PTAB

IPR2014-00102

Starwood Hotels Resorts Worldwide Inc v. Lone Star WiFi LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Network with Multiple Service Classes
  • Brief Description: The ’348 patent discloses systems and methods for providing differentiated classes of service on a wireless network. The technology uses different user credentials, such as non-public or public encryption keys, to control a user’s level of access to network resources and services.

3. Grounds for Unpatentability

Ground 1: Obviousness over ORINOCO, Liu, and PAWNs - Claims 1-14 are obvious over ORINOCO in view of Liu and further in view of PAWNs under 35 U.S.C. §103.

  • Prior Art Relied Upon: ORINOCO (a November 2002 user’s guide for the ORiNOCO AP-1000 access point), Liu (Patent 7,177,637), and PAWNs (a February 2002 publication on public wireless access networks).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that ORINOCO discloses the core hardware infrastructure of the claimed invention: a wireless access point with dual PC card slots, enabling two separate, individually securable network interfaces operating from the same location. These interfaces form the claimed "first" and "second communication part." Petitioner contended that Liu and PAWNs supply the teachings on service differentiation that ORINOCO lacks. Liu taught a system with a secure "private mode" for authorized users (providing full network access, including files) and a restricted "public mode" for unauthorized users (providing limited services). PAWNs further described various service models for public networks, including free access to local intranet services, paid access for full internet connectivity, and policies for tiered bandwidth allocation.
    • Motivation to Combine: Petitioner asserted a POSITA would combine these references because they addressed complementary aspects of a single problem: providing tiered wireless access. A POSITA would have been motivated to implement the well-understood service differentiation schemes of Liu and PAWNs on the configurable, multi-interface hardware taught by ORINOCO to create a versatile and secure network.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these known elements. Implementing established access control policies (from Liu and PAWNs) on a standard, securable wireless access point (from ORINOCO) involved applying known techniques to achieve a predictable result.

Ground 2: Obviousness over Singla, Liu, and PAWNs - Claims 1-3 and 9-14 are obvious over Singla in view of Liu and further in view of PAWNs.

  • Prior Art Relied Upon: Singla (Patent 7,546,458), Liu (Patent 7,177,637), and PAWNs (a 2002 publication).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground relied on Singla as the primary reference, which taught a single access point managing multiple, distinct Virtual Local Area Networks (VLANs) to provide different tiers of service. Petitioner mapped Singla’s VLANs to the claimed communication parts. For example, a high-security VLAN associated with an internal network (requiring an AES key) was mapped to the "first communication part" providing full access, while a lower-security VLAN associated with an external network (requiring a WEP key or no key) was mapped to the "second" and "third" communication parts providing more limited access. Petitioner argued that Liu and PAWNs provided obvious design choices for implementing specific access restrictions within Singla’s VLAN framework, such as limiting public mode users to certain websites or implementing paid-for service tiers.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to configure the access rights of the different VLANs in Singla according to the specific, well-known service models taught by Liu and PAWNs. Applying policies like bandwidth restrictions or differentiating between free local access and paid full internet access was a matter of design choice for a system administrator building upon Singla’s tiered architecture.

  • Additional Grounds: Petitioner asserted that claims 4, 5, 7, and 8 are obvious over Liu in view of PAWNs and Singla, and that claim 6 is obvious over the same combination further in view of Juitt (Patent 7,042,988). These grounds relied on similar arguments, using Liu as the base system for differentiated access and incorporating teachings from PAWNs and Singla for adding multiple service tiers and from Juitt for specifying access to network files via a gateway server.

4. Key Claim Construction Positions

  • "Key" / "Non-public Key" / "Public Key": Petitioner argued that for the purposes of the IPR, these terms should be construed based on their function in controlling access. A "key" was proposed as "an encryption code or code that allows access." Critically, a "non-public key" was construed to mean a key "that is not available to everyone," and a "public key" was construed to mean a key "that is available to anyone." Petitioner asserted these constructions were appropriately directed to the question of access, as opposed to a user's subjective knowledge, which would render the terms indefinite. This distinction was central to mapping prior art keys to the claimed different levels of access.
  • "Substantially A Same Transmitting Area": Petitioner argued for a broad construction requiring "any amount of overlap," consistent with the Patent Owner's position in concurrent litigation. This construction supported the argument that prior art systems with multiple network interfaces or VLANs operating from a single access point met this limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-14 of the ’348 patent as unpatentable.