PTAB

IPR2014-00588

Samsung Electronics America, Inc. v. Pragmatus Mobile LLC

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1. Case Identification

2. Patent Overview

  • Title: PERSONAL SECURITY AND TRACKING SYSTEM
  • Brief Description: The ’795 patent discloses a signaling system that allows an individual in distress to initiate an alarm and enables personnel to monitor the individual's location. The system comprises a portable signaling unit carried by the individual and a remote alarm switch, which communicate with a central dispatch station.

3. Grounds for Unpatentability

Ground 1: Anticipation and Obviousness over Fast and combinations - Claims 1-22 are anticipated by or obvious over Fast, alone or in view of Lookofsky and Layson.

  • Prior Art Relied Upon: Fast (Patent 5,497,149), Lookofsky (Patent 5,416,731), and Layson (Patent 5,731,757).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fast, which discloses a portable "security beacon" for locating persons or objects, anticipates claims 1-15 and 17-21. Fast's beacon is a portable signaling unit containing a cellular telephone for data transmission, a GPS receiver, a microcontroller, a speaker, a microphone, and a display. Crucially, Petitioner asserted that Fast teaches the key limitation of receiving a multi-digit security code via a user interface (a keypad) to program the beacon, a feature the ’795 patent examiner previously found missing from other prior art. Fast also discloses a second, non-cellular receiver for detecting a signal from a protective transmitter (e.g., for enforcing a restraining order), meeting the limitation for a "third signal" in claim 1.
    • Motivation to Combine (for §103 grounds):
      • For claim 16, which requires two separate user interfaces on a single surface of the device housing, Petitioner contended it would be obvious to combine Fast with Lookofsky. Lookofsky teaches an arm-mounted computer with a numeric keyboard and buttons arranged on the same surface for convenience and to reduce accidental activation. A person of ordinary skill in the art (POSITA), knowing from Fast that the beacon could be a wrist-worn device, would be motivated to consolidate Fast’s keypad and call button onto a single surface as taught by Lookofsky for improved ergonomics and ease of access.
      • For claim 22, which requires two-way voice communication, Petitioner argued for combining Fast with Layson. While Fast discloses a microphone and speaker for one-way voice (e.g., listening in) and transmitting DTMF tones, Layson explicitly teaches a portable tracking device with two-way, interactive voice communication with a dispatch operator. A POSITA would find it obvious to incorporate Layson’s established two-way voice capability into Fast’s system to enhance its functionality, providing a clear benefit for a security/tracking device.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in these combinations because they involve integrating known, compatible technologies to achieve predictable results, such as improving user interface ergonomics and adding standard communication features.

Ground 2: Anticipation and Obviousness over Mansell and Mohan - Claims 1-7, 9-16, and 20-22 are anticipated by Mansell, and claims 8 and 17-19 are obvious over Mansell in view of Mohan.

  • Prior Art Relied Upon: Mansell (Patent 5,223,844) and Mohan (Patent 6,121,922).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mansell, which discloses a vehicle tracking and security system, anticipates the majority of the challenged claims. Mansell’s "Mobile Unit" is a portable signaling unit with a cellular transceiver, microcontroller, GPS receiver, keypad, and display. It performs cellular signaling and, critically, receives a security code via a user interface (a sequence of key entries on a keypad) to authorize operations. It also discloses a local radio transceiver for communicating with a handheld unit, satisfying the "third signal" limitation.
    • Motivation to Combine (for §103 grounds): For claims 8 and 17-19, which recite a "standby mode" to conserve power, Petitioner argued for combining Mansell with Mohan. Mansell discloses turning off components when the vehicle's ignition is off to conserve power but does not detail a specific standby mode. Mohan addresses the same problem of battery drain in electronic tracking systems by teaching a specific "Standby Mode" where the GPS and communications transceiver are disabled until awakened by a remote request or a distress signal. A POSITA would be motivated to incorporate Mohan's explicit standby mode into the Mansell system to provide a more robust and efficient power-saving solution, which is a well-known objective in battery-powered tracking devices.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in combining Mohan’s power management strategy with Mansell’s tracking system, as implementing a standby mode by de-powering specific components is a conventional and predictable technique in electronics design.

4. Key Claim Construction Positions

  • "display a [visual] message" (Claims 1, 20): Petitioner argued this term should be construed broadly to mean displaying any indication that conveys information visually. The ’795 patent specification provides minimal detail, only mentioning an LCD screen for the hearing impaired, supporting a broad construction beyond just text.
  • "user interface" (Claims 1, 7): As the term is not defined in the specification, Petitioner proposed it should be construed broadly as any "structure capable of facilitating user interaction." This construction supports finding the limitation met by keypads in the prior art.
  • "First user interface ... and ... second user interface... separate... on the first surface" (Claim 16): Petitioner contended this phrase should be interpreted to require only two separate structures on a single surface, without further limitations on their relative position. This construction is central to the obviousness argument combining Fast with Lookofsky, which teaches placing a keypad and buttons on the same surface of an arm-worn device for convenience.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-22 of the ’795 patent as unpatentable.