PTAB

IPR2013-00486

CaLLCopy Inc v. Verint Americas

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1. Case Identification

2. Patent Overview

  • Title: RECORDING USING PROXY SERVERS
  • Brief Description: The ’290 patent discloses systems and methods for recording a communication session, such as a Voice over IP (VoIP) call, between a customer and an agent in a customer center communication system. The invention centers on using a proxy server to determine whether a media stream should be recorded and to manage the duplication and transmission of that media stream to a recording system.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fortman in view of Boot - Claims 1-49 are obvious over EP '892 in view of WO '914. Claim 49 is also anticipated by EP '892 alone.

  • Prior Art Relied Upon: Fortman (European Patent Application No. EP1111892, “EP ’892”) and Boot (WO 03/058914, “WO ’914”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that EP ’892 taught the core of the invention: a system for IP network surveillance using a proxy server. In EP ’892, a proxy server communicates with an authentication server to identify users under surveillance. Upon notification, the proxy server instructs a policy server, which in turn directs an edge router to copy the media stream and send it directly to a recording device. Petitioner contended this anticipates all limitations of independent claim 49. For the remaining claims, Petitioner asserted that EP ’892 did not explicitly disclose applying this system in a customer center environment or transmitting the duplicated stream through the proxy server itself. WO ’914 was introduced to supply these elements, as it expressly discloses proxy-based recording in customer centers for industries requiring voice recording (e.g., finance, insurance). WO ’914 also disclosed a VoIP gateway acting as a proxy to interface with and transmit a duplicated media stream to a recording device.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA), tasked with implementing a recording solution for a customer center as described in WO ’914, would have been motivated to use the known and robust IP surveillance architecture taught by EP ’892. Applying a general surveillance technology to a specific, known environment where recording is common would have been a predictable and logical design choice.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the teachings. Both references describe systems operating on standard IP network principles, and integrating the customer-center context of WO ’914 with the proxy-based recording architecture of EP ’892 would have involved applying known engineering principles with predictable results.

Ground 2: Obviousness over Ravishankar in view of Shen - Claims 1-49 are obvious over US '032 in view of EP '862.

  • Prior Art Relied Upon: Ravishankar (Application # 2003/0190032, “US ’032”) and Shen (European Patent Application No. EP1389862, “EP ’862”).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that this combination also taught all elements of the challenged claims. US ’032 disclosed a system for lawful interception where an intelligent signaling router identifies calls to be monitored and instructs a media proxy server to duplicate the media stream and transmit it to a "delivery function" for law enforcement. EP ’862 disclosed a similar lawful interception device comprising two key components: a Session Initiation Protocol (SIP) "interception proxy" that determines which calls to intercept, and a Real-time Transport Protocol (RTP) "proxy" that receives the media streams, duplicates them, and transmits the duplicated streams to a recorder. Petitioner argued that together, these references disclose a proxy server that determines whether to record a communication and manages the duplication and transmission of the media stream for recording, meeting the limitations of the independent claims.
    • Motivation to Combine: A POSITA would have been motivated to combine the teachings of US ’032 and EP ’862 because both references address the same technical problem of lawful IP communication surveillance using proxy servers. A skilled artisan would have readily combined the complementary features of these systems—such as the call identification method of US ’032 with the distinct interception and RTP proxy functions of EP ’862—to create a comprehensive and effective recording system.
    • Expectation of Success: The combination was argued to be predictable. Since both systems operate within the same technical field of VoIP surveillance and rely on similar proxy-based architectures, integrating their respective features would have been straightforward for a POSITA, with a high likelihood of success.

  • Additional Grounds: Petitioner asserted numerous additional obviousness grounds for the dependent claims. These grounds primarily relied on the core combinations of EP ’892/WO ’914 or US ’032/EP ’862, supplemented with other references to show that the additional limitations were well-known design choices. Key secondary references included Acharya for teaching caching in proxy servers, Park for teaching network link protection and redundant proxies, and WO ’355 for teaching the use of encryption (e.g., HTTPS) in recording systems.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-49 of Patent 7,613,290 as unpatentable under 35 U.S.C. §102 and/or §103.