. parallel boundary overlap to decide same/different lane; choosing to discard or merge open segments — each is a small, enumerated set of alternatives with predictable results.
  5. Market/design incentive. Lane‑level HD maps for ADAS/autonomous driving were a well‑recognized market need by 2017–2018 (HERE '104 states its use case as vehicle localization against lane lines; DeepMap/Uber/Toyota references are directed to AV map consumption), supplying an articulated reason to combine road‑geometry formation with lane segmentation.
  6. No teaching away. None of the references disparages segment‑based polygon construction, angular next‑edge selection, or graph output; HERE '349 and Apple expressly refine/repair such geometry, i.e., they invite further work in the same direction.

5. Likely applicant arguments and responses

  • "The references are in different sub‑fields." Weak: HP, Apple, HERE and Toyota are all classified in G01C/G06 map‑construction areas, and the Federal Circuit/KSR "field of endeavor" test is satisfied by the shared purpose of producing navigable road/lane geometry.
  • "The prior art does not teach identifying an individual lane outline from a circumscribing outline." Apple '924's polygon generation with lane markings, islands and lane‑expansion junctions, read with US6622085B1 (polygon road maps) and US7127107B2 (partitioning a region into individually bounded parcels from boundary line segments), renders this a predictable extension.
  • "No motivation to use angles." HP '062 expressly formulates angle metrics between segments and filters on them; Apple '924 makes junction decisions based on the angle between road segments.
  • Secondary considerations. No unexpected results are described in the '609 specification (the specification asserts only that "the accuracy of the constructed map will be increased"); no long‑felt‑but‑unsolved narrative beyond the admitted general need; any commercial success would need a nexus to the claimed outline/segment construction, not to the unclaimed grid‑retrieval feature. Note also that the family's earlier issued members (US 11,170,230; US 11,721,112) claim the same priority and would raise obviousness‑type double‑patenting issues if separately challenged.

6. Confidence and evidentiary caveats

  • Verified by retrieved full text: US20130328924A1, US20140095062A1, US20200020104A1/US11087469B2, US20160358349A1/US10546400B2, US20170294036A1, US9170116B1 (and the closely parallel US9384394B2).
  • Relying on title/date only (not verified in this session): US6118404A, US6622085B1, US7127107B2, US20070226243A1, US20080177254??—not asserted; specifically US20080262721A1, US20100266161A1, US20120155745A1, US20150316386A1, US20180188743A1, US20190026591A1, US20200200547A1, US20200210696A1, US20210049780A1. These are used only as secondary/supporting references; claims 1, 2, 16 and 20 can be reached on the verified set alone.
  • Bibliographic discrepancy noted, not auto‑corrected: the page lists US9170116B1 with prior‑art date 2014‑07‑11 (Toyota Motor Engineering & Manufacturing North America); search results show a same‑title, same‑abstract grant, US 9,384,394 B2 (Fairfield et al.), and US9170116B1 (Joshi/James, App. 14/329,363) with an earlier 2013‑10‑30 priority date. Both pre‑date 2019‑02‑26; confirm which is in the record before filing.
  • Litigation context (from the page): "US case filed in Texas Southern District Court," https://portal.unifiedpatents.com/litigation/Texas%20Southern%20District%20Court/case/4%3A25-cv-03371; anticipated expiration 2039‑02‑26. This is a validity challenge environment, so all grounds above should be charted limitation‑by‑limitation against the actual claim language before being asserted.

Bottom line: Claims 1, 9 and 14 are prima facie obvious over Apple US20130328924A1 in view of HP US20140095062A1, optionally with HERE US20200020104A1 (and, for the lane‑level framing, Toyota US9170116B1/US9384394B2). Claims 2, 16, 20 fall with HERE US20160358349A1/US10546400B2 (bidirectional road geometry), HERE US20200020104A1 (segment merging into polylines), and Apple US20130328924A1 (road graph) respectively; claims 3–8, 15 and 17–19 are supported by the angle‑based filtering of HP '062 and Apple '924 plus the polygon/parcel partition art of US6622085B1 and US7127107B2.

Generated 9/29/2026, 4:31:49 AM

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