PTAB

IPR2015-00119

RF Controls LLC v. A 1 Packaging Solutions Inc

Key Events

Petition

petition Intelligence

Title: RADIO FREQUENCY IDENTIFICATION SYSTEM FOR TRACKING AND MANAGING MATERIALS IN A MANUFACTURING PROCESS
Brief Description: The ’057 patent relates to systems and methods for tracking inventory within a defined region using radio frequency identification (RFID) technology. The system uses one or more steerable radio frequency antennas to periodically scan an inventory region, detect RFID tags associated with inventory items, and determine the current physical location of the tags.

Prior Art Relied Upon: Subramanian (Application # 13/214,823).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Subramanian, which was cited during prosecution of the ’057 patent, discloses all limitations of independent claims 17 and 27. Subramanian teaches an RFID tag reader system with a steerable directional antenna that scans a controlled area to detect and locate RFID tags. Petitioner contended that the key limitation—determining a physical location corresponding to a position defined by "two coordinate units" using a single antenna—is met by Subramanian's disclosure of determining location based on the antenna's angular orientation. Subramanian describes rotating a directional antenna around multiple axes (e.g., Z-axis and X-axis) relative to a fixed coordinate system, thereby providing the two required coordinate units (two angles) to define a direction and pinpoint a location.
- Key Aspects: Petitioner asserted that the Patent Owner improperly distinguished Subramanian during prosecution by arguing it could only determine a "directional position" and not a location defined by two coordinates. Petitioner argued this was a mischaracterization of the reference, as determining a location via two angular orientations from a known point satisfies the claim language under its broadest reasonable interpretation.

Prior Art Relied Upon: Hofer (Patent 8,493,182).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Hofer, which was not cited during prosecution, teaches an "intelligent steerable phased array antenna module" that scans a volume using a beam steering technique. Hofer's system explicitly determines the three-dimensional location of an RFID tag by using a phase ranging technique. This technique provides two angular coordinates (phi and theta) from the beam steering unit and a third coordinate (distance) derived from a phase ranging algorithm. Petitioner argued this directly teaches a system that determines a location defined by at least two coordinate units (two angles, or an angle and a distance) using a single antenna system, thus anticipating the claims.
- Key Aspects: Petitioner highlighted that even if the claims were interpreted to require one coordinate to be distance—a position the Patent Owner took during prosecution—Hofer explicitly discloses determining both direction (angular orientation) and distance, making it an especially strong anticipatory reference.

Prior Art Relied Upon: Husak (Patent 7,667,575).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued Husak, also not cited during prosecution, teaches a system with RFID readers incorporating "steerable beam antennae" that periodically scan an RF coverage region. Husak determines tag locations using a "tag location virtualization" technique, which involves mapping tag detections to predefined physical locations within the RFID environment. These locations are defined within a 2- or 3-dimensional space or volume, which inherently requires the use of at least two coordinate units. The system resolves a tag's location to a "segment," which is a subset of the reader's interrogation zone, thus disclosing a location resolved to a region smaller than the antenna's coverage area.
Additional Grounds: Petitioner asserted that dependent claims 18-21 and 23-30 were anticipated by Subramanian or Husak. Petitioner also raised obviousness challenges under 35 U.S.C. §103 to independent claims 17 and 27 over combinations of Subramanian, Hofer, and Husak, and to dependent claim 22 over Subramanian in view of Takaku for adding a visual alarm feature.

"Antenna" / "Antenna System" / "Antenna Element": Petitioner argued that based on the specification, the term "antenna" should be construed as a phased array antenna comprising a plurality of antenna elements. This construction was advanced to avoid potential invalidity issues under 35 U.S.C. §112, as Petitioner contended the ’057 patent's disclosure only enables location determination using techniques like triangulation, which require multiple spaced-apart antenna elements (even if housed within a single antenna system).
"Inventory Tracking Region": Petitioner proposed this term means "an area or location within a building or facility in which inventory is tracked," based on its contextual usage throughout the patent's specification.
"Detection Controller": Petitioner argued this term should be construed functionally as an RFID module that performs several actions: operating an antenna to emit beams and receive signals from RFID tags; using triangulation or other known algorithms to determine tag location based on received signals; and optionally steering the antenna or its beam.

Petitioner requested that the Board institute an inter partes review and cancel claims 17-30 of the ’057 patent as unpatentable.