PTAB

IPR2015-01248

Honeywell International Inc. v. Allure Energy, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Location-Based Control of Networked Devices
  • Brief Description: The ’344 patent discloses a system and method for altering a networked device, such as a wireless thermostat, based on a comparison of the locations of multiple mobile devices relative to a site. The system uses mobile applications and user profiles to generate control actions.

3. Grounds for Unpatentability

Ground 1: 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 asserted that Richton teaches the foundational system claimed in the ’344 patent. Specifically, Richton discloses a location-action server that provides location-based services for network devices at a site (e.g., a thermostat) by monitoring the location of multiple wireless mobile units. Richton’s system further uses user profiles to trigger location-based actions. Petitioner argued that Rosenblatt, in turn, discloses a modern, smartphone-based mobile application with a graphical user interface (GUI) that controls a thermostat based on location, supplying the specific type of mobile application contemplated by the ’344 patent but only generally described in Richton.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to combine the references because Richton suggests that its basic menu-based user interface could be improved with more complex interfaces. A POSITA would combine Rosenblatt’s well-understood graphical mobile application with Richton’s underlying location-based control system to improve the system’s functionality and user experience, which constitutes a predictable improvement.
    • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success in combining these references. The proposed combination involves applying a known type of user interface (from Rosenblatt) to an existing, compatible control system (from Richton) to achieve the predictable result of a more user-friendly, location-aware thermostat system.

Ground 2: 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 argued that Yamashita discloses a system that monitors the location of multiple mobile terminals to automatically control target appliances, such as an air conditioner, based on whether a user is "approaching" or "going away" from a site. To supplement Yamashita’s teachings, Petitioner relied on Shamoon, which explicitly teaches the use of a "geofence" to trigger thermostat adjustments and describes a mobile application with detailed user profiles that can be customized for different users and settings.
    • Motivation to Combine: Petitioner asserted that a POSITA would have been motivated to combine the teachings of Yamashita and Shamoon as they both address the same technical problem of location-based environmental control. A POSITA would naturally look to incorporate the more advanced and explicit geofencing and user profile features of Shamoon into Yamashita’s system to enhance its capabilities and precision, a known method for improving such systems.
    • Expectation of Success: Given that both references operate in the same field and describe complementary technologies, a POSITA would have expected the resulting combination to successfully function as intended, yielding a predictable improvement in location-based appliance control.

Ground 3: 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 builds upon the combination of Yamashita and Shamoon from Ground 2, which establishes a location-aware control system. Petitioner introduced Helvick to teach the limitation of using a remote server to perform the system's processing. Helvick discloses a system for controlling home appliances based on location information and explicitly states that its ETA determination service and associated processing can be located on a mobile device, an on-site home automation system, or a remote server.
    • Motivation to Combine: A POSITA, having combined Yamashita and Shamoon, would be motivated to incorporate Helvick’s teaching of a remote server architecture. This modification would offer significant advantages, such as enhanced scalability, reduced maintenance for the end-user by eliminating the need for a dedicated home server, and the ability to leverage more powerful, cloud-based processing and data.
    • Expectation of Success: Moving processing tasks to a remote server was a well-understood design choice at the time of the invention. A POSITA would have recognized the flexibility and benefits of this architecture and would have had a high expectation of success in implementing the control logic of the Yamashita/Shamoon system on a remote server as taught by Helvick.

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 is narrowed by claim 1 to a "wireless thermostat," but the general construction is relevant to the scope of the invention.
  • Geofence: Petitioner argued this term, which was added during prosecution without definition in the specification, should be construed as "a defined geographic boundary." This construction is critical to invalidity arguments for claims 22-25, as it allows prior art that teaches using location-based triggers and boundaries (even if not explicitly named "geofences") to be mapped to the claims.
  • Control Action Data: Petitioner proposed this term be construed as "data sufficient to alter an operating condition of a network device." This format-neutral construction is important because it allows signals or messages from the prior art, which might not be in a specific data packet format, to satisfy this claim limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8, 19-25, and 30 of Patent 8,626,344 as unpatentable.