PTAB

IPR2013-00386

Sony Corp Of America v. Network 1 Security Solutions Inc

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1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Remotely Powering Access Equipment Over a 10/100 Switched Ethernet Network
  • Brief Description: The ’930 patent describes a method for safely providing remote power to access devices over an Ethernet network. The system first determines if a connected device is capable of accepting remote power by delivering a low-level current and sensing the resulting voltage, and only provides full operational power if a preselected condition is met.

3. Grounds for Unpatentability

Ground 1: Obviousness over Woodmas and Smith/Television Production - Claims 6, 8, and 9 are obvious over Woodmas in view of Smith and/or Television Production under 35 U.S.C. §103.

  • Prior Art Relied Upon: Woodmas (Patent 5,345,592), Smith (Patent 5,982,456), and Television Production (a 1993 publication by Ron Whittaker).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Woodmas taught the core method of the challenged claims, including remotely powering access equipment (camera stations) by first delivering a low-level current (15 mA), sensing a "power status signal" returned from the device in response, and controlling the subsequent delivery of full power based on that signal. However, Woodmas's control station was not explicitly a network data switch. Smith and Television Production, both in the same field of video production, disclosed computer-based production switchers that function as multi-input data switches with LAN/WAN connectivity. Petitioner contended that combining these teachings would result in a "data node adapted for data switching," as required by claim 6.
    • Motivation to Combine: A POSITA would combine Woodmas's remote powering system with the networked, multi-channel switching functionality of Smith or Television Production to achieve the predictable result of a single unit capable of both remote powering and advanced data switching over a network. This combination would allow a wider variety of signal types to be switched on a platform capable of network communication.
    • Expectation of Success: Petitioner asserted success would be expected, as the combination involved integrating familiar elements (production switchers and power supplies) using known principles to yield a predictable outcome.

Ground 2: Obviousness over Lehr and Woodmas - Claims 6, 8, and 9 are obvious over Lehr in view of Woodmas under §103.

  • Prior Art Relied Upon: Lehr (Patent 6,473,608) and Woodmas (Patent 5,345,592).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Lehr disclosed a method for powering access devices (e.g., IP telephones) over a LAN, which included a data node (LAN switch), access devices, and a power supply. Lehr taught interrogating an access device to determine if it could receive power by measuring voltage on the communications cabling. While Lehr taught the broad concept of checking a device before powering, Petitioner contended it did not explicitly disclose using a low-level current for this check. Woodmas was argued to supply this missing element with its disclosure of using a 15 mA current to test a device before applying full power.
    • Motivation to Combine: A POSITA would combine Woodmas's low-level current detection technique with Lehr's remote powering system to improve power management and protect connected devices that cannot accept remote power. This would be a logical and desirable enhancement to Lehr’s system.
    • Expectation of Success: Petitioner asserted that incorporating the well-known power-management technique from Woodmas into the LAN power system of Lehr would be a straightforward application of known principles to achieve a predictable improvement.

Ground 3: Anticipation by Matsuno - Claims 6, 8, and 9 are anticipated by Matsuno under 35 U.S.C. §102(b).

  • Prior Art Relied Upon: Matsuno (Japanese Unexamined Patent Application No. H10-13576).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Matsuno disclosed every element of the challenged claims. Matsuno described a method for powering access equipment (remote subscriber units) in an ISDN network from a data node (switching station). The system delivered a low-level, non-operational voltage (-V2) to the access device over a data signaling pair (subscriber line). When a loss of local power was detected (sensing a DC loop), the system controlled the power supply to provide a higher, operational voltage (-V1) to the device. Petitioner mapped Matsuno's disclosure to all limitations of independent claim 6, dependent claim 8 (polling to confirm remote power capability), and dependent claim 9 (decreasing power upon device removal).

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 6, 8, and 9 over Lamb (Patent 6,449,348) in view of Matsuno.

4. Key Claim Construction Positions

Petitioner requested that the Board adopt several constructions from related proceedings (IPR2013-00071 and IPR2013-00092) and proposed the following key constructions for terms in claim 6:

  • "Low level current": A current (e.g., approximately 20 mA) that is sufficiently low that it will not, by itself, operate the access device. This construction was central to mapping the detection steps in the prior art.
  • "Data node adapted for data switching": A data switch or hub configured to communicate data using temporary, rather than permanent, connections. This construction was important for establishing that prior art production switchers and LAN hubs met the claim limitation.
  • "Main power source" and "secondary power source": Argued that these do not need to be physically separate devices, allowing a single power supply that provides different power levels to satisfy both limitations.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 6, 8, and 9 of Patent 6,218,930 as unpatentable.