PTAB

IPR2014-00030

Apple Inc v. NetAirus Technologies LLC

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and apparatus for data communication in a wireless network
  • Brief Description: The ’380 patent describes a system for conserving power in a wireless client device. The system involves a server that sends a "wakeup message" via a separate communication device to the client device, prompting it to exit a low-power state to receive a pending data object, thereby avoiding the need for constant polling by the client.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kojima and Agrawal - Claims 3, 7, and 9-12 are obvious over Kojima in view of Agrawal.

  • Prior Art Relied Upon: Kojima (Patent 6,330,457), Agrawal (Patent 6,697,639).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kojima disclosed the fundamental architecture of the challenged claims, including a communication system with a server, a terminal device (client device), and a base station (communication device). Kojima’s system allowed the server to transmit data to the terminal, which periodically polled for messages. Petitioner contended that Kojima taught all limitations of independent claim 3 except for the specific "wakeup message" that precedes the data object transmission to rouse the client from a low-power state. Agrawal was asserted to remedy this deficiency. Agrawal described a power-saving method for wireless devices where a base station sends a specific "wake-up signal" to a mobile station in a "doze" mode before transmitting data, explicitly teaching the missing element. Petitioner mapped limitations of dependent claims 7 and 9-12 to inherent features of Kojima's mobile communication system and disclosures in Agrawal regarding different data types.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine the teachings of Kojima and Agrawal to improve the power efficiency of Kojima’s system. Reducing power consumption was a widely recognized goal in wireless device design. A POSITA would have found it obvious to incorporate Agrawal’s explicit "wake-up signal" technique into Kojima's framework to reduce the client device's power-intensive polling cycles, thus extending battery life.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination. Integrating a wakeup signal into a wireless communication protocol was a well-understood and predictable engineering task involving known principles of power management and wireless networking.

Ground 2: Obviousness over Kojima, Agrawal, and Shim - Claims 3, 7, and 9-12 are obvious over Kojima in view of Agrawal and further in view of Shim.

  • Prior Art Relied Upon: Kojima (Patent 6,330,457), Agrawal (Patent 6,697,639), and Shim (Patent 6,970,727).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the arguments from Ground 1, asserting that the combination of Kojima and Agrawal taught most elements of the challenged claims. Petitioner introduced Shim to provide additional detail and support for specific limitations, particularly those in the dependent claims related to managing different types of data objects (e.g., audio, text). Shim disclosed a method for a mobile communication terminal to receive broadcast data, including distinguishing between different service types. Petitioner argued that Shim explicitly taught managing various data formats as recited in the dependent claims.
    • Motivation to Combine: The primary motivation was to enhance the functionality of the system proposed by combining Kojima and Agrawal. A POSITA building a power-efficient wireless data system would naturally seek to ensure it could handle diverse data types, a fundamental requirement for mobile devices. Shim provided a known method for implementing this data differentiation, making its integration a logical next step to improve the system's utility and versatility.
    • Expectation of Success: As with the primary combination, integrating Shim's teachings on data type management into the Kojima/Agrawal framework would be a straightforward application of known software and networking principles with a high probability of success.

4. Key Claim Construction Positions

  • "communication device": Petitioner argued this term should be construed according to its plain and ordinary meaning as a device capable of wireless communication, which could be a standalone entity like a base station or an access point. This construction was important to show that the prior art base stations (e.g., in Kojima and Agrawal) met the claim limitation. Petitioner contended that the Patent Owner’s potential narrower construction, requiring a unique or proprietary device separate from standard network infrastructure, was not supported by the specification.
  • "wakeup message": Petitioner proposed this term be construed as any signal or message sent to a client device with the purpose of causing it to transition from a lower-power state to a higher-power state to receive data. This broad construction was intended to encompass the "wake-up signals" and similar notifications disclosed in prior art like Agrawal, preventing the Patent Owner from arguing that the prior art signals were technically distinct from the claimed "message."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial based on the co-pending district court litigation (Case No. 2:10-cv-03257, C.D. Cal.). It was asserted that the IPR proceeding provided a more efficient and expert forum for resolving the technically complex validity questions based on patents and printed publications. Petitioner contended that the IPR would simplify issues for trial, conserve judicial and party resources, and that the specific prior art combinations presented in the petition were substantially different and more focused than the broader invalidity contentions possible in district court.

6. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 3, 7, and 9-12 of Patent 7,103,380 as unpatentable.