PTAB

IPR2014-01559

General Electric Co v. TransData Inc

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Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Antenna for Use with an Electric Meter
  • Brief Description: The ’294 patent describes an electric meter for automatic meter reading (AMR) that includes an antenna and an associated balance circuit located entirely within the meter's dielectric housing. The invention focuses on integrating a balanced antenna, such as a dipole antenna, inside the meter to protect it from weather and vandalism.

3. Grounds for Unpatentability

Ground 1: Obviousness over Meek and Shields - Claims 1, 7-9, 15-17, and 22-27 are obvious over Meek in view of Shields.

  • Prior Art Relied Upon: Meek (a 1994 publication titled "Electronic Watt-Hour Meter With Integral VHF Transmitter") and Shields (Patent 4,495,505).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Meek disclosed the core elements of the invention by teaching a “digital” electric meter that "includes an integral radio transmitter and antenna" where the "antenna is an electrically short dipole accommodated within the meter case." Because dipole antennas are balanced and require a balanced feed, Petitioner asserted that Meek inherently disclosed the need for a balance circuit. Shields explicitly taught a compact balance circuit (a "balun") specifically designed for use with a printed circuit dipole antenna to interface with an unbalanced feedline, directly addressing the requirement inherent in Meek.
    • Motivation to Combine: A POSITA implementing Meek’s internal dipole antenna would have recognized the fundamental need for a balance circuit. Shields described its balun as "often necessary" for dipole antennas and provided a known, compact solution. Petitioner contended it would have been obvious to combine Shields' balance circuit with Meek's internal dipole antenna to achieve a functional and predictable result, particularly given the space constraints inside an electric meter.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining a standard balun with a standard dipole antenna was a well-understood practice in RF engineering to solve a known impedance-matching and signal-balancing problem.

Ground 2: Obviousness over Bush and Shields - Claims 1, 7-9, 15-17, and 22-28 are obvious over Bush in view of Shields.

  • Prior Art Relied Upon: Bush (Patent 6,078,785) and Shields (Patent 4,495,505).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Bush disclosed an "increased-capability electronic power meter" with "built-in two-way RF communications," including a small antenna integral to the meter. While Bush did not specify a dipole antenna, Petitioner asserted that dipoles were a common and obvious choice for AMR systems at the time. As in the previous ground, Shields provided the explicit teaching of a balance circuit required to properly operate a dipole antenna. Dependent claim features, such as communicating billing information (claim 24) and having a backup power supply (claim 28), were also explicitly taught by Bush.
    • Motivation to Combine: A POSITA designing the AMR system in Bush would have found a dipole antenna to be a simple, readily available, and reliable option. Upon selecting a dipole antenna, the need for a balance circuit would be immediate. Shields provided a suitable design that was functional in the common AMR frequency ranges (e.g., 800-900 MHz) discussed in Bush. The combination was presented as the application of known components to achieve their expected functions.
    • Expectation of Success: A POSITA would have fully expected the combination to work, as it involved integrating a standard antenna type with its necessary supporting circuitry into the electronic meter system described by Bush.

  • Additional Grounds: Petitioner asserted numerous additional obviousness grounds for various dependent claims by adding a single prior art reference to the core Meek/Shields and Bush/Shields combinations. These grounds targeted features such as electromagnetic shielding (Lau, Patent 5,565,783), specific antenna shapes (Johnson, Patent 5,553,094), circuit board racks (Battocletti, Patent 4,615,009), reorientable antennas (Cockson, Patent 5,646,635), microstrip balance circuits (Siwiak, Patent 4,737,797), and flexible connectors (Moore, Patent 5,270,639).

4. Key Claim Construction Positions

Petitioner argued that the claims were unpatentable under two alternative constructions for the key term "electric meter circuitry."

  • Broadest Reasonable Interpretation: "Circuitry in an electric meter." Petitioner contended this plain meaning was consistent with the specification, which discussed both "traditional mechanical meters" and "digital electric meters," and should include both types.
  • Alternative Narrow Construction: "Circuitry in a digital electric meter." This narrower construction was adopted during a prior reexamination based on the Patent Owner's arguments to distinguish prior art disclosing antennas in electromechanical meters. Petitioner argued that even under this narrower scope, the claims were obvious because the primary references (Meek and Bush) explicitly disclosed "digital" or "electronic" meters.
  • "Balance Circuit": Petitioner proposed construing "balance circuit... that balances an impedance... to balance said antenna" as a "circuit that electrically connects the unbalanced output port to the antenna and converts the unbalanced signal of the unbalanced output port to the balanced signal of theantenna."

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner's primary technical contention was that the distinction between "digital" and "electromechanical" meters, which the Patent Owner successfully used to overcome rejections in a prior reexamination, was illusory and of no patentable consequence. Petitioner argued that any AMR meter, regardless of its power measurement sensor (e.g., a rotating disk), requires substantial digital circuitry—including a microprocessor and memory—to process and transmit data wirelessly. Therefore, the prior art disclosing antennas in so-called "electromechanical" AMR meters was highly relevant and should not have been dismissed.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-30 of the ’294 patent as unpatentable under 35 U.S.C. §103.