PTAB

IPR2015-00659

Fieldcomm Group v. Sipco LLC

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1. Case Identification

2. Patent Overview

  • Title: Systems And Methods For Monitoring And Controlling Remote Devices
  • Brief Description: The ’492 patent discloses a wireless communication system for monitoring and controlling remote devices equipped with sensors and actuators. The system uses preformatted messages containing a receiver address, a command indicator, and a data value to communicate between devices via transceivers.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kantronics and AX.25 Protocol - Claims 1-4, 6, 8-11, 13-22, and 24-25 are obvious over Kantronics in view of AX.25 Protocol.

  • Prior Art Relied Upon: Kantronics (Kantronics KPC-3 – Users Guide, 1997) and AX.25 Protocol (AX.25 Amateur Packet-Radio Link-Layer Protocol, Version 2.0, October 1984).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kantronics, a user guide for a terminal node controller (TNC), discloses a packet radio system for remote sensing and control, meeting the core limitations of independent claim 1. It describes a system with remote devices, controllers, transceivers, sensors (e.g., a liquid level sensor), and actuators (e.g., a pump and drain). The AX.25 Protocol, which Kantronics explicitly states it "incorporates," was asserted to teach the remaining key limitations. Specifically, the "scalable address" was mapped to the AX.25 address field, which allows for variable-length addresses padded with spaces. The "command indicator" was mapped to the command syntax in Kantronics (e.g., "CTRL A 3" to pulse an output) and the control field in an AX.25 packet. The "scalable message" was mapped to the AX.25 data field, which can contain 1 to 256 bytes of user data. Dependent claims relating to unique addresses, error checking (Cyclic Redundancy Check), and duplicate message detection were also allegedly taught by the combined references.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to combine these references because Kantronics expressly incorporates the AX.25 Protocol. A POSITA implementing the Kantronics system would naturally consult the AX.25 Protocol specification to understand the underlying packet structure, addressing, and control mechanisms. The references were presented as analogous art from the same field of packet radio communication.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the Kantronics hardware was designed specifically to operate using the AX.25 Protocol. The combination represents the intended and documented operation of the system.

Ground 2: Obviousness over Kantronics, AX.25 Protocol, and Zimmerman - Claims 7, 12, and 23 are obvious over Kantronics in view of AX.25 Protocol and Zimmerman.

  • Prior Art Relied Upon: Kantronics (a 1997 user guide), AX.25 Protocol (an October 1984 protocol specification), and Zimmerman (Patent 5,279,305).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Kantronics and AX.25 Protocol to address the additional limitation of "Manchester encoding" recited in claims 7, 12, and 23. Petitioner argued that the base combination taught all elements of the claims except for this specific encoding method. Zimmerman, which discloses a system for telemetrically transmitting medical data, was introduced to supply the missing element. Zimmerman explicitly teaches converting sensor data into a "selected digital code being Manchester code" for reliable transmission.
    • Motivation to Combine: Petitioner asserted that Manchester encoding was a "notoriously well-known encoding protocol" at the time. A POSITA seeking to implement a robust data transmission scheme for the packet radio system of Kantronics/AX.25 would have been motivated to use a standard, well-known, and reliable physical layer encoding method. Manchester encoding was a common and obvious choice for its properties of ensuring clock recovery and DC balance, and Zimmerman provided an express teaching of its use in a wireless data transmission context.
    • Expectation of Success: Given that Manchester encoding was a standard and widely understood technique, a POSITA would have reasonably expected to successfully integrate it into the known packet radio system of Kantronics and AX.25 without undue experimentation.

4. Key Claim Construction Positions

  • "scalable address": Petitioner agreed with a construction from a related district court case, defining the term as "an address that has a variable size based on the size and complexity of the system." This construction supported the argument that the fixed-length-but-paddable address field of the AX.25 Protocol met the claim limitation.
  • "command indicator": Petitioner proposed this term be construed as "data that indicates a command." This construction allowed Petitioner to map the limitation to both the alphanumeric command syntax in the Kantronics user guide and the dedicated control field bits within the AX.25 packet frame structure.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4 and 6-25 of the ’492 patent as unpatentable.