PTAB

IPR2013-00334

Mobotix Corp v. E Watch Nevada Inc

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1. Case Identification

2. Patent Overview

  • Title: Digital Security Multimedia Sensor
  • Brief Description: The ’371 patent describes a digital security camera system designed for surveillance. The core technology involves an apparatus that, upon a triggering event, transmits two distinct types of compressed image data over an internet protocol network to a monitoring station: a retrieved, higher-resolution selection of stored image data, and a separate, lower-resolution stream of "other" image data (e.g., live video) that is not retrieved from storage.

3. Grounds for Unpatentability

Ground 1: Claims 1-10 are obvious over Ely in view of Seeley.

  • Prior Art Relied Upon: Ely (WO 97/40624) and Seeley (Patent 6,069,655).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ely disclosed a general video surveillance system with networked cameras capable of transmitting both live and stored (buffered) video data to a central station upon an alarm. However, Ely did not explicitly teach using different resolutions for these two data types. Seeley, an advanced video security system patent, was argued to supply this missing element by expressly disclosing the transmission of both high-resolution "snapshots" retrieved from storage and lower-resolution "live" motion video upon detection of an intruder. The combination of Ely's base system and Seeley's specific dual-resolution transmission scheme allegedly rendered all limitations of the challenged claims obvious.
    • Motivation to Combine: A POSITA would combine the teachings of Ely and Seeley to improve the performance of a networked surveillance system. Incorporating Seeley’s method of using a lower resolution for live video while reserving high resolution for critical stored snapshots was a known technique to manage network bandwidth efficiently. Petitioner contended this combination would yield the predictable result of an optimized surveillance system.
    • Expectation of Success: The combination involved applying a known data management technique (dual resolutions) from Seeley to a standard networked camera system (Ely), which would have provided a POSITA with a high expectation of success.

Ground 2: Claims 1-10 are obvious over Ely and Seeley in view of Fernandez.

  • Prior Art Relied Upon: Ely (WO 97/40624), Seeley (Patent 6,069,655), and Fernandez (Patent 6,697,103).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Ely and Seeley combination by adding Fernandez to explicitly teach the use of an "internet protocol network" as required by the claims. While Ely disclosed a local area network (LAN) and Seeley disclosed communication over Ethernet and ISDN, Fernandez was cited for its express disclosure of a surveillance system using the TCP/IP protocol over the internet. Petitioner asserted that Fernandez provided the explicit motivation to use a standard internet protocol for the network in the combined Ely/Seeley system.
    • Motivation to Combine: A POSITA would combine Fernandez with the Ely/Seeley system for the predictable benefits of standardization and interoperability. Using the conventional TCP/IP protocol as taught by Fernandez to implement the network in the Ely/Seeley system was presented as an obvious design choice to allow communication over conventional networks like the internet, rather than being limited to proprietary or mixed-network configurations.
    • Expectation of Success: Implementing a standard, well-understood protocol like TCP/IP on a networked surveillance system was a routine task for a POSITA, leading to a high expectation of success.

Ground 3: Claims 1-10 are obvious over Bonshihara in view of Seeley.

  • Prior Art Relied Upon: Bonshihara (Japanese Patent Publication No. 11-284987) and Seeley (Patent 6,069,655).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented Bonshihara as an alternative primary reference. Petitioner argued Bonshihara disclosed a surveillance system that used a TCP/IP network to transmit both stored image data (retrieved from a hard disk upon request) and real-time image data upon a triggering event. Bonshihara thus taught the core functionality of a dual-mode, IP-based system. However, Bonshihara did not explicitly disclose that the real-time images had a lower resolution than the stored images. Seeley was added to this combination for its express teaching of using a lower resolution for the live video stream compared to the high-resolution stored snapshots to conserve bandwidth.
    • Motivation to Combine: A POSITA would be motivated to apply Seeley's bandwidth-management technique to the TCP/IP-based system of Bonshihara. Since both references concerned networked surveillance, modifying Bonshihara's system to use different resolutions for its two data streams as taught by Seeley was argued to be an obvious optimization to improve network performance, yielding predictable results.
    • Expectation of Success: The combination represented the application of a known principle (varying resolution to manage bandwidth) to a known system type, and a POSITA would have reasonably expected the combination to function as intended.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Seeley alone, Ely alone, Ely in view of Fernandez, and Bonshihara alone, but relied on similar technical principles and design modification theories.

7. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-10 of the ’371 patent as unpatentable.