PTAB

IPR2013-00385

Dell Inc v. Network 1 Security SolutiIONs Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method for Remotely Powering Access Equipment in a Data Network
  • Brief Description: The ’930 patent describes methods and apparatus for remotely delivering power to network access equipment over the same data signaling wires (e.g., Ethernet cables) used for data transmission. The technology involves using a low-level current to detect if a remote device is present and capable of receiving power before supplying full operational power.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 6 and 9 by Matsuno

  • Prior Art Relied Upon: Matsuno (Japanese Publication No. H10-13576)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Matsuno, which discloses an Integrated Services Digital Network (ISDN) switching station, teaches every element of the challenged claims. Matsuno describes a system that provides power and data over the same wires to remote devices. The system delivers a low-level voltage (-V2) from a main power source over a data signaling pair, senses a resulting voltage change to detect a local power failure at the access device, and in response, controls a secondary power source to supply a higher operational voltage (-V1). For claim 9, Petitioner asserted that if the access device in Matsuno were removed, the voltage would drop to zero, which would be sensed, leading to a decrease in supplied power, thus meeting the claim’s limitations.
    • Key Aspects: Petitioner contended that although Matsuno describes an ISDN network, it qualifies as a "data network" as claimed, since ISDN was a well-known standard for transmitting digital data and voice.

Ground 2: Obviousness of Claims 6 and 9 over De Nicolo in view of Matsuno

  • Prior Art Relied Upon: De Nicolo (Patent 6,115,468), Matsuno (Japanese Publication No. H10-13576)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that De Nicolo discloses the foundational system for remotely powering Ethernet devices. It teaches providing a data node (multi-port hub), access devices (Ethernet telephones), and a secondary power supply that delivers power over data signaling pairs using center-tapped transformers. However, De Nicolo does not explicitly teach the claimed power control method. Matsuno was argued to supply these missing elements by teaching a method of delivering a low-level current, sensing a resulting voltage to detect a condition (local power failure), and controlling the power supply in response.
    • Motivation to Combine: A POSITA would combine the power control features of Matsuno with the Ethernet powering system of De Nicolo to solve the known problem of managing power delivery to remote devices. Petitioner argued the combination would improve safety and power efficiency by applying Matsuno’s well-known power management techniques to De Nicolo’s specific Ethernet environment. The ’930 patent itself noted the desire to add remotely powered devices to data networks due to the convergence of voice and data, providing a direct motivation.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in applying Matsuno's established power control logic to De Nicolo's Ethernet system, as it involved implementing known techniques in a predictable manner to achieve a known goal.

Ground 3: Obviousness of Claims 6 and 9 over Chang in view of De Nicolo

  • Prior Art Relied Upon: Chang (Patent 5,991,885), De Nicolo (Patent 6,115,468)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chang discloses a network system for controlling the application of power to a detected device. Chang teaches sending a low-voltage "presence request signal" (a low-level current) to an access device, using a voltage comparator to sense the response, and controlling an electrical power supply circuit to deliver operational power if the device is present. Chang also teaches monitoring for the removal of the device to cease power delivery, meeting the limitations of claim 9. De Nicolo was cited to provide the specific context of an Ethernet power transmission system using phantom power, which complements Chang's more general power control method.
    • Motivation to Combine: A POSITA would have been motivated to combine the teachings because both patents address the same technical problem of powering remote devices in a network environment. The combination would involve the routine substitution of one known networking protocol (as in De Nicolo) into the power control framework of another (Chang), particularly since Chang itself discloses Ethernet adapters.
    • Expectation of Success: The combination was presented as a predictable integration of complementary technologies, where Chang provides the "how" (power control logic) and De Nicolo provides the "where" (an Ethernet environment), leading to a high expectation of success.

4. Key Claim Construction Positions

  • "Main power source" and "Secondary power source": For the purposes of the IPR, Petitioner adopted the Patent Owner's broad construction from district court litigation. This construction allows the "secondary power source" to be the same as, derived from, or physically separate from the "main power source." This broad interpretation was crucial to arguing that the prior art references, which may not explicitly distinguish between two separate power supplies, met these limitations.
  • "Low level current": Petitioner noted that in a related IPR (IPR2013-00071), the Board construed this term as "a current... sufficiently low that, by itself, it will not operate the access device." Petitioner proceeded with its arguments under this construction, asserting that the detection currents in the prior art references met this functional definition.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 6 and 9 of the ’930 patent as unpatentable.