PTAB

IPR2015-00833

Good Technology Software Inc v. MobileIron Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Mobile Device Management
  • Brief Description: The ’633 patent discloses systems and methods for collecting mobile device network traffic usage data from a plurality of devices, aggregating the data at a central database, and generating usage reports based on the aggregated data, particularly for devices associated with an enterprise.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cassett and Stevens - Claims 1-4, 6-25, and 27-28 are obvious over Cassett in view of Stevens.

  • Prior Art Relied Upon: Cassett (Patent 7,817,983) and Stevens (Patent 6,925,160).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cassett discloses nearly all limitations of the independent claims, including a system where mobile devices collect usage data (e.g., call, messaging, browser activity) and report it directly to a server for aggregation and report generation. However, Cassett does not explicitly teach that the mobile devices are "associated with a particular enterprise." Stevens was argued to cure this deficiency by disclosing a system for managing cellular telephone costs for employees within a company, thereby providing the enterprise context missing from Cassett.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Cassett’s general usage monitoring technology with the enterprise-specific application taught by Stevens. The motivation would be to apply Cassett's monitoring capabilities in a business context to generate reports useful to managers for analyzing device usage across an enterprise, as suggested by Stevens.
    • Expectation of Success: Petitioner asserted that combining these known elements—usage monitoring and enterprise management—involved applying well-understood techniques to a predictable business context, leading to a high expectation of success.

Ground 2: Obviousness over Stevens and Cassett - Claims 1-4, 6-25, and 27-28 are obvious over Stevens in view of Cassett.

  • Prior Art Relied Upon: Stevens (Patent 6,925,160) and Cassett (Patent 7,817,983).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented an alternative theory, arguing that Stevens teaches the core enterprise-based system but receives usage data from carriers, not "directly from each of a plurality of mobile devices" as required by the claims. This method requires converting carrier-specific data formats. Cassett was argued to cure this deficiency by teaching a system where mobile devices report usage data directly to a server, eliminating the need for an intermediary carrier.
    • Motivation to Combine: A POSITA would be motivated to modify the system of Stevens with the direct-reporting feature of Cassett to improve efficiency. Receiving data directly from devices in a single format would avoid the extra processing step and complexity of converting multiple carrier-specific data formats into a common format.
    • Expectation of Success: This modification was presented as a predictable design choice to streamline data collection, using known techniques taught by Cassett.

Ground 3: Obviousness over Cassett/Stevens in view of Agarwal and Barnea

  • Prior Art Relied Upon: Cassett (Patent 7,817,983), Stevens (Patent 6,925,160), Agarwal (Application # 2009/0005002), and Barnea (Patent 7,310,511).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that for certain dependent claims, Agarwal and Barnea provide teachings that supplement the primary Cassett/Stevens combination.
      • Agarwal (for claims 6, 20, 23, 24): Agarwal teaches filtering raw data on the portable device before transmission (claim 6), receiving usage data in real-time or on a continuous basis (claims 20 and 23), and specifically monitoring email activity (claim 24).
      • Barnea (for claim 11): Barnea teaches automatically sending alerts (e.g., text messages with offers) to a mobile device based on its recorded usage data, such as roaming status or low usage levels. This maps to the limitation of sending an alert based on received usage data.
    • Motivation to Combine:
      • Agarwal: A POSITA seeking to improve the Cassett/Stevens system would look to Agarwal to implement more timely and efficient data collection (real-time transmission, on-device filtering) and to expand the system’s monitoring capabilities to include specific application types like email, which was a common business need.
      • Barnea: A POSITA would be motivated to add Barnea’s alerting functionality to the Cassett/Stevens system to provide targeted marketing or automated notifications to users based on their behavior, fulfilling a known business objective of leveraging usage data.

4. Key Claim Construction Positions

  • "Mobile Device Network Traffic Usage Data": Petitioner proposed this term be construed as "information regarding use of a network for sending and/or receiving data by a mobile device." This construction was argued to be consistent with the specification's examples (e.g., call, SMS, browser data) and the prosecution history, where the patentee added "network traffic" to distinguish from general device usage.
  • "Characterized Actions Performed on Each of the Mobile Devices": Petitioner proposed this term be construed as "identifiable usage of and/or actions performed on a mobile device." This construction was argued to be supported by the specification's disclosure of logging specific user interactions (e.g., man-machine interface data, file system commands) and the prosecution history's focus on aggregating data based on actions occurring at the device itself.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-4, 6-25, and 27-28 of the ’633 patent as unpatentable.