Samsung Electronics America Inc v. Pragmatus Mobile LLC

1. Case Identification

• Case #: IPR2014-00582
• Patent #: 8,149,124
• Filed: April 4, 2014
• Petitioner(s): Samsung Electronics America, Inc., Samsung Telecommunications America, LLC, and Samsung Electronics Co., Ltd.
• Patent Owner(s): Pragmatus Mobile, LLC
• Challenged Claims: 1-21

2. Patent Overview

• Title: PERSONAL SECURITY AND TRACKING SYSTEM
• Brief Description: The ’124 patent describes a method and system for tracking a portable signaling unit. The system involves a portable unit with a GPS receiver that transmits its location data over a wireless link to a computer at a central dispatch station, which then displays the unit's location as a symbol on a map for an operator.

3. Grounds for Unpatentability

Ground 1: Claims 1-21 are anticipated by Mansell under 35 U.S.C. § 102(b).

• Prior Art Relied Upon: Mansell (Patent 5,223,844).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Mansell, which was not considered during prosecution, discloses every limitation of the challenged claims. Independent claim 1 recites a method for tracking a portable unit comprising: receiving a GPS signal at the unit, using the signal to determine a position, transmitting position data to a computer, and displaying on a remote networked display a map with a symbol identifying the unit's location. Petitioner asserted that Mansell’s “Mobile Units” are portable signaling units that receive GPS signals to determine position and transmit this data via a cellular link to a “Control Center” computer. Crucially, Petitioner argued that the final “displaying” limitation, which was the feature that overcame rejections during prosecution, is explicitly taught by Mansell. Mansell’s control center includes a display controller and mapping displays that show a map with a symbol identifying the mobile unit's location. Petitioner contended that Mansell's display is "remote" from its communications controller (computer) and connected by a local area network (LAN), directly mapping to the claim language. Petitioner provided a detailed element-by-element mapping for all dependent claims, arguing that Mansell’s system also discloses features like running a digital map program (claim 2), voice communication (claim 8), and the various hardware components of the portable unit (claims 12-21).

Ground 2: Claims 1-21 are anticipated by Simms under 35 U.S.C. § 102(e).

• Prior Art Relied Upon: Simms (Patent 5,808,564).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Simms independently anticipates all challenged claims by disclosing a functionally identical system. Simms describes a "mobile security assembly" that uses a GPS position locator to determine its coordinates and communicates this data via a cellular link to a "central dispatch station." At the station, a communications console (the computer) receives and processes the data, which is then shown on one or more display consoles. Petitioner asserted that Simms expressly discloses the key "displaying" limitation, stating that an "alarm symbol corresponding to the type of emergency assistance required is superimposed on the map at the position of the mobile entity." Petitioner further argued that Simms teaches the display consoles are "remote" from and "networked to" the communications console, satisfying the final limitations of claim 1. As with Mansell, Petitioner asserted that Simms also teaches the limitations of the dependent claims, including running a conventional digital map program on the display consoles (claim 2), using a voice mode for communication (claim 8), and incorporating hardware such as a cellular telephone, multiple receivers, and a microcontroller (claims 10-21).

4. Key Claim Construction Positions

Petitioner argued for constructions of several terms under the broadest reasonable interpretation standard to support its anticipation arguments.

• "symbol identifying the location of the portable signaling unit": Petitioner proposed this term should be interpreted broadly to include any display indicator positioned on a map corresponding to the unit's location. This broad construction allowed mapping to the icons and symbols shown in both Mansell and Simms.
• "remote": Petitioner argued this term should be construed as simply "separate by a distance," without requiring a significant separation. This interpretation was based on the ’124 patent's own disclosure and was critical for showing that the networked but co-located displays and computers in the prior art meet the limitation.
• "central dispatch station": Petitioner proposed this phrase covers any station to which information is transmitted and made available to a dispatch operator. This construction encompasses the "Control Center" in Mansell and the "central station" in Simms.
• "radio signal": Petitioner argued this should be construed as a signal in the radio frequency spectrum, allowing GPS signals to qualify as a type of "radio signal" as recited in claim 15.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-21 of Patent 8,149,124 as unpatentable.