PTAB

IPR2013-00495

Sony Corp Of America v. Network 1 Security Solutions Inc

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1. Case Identification

2. Patent Overview

  • Title: Method for Remotely Powering Network Access Equipment
  • Brief Description: The ’930 patent relates to a method for remotely powering access equipment (e.g., Ethernet devices) over a data network. The method involves delivering a low-level current to the access device, sensing a resulting voltage level on the data line, and controlling a secondary power source to supply operational power in response to a preselected condition of the sensed voltage.

3. Grounds for Unpatentability

Ground 1: Claims 6 and 9 are anticipated under 35 U.S.C. §102 by Matsuno.

  • Prior Art Relied Upon: Matsuno (JP H10-13576).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Matsuno, which discloses powering remote devices in an Integrated Services Digital Network (ISDN), teaches every element of claims 6 and 9. Matsuno's ISDN switching station functions as the claimed "data node," and its remote network terminal (NT1) and subscriber terminal (DTE) function as the "access device." Matsuno delivers a low-level voltage (-V2, or -48V) to the access device, senses a resulting voltage via a loop detection part, and controls power by switching to a higher voltage (-V1, or -120V) when it detects that local AC power to the access device has been lost. This maps directly to the delivering, sensing, and controlling steps of claim 6. For claim 9, Petitioner asserted that if the access device in Matsuno were removed, the circuit would open, causing the sensed voltage to drop to zero, which would inherently trigger a decrease in supplied power, thus anticipating the claim.
    • Key Aspects: The core of this argument was that the power management techniques claimed in the ’930 patent for an Ethernet context were already fully disclosed and operational within the well-established ISDN data network context described by Matsuno.

Ground 2: Claims 6 and 9 are obvious under 35 U.S.C. §103 over De Nicolo in view of Matsuno.

  • Prior Art Relied Upon: De Nicolo (Patent 6,115,468) and Matsuno (JP H10-13576).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that De Nicolo discloses the foundational system for remotely powering Ethernet devices. It teaches a data node (multiport switch), an access device (Ethernet telephone), a data signaling pair (4-wire Ethernet connection), and main and secondary power sources that supply power over the data lines using center-tapped transformers. While De Nicolo provides the complete hardware environment, it does not explicitly detail a method for intelligently controlling the power based on the needs of the access device. Matsuno supplies these missing control and detection steps. Matsuno teaches the very method of delivering a low-level current, sensing a voltage to detect a condition (e.g., local power failure), and controlling the main power supply in response.
    • Motivation to Combine: A POSITA would combine these references to create a safer and more efficient Power over Ethernet system. De Nicolo provides the Ethernet-specific power delivery architecture, and Matsuno provides a well-known power management strategy to improve it. A POSITA would be motivated to incorporate Matsuno's control logic into De Nicolo’s system to save power (by not supplying full operational power when not needed) and improve safety (by using a low voltage for detection and a high voltage only when required). The ’930 patent itself noted the industry desire to add remote power to data networks, providing a clear motivation to implement such known control techniques.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in applying Matsuno's conventional power management and control techniques to De Nicolo's Ethernet power delivery system, as it involved the application of known principles to achieve a predictable result.

4. Key Claim Construction Positions

  • "main power source" and "secondary power source": Petitioner argued that, for the purposes of the IPR, it adopted the Patent Owner's broad construction from district court litigation. This construction posits that the "secondary power source" can be the same as, derived from, or not physically separate from the "main power source." This interpretation was critical for the invalidity arguments, as it allows a single power supply circuit that provides two different voltage levels (as in Matsuno) to satisfy the claim limitations for both a main and a secondary power source.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 6 and 9 of the ’930 patent as unpatentable.