PTAB

IPR2015-01253

Honeywell Intl Inc v. Allure Energy Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Location-Based Control of Network Devices
  • Brief Description: The ’797 patent describes systems and methods for automatically altering the operating condition of network devices, such as thermostats, at multiple distinct sites. The alteration is triggered by a "proximity detection module" that determines the relative location of associated mobile reporting devices with respect to their corresponding sites.

3. Grounds for Unpatentability

Ground 1: Claims 1-17 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 disclosed the core elements of the challenged claims, including a system with network devices (e.g., thermostat, light switch) disposed at multiple sites (e.g., a home and an office) that are controlled based on the location of one or more mobile units. Petitioner asserted that Richton's "location-action server," which orchestrates location-based services, performs the function of the claimed "proximity detection module" by comparing a mobile unit's location to predefined geographic criteria to trigger an action. Rosenblatt was cited primarily to teach specific, modern implementations of features described more generally in Richton, such as a user interface on a handheld device with a checkbox to enable or disable location-based control.
    • Motivation to Combine: A POSITA would combine Richton and Rosenblatt because both references are directed to the same field of automatically controlling a thermostat based on a user's location. Petitioner argued a POSITA implementing Richton's system, which mentioned the need for administrative controls like starting and stopping the service, would naturally look to a contemporary reference like Rosenblatt for its clear disclosure of a user-friendly mechanism (e.g., a checkbox) to provide such control.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references because it involved integrating a known user interface element from Rosenblatt into the analogous, pre-existing system architecture of Richton. This was presented as a straightforward combination of complementary features to create a more practical and complete system.

Ground 2: Claims 1-8 and 10-17 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 taught a system for controlling a target appliance (an air conditioner) at a single site based on its proximity to one or more mobile terminals. In Yamashita, a "control terminal" receives "approaching" messages from mobile devices and transmits a command to alter the appliance's operation, thereby functioning as the proximity detection module. The teachings of Shamoon were introduced to bridge Yamashita’s single-site system to the claimed multi-site environment. Shamoon explicitly described controlling systems in multiple residences, such as a main home and a vacation home, from a single mobile device using geofencing.
    • Motivation to Combine: A POSITA would combine Yamashita and Shamoon to extend the utility of Yamashita’s system. Petitioner argued that applying Shamoon's teachings on multi-site control to Yamashita's system was a predictable and desirable improvement. Shamoon also taught more advanced features like two-way feedback and user-specific profiles, which a POSITA would have been motivated to incorporate to improve the functionality and user experience of the more basic system disclosed in Yamashita.
    • Expectation of Success: A POSITA would expect success because the combination involved scaling a known technology (Yamashita's location-based appliance control) to a broader, known application (multi-site control) as explicitly taught by Shamoon. The integration was portrayed as the combination of known elements, each performing its known function.

4. Key Claim Construction Positions

  • "proximity detection module": Petitioner proposed this term be construed as "a module (software or firmware) that determines the presence of a user or device, or the proximity of a user or device, based on data received." This construction was central to the petition's arguments, as it is broad enough to encompass server-side components (like Richton's "location-action server") or distributed software, rather than being limited to a specific hardware component on a thermostat or mobile device.
  • "network device": Petitioner proposed construing this term as "a physical component that is connectable to a communications interface." This broad interpretation was asserted to be consistent with the patent’s disclosure of various devices, including cable modems and wireless air dampers, and was crucial for mapping the claims onto the diverse appliances and controllers found in the prior art.
  • "zone": Petitioner proposed this term means "a defined geographical area." This construction supports the argument that the simple distance-based thresholds disclosed in the prior art (e.g., within 5 miles of a target) meet the claim limitation for detecting a mobile device within a "zone."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 8,457,797 as unpatentable.