PTAB

IPR2014-00130

FLIR Systems Inc v. E Watch Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multimedia Surveillance And Monitoring System Including Network Configuration
  • Brief Description: The ’183 patent discloses a full-service, multimedia surveillance system built on a digital network architecture. The system combines digital camera capabilities with network components and appliances, such as servers, to transmit event data, video, audio, and other sensor data over various networks like a LAN, wireless LAN, Intranet, or Internet for automatic assessment and response. The system is described as being dispersible geographically and capable of using GPS for dispatching response personnel.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8-12, 18-20, 24, and 25 are unpatentable under pre-AIA 35 U.S.C. § 102(b) as anticipated by Koz.

  • Prior Art Relied Upon: Koz (Patent 5,581,297).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Koz, which discloses a low-power video security monitoring system, teaches every limitation of the challenged claims. Independent claim 1 recites an "IP network compatible" system; Petitioner asserted that Koz's disclosure of transmitting data over an ISDN channel meets this limitation, as ISDN was a known IP-compatible digital network. Koz's "remote video monitoring facility" was argued to be the claimed "network based server" that receives, logs, and manages data. Furthermore, Koz's use of video image processing to detect motion (a "temporal image difference") functions as the claimed "conventional security sensor," and its digital image compression and signal interface subsystems act as the "convertor" that prepares sensor signals for network transmission. Petitioner contended that Koz’s camera control in response to commands from the monitoring facility meets the limitation of a "surveillance sensor appliance controlled by the server." The petition also mapped elements of the dependent claims to specific disclosures in Koz, such as its on-board memory, transmission control, and support for both still and full-motion video.

Ground 2: Claims 1-6, 8-12, 18-20, 24, and 25 are obvious under pre-AIA 35 U.S.C. § 103 over Koz in view of Kavy.

  • Prior Art Relied Upon: Koz (Patent 5,581,297), Kavy (WO 99/39505).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented contingently, in the event the Board found Koz’s system was not "IP network compatible." Petitioner argued that while Koz provides the fundamental surveillance system components (sensors, cameras, data logging, etc.), Kavy explicitly supplies the missing network-centric elements. Kavy discloses a "networked" security system for "network-based" monitoring and control of an environment accessible via the Internet. It teaches a server computer coupled to a wide-area network (e.g., the Internet) that communicates with remote site control units, which digitize video, audio, and sensor data into packets for network transfer. This combination, Petitioner argued, results in the precise system claimed in the ’183 patent.
    • Motivation to Combine: A POSITA would combine Koz’s surveillance technology with Kavy’s network architecture for several reasons. Kavy explicitly criticizes conventional systems (like those using point-to-point telephone lines or hard-wired connections) for suffering from bandwidth limitations, high costs, and a lack of flexibility. Kavy expressly provides the motivation to use an internet-based system to overcome these deficiencies. A POSITA would have been motivated to apply Kavy's superior networking approach to a system like Koz's to achieve a more robust, flexible, and capable surveillance system. Petitioner further argued it was commonplace and obvious to adapt older electronic processes to use modern internet technology.
    • Expectation of Success: Petitioner asserted that a POSITA would have a reasonable expectation of success in making this combination. The integration involved applying a known networking method (Internet-based communication as taught by Kavy) to a known type of system (video surveillance as taught by Koz) to achieve the predictable result of a more flexible and powerful networked surveillance system.

4. Key Claim Construction Positions

  • "IP network compatible": Petitioner argued this term, found in the preambles of the independent claims, should be construed broadly and is not limited to systems that operate exclusively using IP protocol. Petitioner submitted that the term encompasses security systems that are "compatible" with IP networks, such as a system using an all-digital ISDN service as a transport mechanism. This construction was central to Petitioner’s anticipation argument, as the primary prior art reference (Koz) discloses using an ISDN network.
  • Adoption of Prior Constructions: To minimize inconsistent results with a concurrent inter partes review proceeding involving the same patent (IPR2013-00255), Petitioner adopted the claim constructions being applied by the Board in that case for other key terms like "Surveillance Sensor Appliance."

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-6, 8-12, 18-20, 24, and 25 of Patent 6,970,183 as unpatentable.