PTAB

IPR2015-01226

Global Tel Link Corp v. Securus Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Multi-Channel Recording
  • Brief Description: The ’115 patent discloses a system for recording multiple channels of a telephone call to overcome the limitations of prior art single-channel recording. The invention involves separately recording each participant's audio, generating control information to correlate the recordings, and classifying participants into speaking or listening groups.

3. Grounds for Unpatentability

Ground 1: Obviousness over Schrage and Koga - Claims 1, 2, 15, and 16 are obvious over Schrage in view of Koga.

  • Prior Art Relied Upon: Schrage (Patent 6,850,609) and Koga (Application # 2005/0207357).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schrage taught the core concepts of independent claim 1, including separately recording incoming audio signals from different parties on a conference call and generating control information (e.g., time stamps, source identifiers) to allow for subsequent correlation and reconstruction. However, Petitioner asserted that Schrage did not explicitly teach classifying participants into "listening" and "talking" groups and dynamically re-classifying them as the call progresses. This limitation, Petitioner contended, was taught by Koga, which described classifying terminals in an IP-based conference call system into speaker and listener groups to manage processing and network load, and allowing terminals to move between groups as the conversation evolved.
    • Motivation to Combine: A POSITA would combine Schrage and Koga to improve the functionality of Schrage’s system, particularly in an internet-based environment. Koga’s method of classifying participants would have been a known solution for reducing the processing load and network traffic in the multi-channel recording system described by Schrage.
    • Expectation of Success: The combination would have been a predictable integration of known conference call management techniques into a recording system, as both references operated in the same technical field.

Ground 2: Obviousness over Schrage, Koga, Creamer, and Peterson - Claims 3-6, 17, and 18 are obvious over Schrage in view of Koga, Creamer, and Peterson.

  • Prior Art Relied Upon: Schrage (Patent 6,850,609), Koga (’357 application), Creamer (Application # 2005/0094794), and Peterson (Patent 6,970,554).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Schrage/Koga combination to address claims reciting an interactive voice response (IVR) system. Petitioner argued that while Schrage disclosed recording conference calls, it lacked detail on call setup and access control. Creamer was introduced to teach using an IVR system to automatically set up a conference call and authenticate participants. Peterson was introduced to teach the importance of recording the entire interaction with a caller, including prompts and responses involving an IVR system, for assessment and quality control purposes. The combination allegedly taught recording various phases of a call where parties interact with the IVR system before and during communication with other human parties.
    • Motivation to Combine: A POSITA would have sought to add access control and automated setup to the Schrage/Koga system, leading them to Creamer’s IVR-based solution. Once incorporating an IVR, it would be obvious to also incorporate Peterson's teaching of recording the IVR interactions to ensure a complete record of the communication for quality and analysis purposes.
    • Expectation of Success: Combining these systems was argued to be predictable, as it involved integrating known IVR and recording functionalities into a conference call system to improve its features and robustness.

Ground 3: Obviousness over Schrage, Koga, and Glowny - Claims 7-12, 19, 20, 23, and 24 are obvious over Schrage in view of Koga and Glowny.

  • Prior Art Relied Upon: Schrage (Patent 6,850,609), Koga (’357 application), and Glowny (Patent 6,728,345).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the control signal to include more detailed event information, such as when a party is added or leaves a call, call detail records, and location information. Petitioner asserted that the Schrage/Koga combination lacked this level of detailed, real-time call data management. Glowny was cited for its disclosure of a Computer-Telephony Integration (CTI) system that creates a "Master Call Record." This record captures a complete history of a call, including specific event messages like "CONFERENCE-ADD" and "CONFERENCE-DROP," as well as call detail record (CDR) information and location data.
    • Motivation to Combine: A POSITA implementing the Schrage/Koga system would have been motivated to incorporate Glowny's CTI-based techniques to enhance the control information. Glowny provided a known method for handling the real-time processing and logging of complex call events, which Koga suggested but did not detail.
    • Expectation of Success: The integration was presented as straightforward, as both Schrage and Glowny addressed the problem of separately recording call participants and reconstructing calls from those recordings.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 13, 14, 21, 22, 27, and 28 by adding Ostrover (Patent 5,469,370) to the Schrage/Koga/Glowny combination to teach selective playback of audio tracks. A final ground combined all references (Schrage, Koga, Glowny, Peterson, Creamer) to address claims 25 and 26.

4. Key Claim Construction Positions

  • "external data signal": Petitioner proposed this term should be construed to mean "a signal that includes data that is related to a call and that is external to the voice signals of the call." This construction was argued to be critical because it clarifies that "external" describes the type of data (non-voice) rather than its physical origin, aligning with the patent's disclosure of including call-related data like location information within the recording.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-28 of Patent 8,135,115 as unpatentable.