PTAB

IPR2015-01248

Honeywell Intl Inc v. Allure Energy Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Altering a Networked Device Based on Proximity
  • Brief Description: The ’344 patent discloses a system and method for altering the operating condition of a networked device, such as a wireless thermostat at a specific site, based on the locations of multiple mobile devices relative to that site. The system uses mobile applications and user profiles to generate control actions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Richton and Rosenblatt - Claims 1-8, 21-25, and 30 are obvious over Richton in view of Rosenblatt.

  • Prior Art Relied Upon: Richton (Patent 6,400,956) and Rosenblatt (Application # 2010/0081375).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Richton taught the core system of claim 1, including using the location of multiple mobile devices to trigger actions on network devices at a site, such as a thermostat. Richton also disclosed using individual user profiles to define these location-based actions. However, Richton described a menu-based user interface. Petitioner asserted that Rosenblatt supplied the teaching of a modern, smartphone-based mobile application with a graphical touchscreen interface for controlling a thermostat based on location, a feature that was well-known by the time of the ’344 patent. The combination of Richton’s system logic with Rosenblatt’s modern user interface allegedly rendered the claims obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because Richton explicitly suggested that its menu-based system could be improved with more complex interfaces, such as the graphical application taught by Rosenblatt. Both references addressed the same problem of using location to automatically control a thermostat, making the combination a predictable solution to improve Richton's system with a superior, commercially available user interface.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The integration involved applying a known graphical user interface (Rosenblatt) to an existing location-based control system (Richton), which was a straightforward application of known technologies to achieve a predictable result.

Ground 2: Obviousness over Yamashita and Shamoon - Claims 1, 5, 7, 8, 19, 20, 22-25, and 30 are obvious over Yamashita in view of Shamoon.

  • Prior Art Relied Upon: Yamashita (Patent 6,909,891) and Shamoon (Patent 6,990,335).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Yamashita disclosed a system for controlling home appliances, including an air conditioner, based on the location of multiple mobile terminals. Yamashita's system determined whether a mobile terminal was "approaching" or "going away" from a site to trigger control commands. To the extent Yamashita did not fully detail a mobile application or user profiles, Shamoon provided these elements. Shamoon taught a mobile application with a user interface for controlling a thermostat, using geofencing, and establishing user profiles with specific preference settings.
    • Motivation to Combine: A POSITA would combine Yamashita and Shamoon because they were in the same field of endeavor and Shamoon's advanced mobile application and geofencing features represented a known method for improving location-based control systems like Yamashita's. Yamashita disclosed user-specific "message transmission rules," which motivated a POSITA to look to Shamoon's more detailed user profiles to implement this functionality.
    • Expectation of Success: The combination was predictable. It involved implementing Yamashita's core logic of multi-device location tracking with the enhanced user interface and profile management features described in Shamoon, both of which were well-understood technologies.

Ground 3: Obviousness over Yamashita, Shamoon, and Helvick - Claims 2-4 and 6 are obvious over Yamashita in view of Shamoon in further view of Helvick.

  • Prior Art Relied Upon: Yamashita (Patent 6,909,891), Shamoon (Patent 6,990,335), and Helvick (Application # 2010/0127854).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Yamashita and Shamoon to address claims requiring a "remote server." Yamashita’s "control terminal" could be interpreted as being on-site. Helvick was introduced to explicitly teach moving the control logic and processing to a remote server. Helvick described a home automation system where location processing and ETA calculations could be performed on a remote server, a mobile device, or a home controller, disclosing the architectural flexibility to place the processor remotely.
    • Motivation to Combine: A POSITA would be motivated to add Helvick's teachings to the Yamashita/Shamoon system to gain the known advantages of a remote server architecture. Helvick explained that using a remote server reduces maintenance and provides functionality not available on a user-controlled home server. This provided a clear reason to modify the base system to include a remote processor for dependent claims 2 and 6.
    • Expectation of Success: A POSITA would expect success, as moving processing from a local controller to a remote server was a known and common design choice in networked systems with predictable benefits in scalability and maintenance.

4. Key Claim Construction Positions

  • Network Device: Petitioner proposed this term be construed as "a physical component that is connectable to a communications interface." This broad construction was argued to be consistent with the specification and necessary to encompass the various thermostats and appliances disclosed in the prior art.
  • Control Action Data: Petitioner argued for a construction of "data sufficient to alter an operating condition of a network device." This functional, format-neutral definition was asserted to cover the various signals, messages, and commands taught by the prior art references.
  • Geofence: Petitioner proposed that "geofence" be construed as "a defined geographic boundary." As the term was added during prosecution without explicit support in the specification, Petitioner argued a POSITA would understand it to mean the boundary itself, which, when crossed, triggers an action. This construction allowed Petitioner to map the distance-based triggers in Richton and Yamashita to this claim term.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-8, 19-25, and 30 of the ’344 patent as unpatentable.