PTAB
IPR2013-00255
Mobotix Corp v. E Watch Corp
Key Events
Petition
Table of Contents
petition Intelligence
1. Case Identification
- Case #: IPR2013-00255
- Patent #: 6,188,429
- Filed: April 12, 2013
- Petitioner(s): March Networks Corporation
- Patent Owner(s): E-Watch, Inc.
- Challenged Claims: 1-3, 5-8, 10, 11, 13-16, 18, 20, 21, 23, 24, 26, 27, and 29-32
2. Patent Overview
- Title: System for Monitoring an Area
- Brief Description: The ’429 patent discloses a surveillance system comprising a remote station and a central station connected via a communication link. The system captures and transmits compressed image data, adjusting transmission based on available bandwidth, and allows an operator at the central station to interactively control the remote camera.
3. Grounds for Unpatentability
Ground 1: Anticipation by Monroe
Claims 1-3, 5-8, 10, 11, 13-16, 18, 20, 21, 23, 24, 26, 27, and 29-32 are anticipated by Monroe under §102(b).
- Prior Art Relied Upon: Monroe (Patent 5,798,798)
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Monroe, a patent issued to the same inventor as the ’429 patent and from a parent application, expressly or inherently disclosed every limitation of the challenged claims. Independent claim 1 requires a remote station with a camera, a central station, and a communication link for an "interactive communication session." Petitioner contended that Monroe’s system for monitoring vehicles disclosed a functionally identical architecture. Monroe’s disclosure of an operator selecting cameras and receiving images in response was argued to meet the "interactive communication session" limitation. For dependent claims, Petitioner mapped Monroe’s teachings of data compression (e.g., JPEG), bandwidth management, and operator control over camera functions (pan, tilt, zoom) to the corresponding claim limitations.
Ground 2: Obviousness over Abe and Hooper
Claims 1-3, 5-8, 10, 11, 13, 15, 16, 18, 20, 21, 23, 26, and 29-32 are obvious over Abe in view of Hooper.
Prior Art Relied Upon: Abe (Patent 5,473,369), Hooper (Patent 5,671,225)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Abe disclosed a base system for remote surveillance with most elements of the independent claims, including remote and central stations, a camera, and transmission of compressed image data. However, Abe’s system operated on a schedule rather than being fully interactive. Hooper was introduced to supply the missing "interactive communication session" and operator-initiated control limitations. Hooper taught a system for transmitting data over a network where the transmission rate is controlled based on network conditions, which Petitioner equated to the bandwidth-adaptive features claimed.
- Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Abe and Hooper to improve Abe's pre-scheduled system. A POSITA would have recognized the benefits of adding Hooper’s interactive control and network-adaptive transmission capabilities to Abe’s surveillance framework to provide more flexible, real-time monitoring and more efficient use of network resources, particularly in variable-bandwidth environments like the internet.
- Expectation of Success: The combination was presented as a predictable integration of known technologies. A POSITA would have reasonably expected success in implementing Hooper’s interactive control logic into Abe’s system, as both operated on fundamental principles of digital data transmission and remote system control.
Additional Grounds: Petitioner asserted that the challenged claims are also obvious over Monroe (’798 patent) as a standalone reference. Further, Petitioner argued that claims 14, 24, and 27 are obvious over the combination of Abe, Hooper, and Riley (Patent 5,870,136), with Riley providing specific teachings on transmitting status information.
4. Key Claim Construction Positions
- "interactive communication session" (claims 1, 11, 21, 29): Petitioner argued this term should be construed according to its plain and ordinary meaning, which requires a back-and-forth exchange between the remote and central stations initiated and controlled by an operator in real-time. This construction was central to Petitioner's argument that scheduled or automated systems like Abe’s did not meet the limitation, thus necessitating the combination with a reference like Hooper that explicitly taught such real-time, operator-driven interaction.
- "bandwidth of the communication link" (claims 1, 21): Petitioner contended this term refers to the data-carrying capacity of the link available at a given time. This interpretation supported the argument that prior art teaching adjustment of data transmission rates in response to network congestion or availability, such as in Hooper, directly corresponded to this claimed feature.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-8, 10, 11, 13-16, 18, 20, 21, 23, 24, 26, 27, and 29-32 of the ’429 patent as unpatentable.
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