Honeywell Intl Inc v. Allure Energy Inc

1. Case Identification

• Case #: IPR2015-01251
• Patent #: 8,626,344
• Filed: May 22, 2015
• Petitioner(s): Honeywell International Inc.
• Patent Owner(s): Allure Energy, Inc.
• Challenged Claims: 9-18 and 26-29

2. Patent Overview

• Title: System and Method for Altering a Networked Device
• Brief Description: The ’344 patent discloses systems and methods for altering the operating condition of a networked device, such as a wireless thermostat, based on the detected geographic location of multiple mobile devices associated with a particular site.

3. Grounds for Unpatentability

Ground 1: Obviousness over Richton and Rosenblatt - Claims 9-18 and 26-29 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 taught the core functionality of the challenged claims, including a location-based service for controlling network devices like thermostats. Richton’s system monitors the location of multiple wireless mobile units and automatically sends a signal to adjust a device (e.g., a thermostat) when a unit meets a geographic criterion, such as being within five miles of a home. Petitioner argued Richton discloses comparing the locations of multiple devices and initiating control actions when they are either approaching or leaving a site. To address limitations not explicitly detailed in Richton, Petitioner cited Rosenblatt. Rosenblatt was argued to teach a modern mobile application (on an iPhone) for controlling a thermostat, including features for detecting the availability of the network device, providing a graphical user interface with a checkbox to enable or disable proximity settings, and updating the mobile device with the current status of the controlled device.
  • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Richton and Rosenblatt to improve Richton’s foundational system with more modern and practical features. Richton suggests its interface could be improved, and Rosenblatt provides a known graphical interface for such a system. Petitioner contended that Rosenblatt’s features for enabling and disabling proximity services were the type of necessary "administrative steps" that a POSITA would have found obvious to add to make Richton's system commercially practical and user-friendly.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these teachings, as it involved implementing known user interface designs and networking protocols from Rosenblatt into the established location-based control framework of Richton.

Ground 2: Obviousness over Yamashita and Shamoon - Claims 9-18 and 26-29 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 disclosed a system for automatically controlling a home appliance, such as an air conditioner, based on the position of multiple mobile terminals without requiring user interaction. Yamashita’s system uses predefined "message transmission rules" based on location (e.g., a message indicating a terminal is "approaching") to trigger control commands. Yamashita also discloses comparing messages from multiple terminals to make control decisions. Petitioner relied on Shamoon to supply teachings on a two-way communication system. Shamoon was asserted to teach providing feedback to the mobile device, such as displaying the current temperature and operating status of the thermostat. Shamoon also explicitly discloses the concept of a "geofence" as a trigger for altering a thermostat’s operation and describes user profiles for managing settings on a per-device basis.
  • Motivation to Combine: Petitioner asserted that a POSITA would combine Yamashita and Shamoon because they are both in the field of location-based appliance control. The primary motivation was to improve Yamashita's one-way control system by adding the two-way feedback and status update capabilities taught by Shamoon. Providing such feedback is a common, predictable, and desirable feature in any control system to allow users to confirm that commands were executed correctly.
  • Expectation of Success: Integrating a feedback loop and status display from Shamoon into the control system of Yamashita was presented as a straightforward application of known principles with a high likelihood of success.

4. Key Claim Construction Positions

• Geofence: Petitioner argued that because the term was added during prosecution without explicit support in the specification, it should be construed according to its plain and ordinary meaning. Petitioner proposed the construction "a defined geographic boundary," consistent with the patent’s disclosure of using distance-based boundaries (e.g., zones) to trigger actions.
• Network Device: Petitioner proposed that this term be construed broadly under the broadest reasonable interpretation standard as "a physical component that is connectable to a communications interface." This broad construction was argued to be consistent with the specification’s exemplary embodiments (thermostats, smart appliances) and necessary to properly apply the prior art.
• Proximity Setting: Petitioner proposed this term means "a setting that allows a mobile device to generate location information." This construction was based on the specification’s description of a user enabling a "proximity detection selector" to alter energy use based on distance from a site.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 9-18 and 26-29 of the ’344 patent as unpatentable under 35 U.S.C. §103.