PTAB

IPR2014-01565

Apple Inc v. Aylus Networks Inc

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1. Case Identification

2. Patent Overview

  • Title: Digital Home Networks Having A Control Point Located On A Wide Area Network
  • Brief Description: The ’412 patent discloses a system for delivering media content from a media server (MS) to a media renderer (MR) within a digital home network. The patent describes an extension of the Universal Plug and Play (UPnP) architecture where the control point (CP) is located on a wide area network (WAN), and a control point proxy (CPP) is located on the user premises to facilitate communication.

3. Grounds for Unpatentability

Ground 1: Obviousness over UPnP Design - Claims 1-33 are obvious over UPnP Design.

  • Prior Art Relied Upon: UPnP Design by Example: A Software Developer's Guide to Universal Plug and Play (a 2003 book and accompanying CD-ROM, hereinafter "UPnP Design").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that UPnP Design, a comprehensive guide to the UPnP standard, disclosed all elements of the challenged claims. It described the foundational UPnP A/V architecture, including a Media Server, a Media Renderer, and a Control Point that negotiates media delivery between them. Critically, UPnP Design taught a "Device Relay" feature, which Petitioner mapped to the claimed control point (CP) logic. This Device Relay "effectively bridges two UPnP networks" and operates "over the Internet" or WAN. Petitioner further mapped the "Device Spy" and "A/V Media Controller" tools described in UPnP Design to the claimed control point proxy (CPP) logic, which resides on a user's PC (the user endpoint or UE) and cooperates with the remote Device Relay. The reference also disclosed using standard VCR-type controls for media playback.
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, the argument was that a person of ordinary skill in the art (POSITA) would have found it obvious to apply the teachings of UPnP Design to achieve the claimed invention. Petitioner contended that a primary goal of the UPnP initiative was to extend the accessibility and interoperability of devices beyond a single local network. Therefore, implementing the "Device Relay" feature to control a home media network remotely was a predictable application of the reference's own teachings.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing remote media control, as it involved using well-documented UPnP protocols and tools for their intended purpose of extending network interoperability.

Ground 2: Obviousness over UPnP Design and Costa-Requena - Claims 1-33 are obvious over UPnP Design in view of Costa-Requena.

  • Prior Art Relied Upon: UPnP Design and Costa-Requena (Application # 2006/0143295).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent UPnP Design was found deficient, Costa-Requena explicitly disclosed a UPnP architecture for remote access. Costa-Requena taught a mobile station (UE with CPP logic) located outside a home UPnP network communicating with UPnP devices (including an MS and MR) inside the network. This remote communication was facilitated by a "web proxy gateway" (CP logic) located within an "Internet Gateway Device" (serving node), which "acts as a Control Point" and relays UPnP commands over the Internet. Costa-Requena thus provided a clear blueprint for the claimed system of a remote UE controlling local media devices through a WAN-based serving node.
    • Motivation to Combine: A POSITA would combine these references because both addressed extending UPnP network functionality. Costa-Requena provided a high-level architecture for remote access, while UPnP Design provided the detailed, foundational specifications required to implement the specific UPnP services, devices (MediaServer, MediaRenderer), and actions. A developer seeking to build the system in Costa-Requena would have naturally turned to the official UPnP specifications and guides like UPnP Design.
    • Expectation of Success: Combining Costa-Requena’s architecture with the standard implementation details from UPnP Design would involve applying known elements for their intended purposes, leading to the predictable result of a functional remote media control system.

Ground 3: Obviousness over UPnP Design and Stewart - Claims 1-33 are obvious over UPnP Design in view of Stewart.

  • Prior Art Relied Upon: UPnP Design and Stewart (Application # 2006/0112192).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Stewart taught another method for bridging UPnP networks across a WAN. Stewart disclosed a "first enabling device" (UE with CPP logic) on a local network that cooperates with a "remote local area network control point" (CP logic) to interact with UPnP devices (MS and MR) on a second, remote network via a WAN. Stewart's remote control point provided "proxy-like/masquerading functionality," enabling devices on the two separate networks to communicate as if they were on the same local network. This proxy functionality directly mapped to the claimed functions of the CP and CPP logic.
    • Motivation to Combine: The motivation was similar to the Costa-Requena combination. A POSITA seeking to enable communication between disparate UPnP networks as taught by Stewart would have relied on the fundamental UPnP specifications detailed in UPnP Design to implement the underlying device behaviors and control actions. Both references shared the common goal of extending UPnP interoperability across network boundaries.
    • Expectation of Success: A POSITA would have reasonably expected success in combining Stewart's network bridging and proxy techniques with the standard UPnP protocols from UPnP Design, as it represented the integration of known networking solutions with a well-defined device control framework.

4. Key Claim Construction Positions

  • Petitioner argued for constructions consistent with those proposed by the Patent Owner in a related district court litigation, applying the broadest reasonable interpretation standard.
  • "serving node": construed as "a serving element in the wide area network."
  • "control point (CP) logic": construed as "logic used to control UPnP devices or transmit UPnP control messages."
  • "control point proxy (CPP) logic": construed as "logic used to communicate with UPnP devices using the UPnP protocol or to transmit UPnP control messages."
  • These constructions were central to Petitioner's arguments, as they framed the "Device Relay" of UPnP Design, the "web proxy gateway" of Costa-Requena, and the "remote control point" of Stewart as the claimed WAN-based "CP logic."

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-33 of Patent RE44,412 as unpatentable.