Quanergy Systems, Inc. v. Velodyne Lidar USA, Inc.
24f4th1406
| Fed. Cir. | 2022Background:
- The ’558 patent claims a rotating lidar-based 3‑D point‑cloud system (preferred: 64 laser/detector pairs, ~360° horizontal × ~26.8° vertical FOV, rotation ≥200 RPM, ~1 million time‑of‑flight points/sec).
- Quanergy filed two IPR petitions challenging multiple claims of the ’558 patent as obvious (primarily over Mizuno). The PTAB instituted review and found the challenged claims not unpatentable.
- The Board construed "lidar" in the patent to mean pulsed time‑of‑flight (ToF) lidar, reasoning the specification focuses exclusively on measuring distance from pulse time‑of‑flight.
- The Board found Mizuno describes a triangulation/specular‑reflection short‑range system, not a pulsed ToF lidar, and concluded a skilled artisan would not have been motivated to or had a reasonable expectation of success in modifying Mizuno to use pulsed ToF (Berkovic supported short‑range ToF limitations).
- The Board credited Velodyne’s objective indicia (long‑felt need, praise, commercial success), presumed a nexus to the claimed invention based on Velodyne’s mapping, and found that evidence outweighed any showing of obviousness.
- The Federal Circuit affirmed the Board’s claim construction, factual findings, and ultimate nonobviousness determinations.
Issues:
| Issue | Plaintiff's Argument (Quanergy) | Defendant's Argument (Velodyne / Board) | Held |
|---|---|---|---|
| Claim construction of “lidar” | "Lidar" is broad and includes triangulation and other techniques | Specification focuses on pulsed time‑of‑flight; experts agree ToF meaning | "Lidar" construed as pulsed time‑of‑flight lidar (affirmed) |
| Whether Mizuno discloses/suggests pulsed ToF lidar or motivates using it | Mizuno teaches reflected‑light distance measurement and thus renders claims obvious | Mizuno is triangulation/specular‑reflection, not ToF; experts support this; Berkovic shows ToF poor at short range | Substantial evidence supports Board that Mizuno does not disclose/suggest pulsed ToF and skilled artisan would lack reasonable expectation of success |
| Objective indicia nexus (long‑felt need, praise, commercial success) | Velodyne’s commercial praise/success are tied to unclaimed features; nexus not presumed | Velodyne’s products embody claimed features; expert mapped claim elements to products; nexus proper and rebuttal was undeveloped | Board properly presumed nexus; Velodyne showed nexus and persuasive objective indicia; Quanergy’s new/further arguments forfeited |
| Weight of objective indicia vs. obviousness | Quanergy contends objective evidence insufficient to overcome prima facie case | Board found Velodyne’s objective evidence persuasive and coextensive with claims | Board reasonably weighed and credited objective evidence; nonobviousness affirmed |
Key Cases Cited
- Graham v. John Deere Co., 383 U.S. 1 (1966) (establishes obviousness framework and Graham factors)
- Trivascular, Inc. v. Samuels, 812 F.3d 1056 (Fed. Cir. 2016) (broadest reasonable interpretation standard in IPRs)
- Veritas Technologies LLC v. Veeam Software Corp., 835 F.3d 1406 (Fed. Cir. 2016) (specification does not always limit a term to a preferred embodiment)
- Eli Lilly & Co. v. Teva Pharms. Int’l GmbH, 8 F.4th 1331 (Fed. Cir. 2021) (application of claim‑construction standard in post‑petition IPRs)
- Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366 (Fed. Cir. 2019) (standards for presuming nexus between product and claimed invention)
- WBIP, LLC v. Kohler Co., 829 F.3d 1317 (Fed. Cir. 2016) (rebuttal of nexus requires evidentiary showing, not argument)