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 relates to a system and method for remotely powering access equipment over a data network. The core of the alleged invention is a process for first automatically determining if a connected device is capable of receiving remote power by delivering a low-level test current, and only then supplying full operational power in a non-intrusive manner.

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.

  • Prior Art Relied Upon: Woodmas (Patent 5,345,592), Smith (Patent 5,982,456), and Television Production (a 1993 book by Ron Whittaker).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Woodmas discloses the core method of the ’930 patent: remotely powering equipment (camera stations) by first delivering a low-level current (15 mA) to check the device’s status and then controlling the supply of full power based on a returned status signal. Smith and Television Production, which both relate to the same field of video production, teach modern digital production switchers with advanced data switching capabilities, including LAN/WAN connectivity and the ability to handle numerous data inputs (e.g., cameras, network feeds, satellite signals).
    • Motivation to Combine: A POSITA would combine Woodmas’s remote powering method with the advanced networking and multi-channel switching functionalities of Smith or Television Production. The motivation was to create a single, more capable system that integrated the known benefit of remote powering with the necessary evolution toward computer-based, networked production environments, a predictable improvement.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved integrating familiar elements (power supplies and production switchers) from the same field of endeavor to achieve a predictable result.

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

  • Prior Art Relied Upon: Lehr (Patent 6,473,608) and Woodmas (Patent 5,345,592).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Lehr teaches a system for remotely powering access devices (e.g., IP telephones) over a LAN and includes a method for interrogating a device to determine its power capabilities by measuring voltage/current. However, Lehr does not explicitly disclose using a low-level current for this initial detection step. Woodmas was argued to supply this missing element, as it explicitly teaches using a low-level current to check device status before applying full power.
    • Motivation to Combine: A POSITA would combine the teachings because both references address remote powering over data networks. A POSITA would have been motivated to incorporate Woodmas’s specific low-level current detection technique into Lehr’s LAN-based power system to improve power consumption efficiency and, crucially, to protect network devices that cannot accept remote power.
    • Expectation of Success: The combination would have yielded predictable results, as it involved applying a known power control technique (from Woodmas) to a different type of data network (Lehr’s LAN) to achieve the known benefits of safer and more efficient power management.

Ground 3: Anticipation by Matsuno - Claims 6, 8, and 9 are anticipated by Matsuno.

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

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Matsuno discloses every element of the challenged claims. Matsuno describes a power supply system for an ISDN network that provides power over the same wires used for data. It explicitly teaches providing a low, non-operational voltage (-V2) to a remote subscriber unit to detect if its local AC power has failed. This detection occurs by sensing the resulting voltage/current on the line via a "loop detection part." If local power loss is detected, the system controls power by switching to a higher, operational voltage (-V1) to keep the device running. This process directly maps to the ’930 patent’s claimed method of delivering a low-level current, sensing a voltage level in response, and controlling the power supply based on a preselected condition of that voltage.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 6, 8, and 9 based on Lamb (Patent 6,449,348) in view of Matsuno, arguing a POSITA would have applied Matsuno's power control features to Lamb's Ethernet-based system.

4. Key Claim Construction Positions

  • "Low level current": Petitioner proposed this term be construed as "a current (e.g., approximately 20 mA) that is sufficiently low that, by itself, it will not operate the access device." This construction was central to arguing that references like Woodmas and Matsuno, which use non-operational test currents, meet the claim limitation.
  • "Data node adapted for data switching": Petitioner proposed this term means "a data switch or hub configured to communicate data using temporary rather than permanent connections with other devices or to route data between devices." This broad construction allowed Petitioner to argue that devices like the production switchers in Smith and the ISDN switching station in Matsuno satisfied this element.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 6, 8, and 9 of Patent 6,218,930 as unpatentable under 35 U.S.C. §102 and §103.