PTAB

IPR2013-00482

ABB Technology Ltd v. Ipco LLC

Key Events

Petition

petition

Title: Wireless Network System and Method for Providing Same
Brief Description: The ’062 patent is directed to a wireless network system featuring multiple clients and at least one server. The patent describes a multi-hop packet radio network where the server functions as a gateway to an external network (e.g., the Internet) and maintains a routing tree to optimize communication paths with clients based on metrics such as the number of hops.

Prior Art Relied Upon: Goldstein (a 1992 routing protocol document titled "The Radio Shortest Path First (RSPF) Routing Protocol for Internet Protocol over Amateur Packet Radio").
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued Goldstein discloses every element of the challenged claims, particularly independent claims 2 and 6. Goldstein's description of a packet radio network implementing the Radio Shortest Path First (RSPF) protocol was alleged to teach a system with servers (nodes configured to serve a group of nodes) and clients (other nodes in the network). Petitioner contended that Goldstein's use of Dijkstra's Shortest Path First (SPF) algorithm to generate an optimized spanning tree rooted at each "home node" directly taught the claimed "client link tree" and the process for maintaining it, including calculating least-cost paths and updating them based on new link information.

Prior Art Relied Upon: Kahn (an 1978 IEEE paper titled "Advances in Packet Radio Technology") and Schwartz (a 1987 book chapter from "Telecommunication Networks").
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Kahn teaches a foundational multi-hop packet radio network (PRNET) with centralized "stations" (servers) and other packet radios (clients), fulfilling most limitations of the independent claims. The combination with Schwartz was argued to render obvious the claim limitation requiring logic to maintain a "client link tree." Schwartz described a generalized routing "Algorithm A" where a centralized node computes and maintains a shortest-path tree for every node by using global topological knowledge, which Petitioner equated to the claimed link tree.
- Motivation to Combine: A POSITA would combine the references because both address the core problem of routing in networks. Petitioner argued that a POSITA seeking to implement a robust routing algorithm for Kahn's PRNET would naturally look to well-known, generalized algorithms like the one described in Schwartz.
- Expectation of Success: Success would be expected because adapting known routing protocols to packet radio networks was a routine and well-understood task for a person of ordinary skill at the time.

Prior Art Relied Upon: Kahn (an 1978 IEEE paper) and Brownrigg (a 1987 book titled "Packet Radio Networks").
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that the base network of Kahn is rendered obvious by adding the authentication features taught by Brownrigg to meet the limitations of claims 4, 8, 12, and 16. These claims add requirements for client authentication. Brownrigg was cited for its explicit teachings on authentication techniques in packet radio networks, including node-to-node and end-to-end authentication, to secure the network and limit the effects of attacks.
- Motivation to Combine: A POSITA would be motivated to combine the references because Kahn itself suggested the desirability of using "protected" packet radios without detailing the implementation. Brownrigg provided the specific, well-known solution for protecting such radios. A POSITA would therefore incorporate Brownrigg's authentication methods into Kahn's network as a criterion for adding or removing nodes from the network's routing tables.
Additional Grounds: Petitioner asserted additional anticipation challenges based on Kahn, and numerous other obviousness challenges based on combinations of Kahn, Jubin, Goldstein, Schwartz, and Brownrigg. These grounds relied on similar mapping arguments and motivations to combine known routing and security features to arrive at the claimed invention.

"housekeeping functions" (claims 6, 10, 14): Petitioner argued that based on the specification, this term's broadest reasonable interpretation (BRI) includes removing nodes from a data structure (like a routing table or client link tree) that have not communicated for a predetermined time.
"link" (claims 2, 3, 6, 7, 10, 11, 14, 15): Citing the specification and prosecution history, Petitioner asserted the BRI of "link" covers both the direct connection to an adjacent client and the entire path description from a given client to a server.
"client link tree" (claims 2-4, 6-8, 10-12, 14-16): As this term is not explicitly defined in the patent, Petitioner proposed a construction based on the disclosure of "tree" structures. The proposed BRI is a structure maintained by the server that identifies paths between a plurality of clients and a server, as well as connections between adjacent clients.

Petitioner requests institution of an inter partes review and cancellation of claims 2-4, 6-8, 10-12, and 14-16 of Patent 6,044,062 as unpatentable.