PTAB

IPR2014-01283

Global Tel Link Corp v. Securus Technologies Inc

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1. Case Identification

2. Patent Overview

  • Title: Method for Monitoring Detainee Activity
  • Brief Description: The ’457 patent discloses a method for investigating gang affiliations by identifying a known gang-affiliated detainee, searching databases for associated information such as call records, visitor logs, and financial data, and correlating the information to identify other potential gang affiliates. The method also includes creating alerts for investigators based on specified events, such as the use of certain words during a telephone call.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 and 14-17 are obvious over Crites in view of Krebs and Hodge.

  • Prior Art Relied Upon: Crites (Patent 7,085,359), Krebs (a 2002 publication titled "Mapping Networks of Terrorist Cells"), and Hodge (Application # 2004/0029564).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Crites, taught the core of the claimed invention: monitoring inmate telephone call activities to identify security threat group members. Crites disclosed identifying a known member, searching call detail record (CDR) databases for associated calls, and correlating the information. Petitioner contended that Krebs, which taught mapping terrorist networks, supplied the motivation to expand Crites's telephone-centric analysis to other data types mentioned in the ’457 patent, such as in-person meetings (visitation records) and financial transactions. Finally, Hodge disclosed a specific technical implementation for the claimed alerting feature, teaching a centralized inmate call monitoring system that generates an alert when specific keywords are detected during a call.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Crites and Krebs because they address the same problem of identifying covert members of a threat group by analyzing the activities of known members. A POSITA would look to Krebs to supplement Crites’s general disclosure of "correlation" with Krebs's specific methods for analyzing various data types. The POSITA would then incorporate Hodge to implement a practical, multi-facility monitoring and alerting system, a feature detailed in Hodge but not fully enabled by Crites or Krebs.
    • Expectation of Success: The combination involved applying known network analysis techniques (Krebs, Crites) to a known system architecture for monitoring inmates (Hodge), which would have yielded predictable results.

Ground 2: Claims 6-13 are obvious over Crites, Krebs, and Hodge in view of Eisen.

  • Prior Art Relied Upon: Crites (Patent 7,085,359), Krebs ("Mapping Networks of Terrorist Cells"), Hodge (Application # 2004/0029564), and Eisen (Application # 2005/0039036).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 and added Eisen to teach the specific multi-level search limitations of claims 6-13. Petitioner asserted that while Crites suggested a second search based on results from a first search, it did not explicitly teach the "graduated database search" method claimed. Eisen explicitly disclosed this method for fraud detection: performing a first-level search of databases for records sharing a "key value" with an initial record, and then using the key values from those first-level results to perform a second-level search, thereby building a "tree" of connections. This directly mapped to the claims’ requirements for searching a first plurality of databases to identify a first level of information and then using that first level of information to search a second plurality of databases for a second level of information.
    • Motivation to Combine: A POSITA, seeking to implement the general investigative concept from Crites of using initial search results to conduct further searches, would have been motivated to consult the prior art for specific, effective methods of relationship analysis. This search would have led to Eisen’s well-defined graduated search methodology, which was designed for the analogous purpose of uncovering hidden relationships in large datasets.
    • Expectation of Success: Applying Eisen’s systematic, data-driven search logic to the inmate monitoring context established by Crites, Krebs, and Hodge was a straightforward application of a known data analysis technique to a new dataset, with a high expectation of success.

Ground 3: Claims 1-5, 14, and 15 are obvious over Sparrow in view of Hodge.

  • Prior Art Relied Upon: Sparrow (a 1991 publication titled "The application of network analysis to criminal intelligence") and Hodge (Application # 2004/0029564).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative combination for the base claims. Petitioner argued that Sparrow provided the foundational theory, teaching the application of network and link analysis techniques to criminal intelligence data. Sparrow explicitly suggested analyzing various data types—including contact reports, telephone toll data, and financial transactions—to uncover hidden relationships between individuals. Hodge, as in Ground 1, provided the necessary technical implementation for applying Sparrow’s high-level analytical framework within a correctional facility. Hodge disclosed the centralized system for acquiring, storing, and monitoring inmate data, including the keyword-based alerting functions.
    • Motivation to Combine: A POSITA starting with Sparrow’s academic framework for criminal network analysis would have sought a practical system for data acquisition and management, especially in a controlled environment like a prison. Hodge’s disclosure of a data management and monitoring system for inmates provided a direct and logical platform for implementing the analytical techniques taught by Sparrow.
    • Expectation of Success: Combining Sparrow’s analytical methods with Hodge’s data management system represented the pairing of a known problem-solving strategy with a suitable technical environment, which would have been a predictable and successful endeavor for a POSITA.

4. Key Claim Construction Positions

  • "Database": Petitioner proposed this term be construed to mean "a source of data or information." This construction was argued to be consistent with the ’457 patent’s specification, which suggests that databases could be non-electronic, such as "court paper file systems." Petitioner asserted this broader meaning was necessary to properly apply prior art references that discuss gathering intelligence from various sources, not just structured electronic databases.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of the ’457 patent as unpatentable.