Iron Dome LLC v. CRFD Research Inc

1. Case Identification

• Case #: IPR2015-00055
• Patent #: 7,191,233
• Filed: October 10, 2014
• Petitioner(s): Iron Dome LLC
• Patent Owner(s): CRFD Research, Inc.
• Challenged Claims: 1-6, 8-11, 13-15, 17, 18, 20, and 34

2. Patent Overview

• Title: System for Automated, Mid-Session, User-Directed, Device-to-Device ...
• Brief Description: The ’233 patent discloses methods and systems for transferring an ongoing software session, such as a web browsing session, from a first user device to a second, networked device. The system uses a session server to manage the handoff, which can involve reformatting session data to be compatible with the target device.

3. Grounds for Unpatentability

Ground 1: Anticipation and Obviousness over Phan San Jose - Claims 1-3, 13, 14, and 34 are anticipated or obvious over Phan San Jose.

• Prior Art Relied Upon: Phan San Jose (“A New TWIST on Mobile Computing: Two-Way Interactive Session Transfer,” WIAPP 2001).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Phan San Jose, which describes the iMash mobile computing platform, discloses every element of independent claims 1, 13, and 34. The iMash platform was developed to allow physicians to seamlessly hand off application sessions across heterogeneous devices. For example, a physician reviewing clinical data on a PDA (the "first device") can discontinue the session, have the session state ("session history") transmitted to a middleware server (the "session transfer module"), and resume the session on a desktop computer (the "second device"). This process directly maps to the limitations of the independent method and system claims.
  • Motivation to Combine (for §103 grounds): For dependent claims 2 and 3, Petitioner argued that Phan San Jose teaches both "push" and "pull" mechanisms for session transfer. The claimed features, such as pushing the session in response to discontinuing or pushing a notification, represent obvious variations of the disclosed iMash system. For instance, Petitioner contended it would be an obvious matter of user preference to modify the "push" mechanism to be non-automatic (resuming upon user activation at the second device) or to provide a notification that a session is ready to be resumed, thereby rendering claims 2 and 3 obvious.
  • Expectation of Success: The expectation of success was high because Phan San Jose describes a system that was already implemented and operational.

Ground 2: Obviousness over Phan San Jose in view of Phan Helsinki - Claims 4-6, 8-11, 15, 17, 18, and 20 are obvious over Phan San Jose in view of Phan Helsinki.

• Prior Art Relied Upon: Phan San Jose (WIAPP 2001) and Phan Helsinki (“Handoff of Application Sessions Across Time and Space,” ICC 2001).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that while Phan San Jose teaches the core session handoff system, Phan Helsinki provides explicit details about adapting session data for different devices, as required by these more specific dependent claims. Phan Helsinki explains that the iMash middleware server is responsible for making "necessary conversion to fit the clients' needs." This disclosure of "Presentation conversion" was argued to teach the limitations of "accessing a device profile of said second device" and "restructuring said session data to conform with said device profile" (claim 4). For example, Phan Helsinki describes converting proprietary PACS medical images to Java images for a client device, which meets the limitation that data "conforms to a data format of said second device" (claim 5). Similarly, Phan Helsinki's description of transferring and reformatting web browser bookmarks and history for a Mozilla browser was argued to teach "reformatting said session history" (claim 8).
  • Motivation to Combine: A POSITA would combine these references because they were published by the same research group, describe different aspects of the same iMash project, and were published only one month apart. Phan San Jose explicitly cites Phan Helsinki as previous work. Therefore, a POSITA seeking to understand the full capabilities of the iMash platform, particularly regarding data handling for heterogeneous devices, would have been motivated to consult both publications.
  • Expectation of Success: A POSITA would have a high expectation of success in combining the teachings, as the references describe a single, integrated, and already-implemented system. The combination merely involves using the specific data conversion techniques described in Phan Helsinki within the overall session handoff framework described in Phan San Jose.

4. Key Claim Construction Positions

• "in response to an activation of said second device": Petitioner proposed this term encompasses any user action at the receiving device that triggers the retrieval of the transferred session. This includes logging-on, powering-on, or launching the relevant application. This construction was important for arguing that the "pull" mechanism in Phan San Jose, where a user manually launches an application on the second device to retrieve the session, met this limitation.
• "conform with said device profile of said second device": Petitioner proposed this term encompasses, at a minimum, converting the session data into a data format compatible with the second device. This construction was central to mapping the data and presentation conversion functionalities described in Phan Helsinki to the claim limitations.
• "conforms to a modality of said second device": Petitioner proposed "modality" refers to the mode of user interaction (e.g., graphical, text, voice). This allowed Petitioner to argue that the handoff shown in Phan San Jose, which conforms to the graphical interface of the destination desktop or laptop, met this claim limitation.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-6, 8-11, 13-15, 17, 18, 20, and 34 of the ’233 patent as unpatentable.