Parking Technology Holdings LLC v. Park Assist, LLC

Background

Parking Technology Holdings LLC alleged that Park Assist, LLC infringed one or more claims of U.S. Patent No. 7,893,848. The patent concerns using cameras, image processing, and related systems to determine and display the locations of vacant parking spaces.

The order concerned claim construction, the process of determining what disputed patent language means. The disputed terms appeared in Claims 1, 4, and 12:

1. “processing the repeatedly captured sequence of images”; and 2. “processing the repeatedly captured sequence of images ... resulting in segmentation of the respective images into vehicle and non-vehicle objects.”

The court held a claim-construction hearing on June 28, 2021.

The Parties’ Positions

Parking Technology argued that the first term was understandable and did not require construction. It also argued that the second term clearly described processing images to determine whether parking spaces contained vehicles and that no construction was necessary.

Park Assist argued that the first term was indefinite because “sequence” could refer to different ways of arranging images. In the alternative, Park Assist proposed construing the term to mean processing a sequence of images of a parking space together in a single processing event.

Park Assist also argued that the second term was indefinite because the patent did not identify which image-segmentation method or criteria to use. In the alternative, it proposed construing the term to mean separating or dividing images into vehicle and non-vehicle objects without using an earlier clean image with no vehicles.

Court’s Analysis

The court explained that patent terms generally receive their ordinary and customary meaning unless the patent clearly defines a term differently or clearly disclaims part of its ordinary scope. A claim is indefinite only when, read in light of the patent and its prosecution history, it fails to inform skilled readers about the scope of the invention with reasonable certainty.

As to “processing the repeatedly captured sequence of images,” the court found that the patent’s claims made the invention’s scope clear. The invention repeatedly captures images of parking spaces, processes those images, separates vehicle and non-vehicle objects, and identifies features showing whether a vehicle is present. The court concluded that the term was understandable to a person skilled in the field and to a layperson. The fact that the term could cover multiple image-sequencing methods did not make it indefinite.

As to the second term, the court found that the claims and specification clearly described segmenting images into vehicle and non-vehicle objects to determine parking-space occupancy. The patent did not need to identify one particular algorithm or segmentation method. The availability of multiple methods did not create indefiniteness when the objective and scope of the claimed process were clear.

The court also rejected Park Assist’s proposed limitation involving an earlier “clean” image. The patent applicant had stated during prosecution that embodiments did not need or require an earlier clean image. The court found that this language did not clearly and unmistakably exclude using such an image. It also found that the cited prosecution record did not show that the statement was made to distinguish the Japanese patent identified by Park Assist.

Disposition

Judge Gardephe concluded that neither disputed term required construction and declined to construe the terms. The order also directed any party wishing to file a dispositive motion to submit a pre-motion letter by May 10, 2024, with responsive letters due May 17, 2024.