PTAB

IPR2015-00086

AT&T Corp v. comcam Intl Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Internet Based Security, Fire and Emergency Identification and Communication System
  • Brief Description: The ’220 patent discloses an internet- and video-based security system. The system uses a sensor to detect an event, which sends a signal to a controller that activates an imaging device; a transmitter then sends the captured event data to a website for remote viewing by authorized entities.

3. Grounds for Unpatentability

Ground 1: Obviousness over Walker and Parsadayan - Claims 1, 3, 11-12, 14-15, 19, and 24-26 are obvious over Walker in view of Parsadayan.

  • Prior Art Relied Upon: Walker (Patent 6,720,990) and Parsadayan (Patent 6,329,930).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Walker discloses the core elements of the ’220 patent’s independent claims, including an internet-based security system with a central server (controller), remote sensors, and the ability to transmit data to a website for monitoring. However, Walker only broadly describes that camera recording can be activated by motion detection. Petitioner asserted that Parsadayan remedies this by teaching a specific implementation where a microprocessor controller receives a signal from a sensor (e.g., a gate breach sensor) and, in response, activates specific cameras to capture the event. The combination of Walker’s general system with Parsadayan’s specific camera activation logic allegedly renders the claimed system obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Parsadayan’s detailed controller-activated camera logic with Walker’s foundational security system. Petitioner contended this combination would provide more precise and reliable control over camera activation in an environment with multiple sensors, which is a clear design choice to improve the overall system's effectiveness.
    • Expectation of Success: As both references describe security systems with common components like sensors, cameras, and controllers, a POSITA would have a high expectation of success in integrating Parsadayan's logic into Walker’s framework.

Ground 2: Obviousness over Walker/Parsadayan with additional features - Claims 2, 6-10, 16, 20-21, and 27 are obvious over Walker and Parsadayan in view of Simerly, Fowler, Stevenson, and/or Kavy.

  • Prior Art Relied Upon: Walker, Parsadayan, and one or more of Simerly (Patent 6,954,859), Fowler (Patent 6,714,977), Stevenson (European Publication # 0856826), and Kavy (WO 99/39505).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the Walker/Parsadayan combination to meet various dependent claim limitations by incorporating conventional, well-known components.
      • Simerly was cited for its disclosure of conventional sensors required by claims 2, 6, 9, and 10, including "contact sensors for doors and windows" (entry point), "glass break detectors," and "smoke sensors."
      • Fowler was cited for claims 7 and 8, as it discloses a "maintenance detector," specifically a "temperature sensor" for monitoring environmental parameters.
      • Stevenson was cited for claim 16, as it teaches using "separate illumination" (a lamp) to enable a camera to record events in low-light conditions.
      • Kavy was cited for claims 20, 21, and 27, as it discloses a system where a remote user can access a web server to actively control system components, such as activating video cameras.
    • Motivation to Combine: Petitioner argued that Walker itself suggests its system can be combined with "other sensing devices well known to those skilled in the art." A POSITA would therefore be motivated to incorporate the conventional sensors and features from Simerly, Fowler, Stevenson, and Kavy to improve the functionality of the base Walker/Parsadayan system. Adding these features—such as broader sensor coverage, night-time operational capability, and active user control—were presented as obvious modifications and predictable design choices to create a more comprehensive and robust security product.

  • Additional Grounds: Petitioner asserted a parallel set of obviousness challenges using Naidoo (Patent 6,690,411) as the primary reference instead of Walker, combined with the same secondary references (Parsadayan, Simerly, etc.) under similar motivations.

4. Key Claim Construction Positions

  • Petitioner argued that the term "event data" should be construed as "data about an event, e.g., a video image or audio recording."
  • This proposed construction was based on the patent's own disclosure, which explicitly defines the scope of "event data" in dependent claim 11 as a "video image" and in dependent claim 12 as an "audio record."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6-12, 14-16, 19-21, and 24-27 of the ’220 patent as unpatentable under 35 U.S.C. §103.