PTAB

IPR2015-01444

Samsung Electronics Co Ltd v. IXI IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System, Device and Computer Readable Medium for Providing a Managed Wireless Network Using Short-Range Radio Signals
  • Brief Description: The ’033 patent describes a gateway device that provides wireless communication between a short-range Personal Area Network (PAN) and a wide area cellular network (WAN). The gateway connects local terminals via technologies like Bluetooth and accesses the internet through the cellular network, managing services and data transfer between the two networks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Marchand, Nurmann, and Vilander - Claims 1, 4, 7, and 14 are obvious over Marchand in view of Nurmann and Vilander.

  • Prior Art Relied Upon: Marchand (WO 01/76154), Nurmann (Patent 6,560,642), and Vilander (Patent 6,771,635).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Marchand disclosed the core system of claim 1: a mobile phone acting as a gateway between a local, short-range ad-hoc network (Bluetooth Piconet) and an external 3G wireless IP network. Marchand’s gateway performs routing between the networks and uses JINI technology for service discovery. The gateway includes a network address translator (NAT) to handle a public IP address on the cellular side and private IP addresses on the local side. Marchand also disclosed a service repository (JINI Lookup Service or LUS) that identifies services provided by devices on the local network.
    • Motivation to Combine: A POSITA would combine the references to improve Marchand's system using known, predictable techniques. A POSITA would modify Marchand's gateway according to Vilander, which taught allocating a public IP address to a mobile terminal from a GPRS cellular network. This was a standard method for ensuring unique addresses on the public network. A POSITA would also modify Marchand’s gateway to act as a DHCP server as taught by Nurmann, allowing it to allocate private IP addresses to devices on the local ad-hoc network. This would centralize address management in the gateway, which already performs address translation, thereby avoiding IP address conflicts and routing errors.
    • Expectation of Success: The combination involved applying known networking principles (DHCP for local networks, GPRS for public IP allocation) to a known gateway architecture to achieve predictable improvements in network stability and management.

Ground 2: Obviousness over Marchand, Nurmann, Vilander, and RFC 2543 - Claim 5 is obvious over the combination of Ground 1 in view of RFC 2543.

  • Prior Art Relied Upon: Marchand (WO 01/76154), Nurmann (Patent 6,560,642), Vilander (Patent 6,771,635), and RFC 2543 (an Internet standards document for Session Initiation Protocol).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1. Marchand’s gateway already included a Session Initiation Protocol (SIP) client to enable calling capabilities. Claim 5 adds a domain naming service (DNS) software component to translate between a human-readable name and an IP address. RFC 2543, the standard for SIP, explicitly described a SIP client querying a DNS server to resolve a host name into an IP address to establish a session.
    • Motivation to Combine: A POSITA implementing the SIP client disclosed in Marchand would have been motivated to consult RFC 2543 to ensure standards compliance and full functionality. A POSITA would combine the standard DNS querying capability from RFC 2543 with Marchand's SIP client to implement a complete and functional SIP system, which was a known technique for improving such devices.
    • Expectation of Success: Integrating standard DNS functionality into a SIP client was a routine and well-understood task for a POSITA, with a high expectation of success.

Ground 4: Obviousness over Marchand, Nurmann, Vilander, and JINI Spec. - Claims 12, 15, 22, 34, 39, 40, 42, and 46 are obvious over the combination of Ground 1 in view of the JINI Spec.

  • Prior Art Relied Upon: Marchand (WO 01/76154), Nurmann (Patent 6,560,642), Vilander (Patent 6,771,635), and the JINI Spec. (a textbook describing the JINI architecture).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground argued that while Marchand disclosed using JINI technology, the JINI Spec. provided the necessary detail for its full implementation. The JINI Spec. described a complete "plug and play" architecture where a service provider registers with a Lookup Service (LUS) by providing a proxy object. A client can then search the LUS, download the proxy object, and execute it to access the service. This architecture directly mapped to the limitations of a "plug and play software component" (claim 12), searching the service list by "class, attribute and instance" (claims 22 and 39), and a third device obtaining a service from a second device (claim 15).
    • Motivation to Combine: A POSITA seeking to implement the JINI-based service discovery mentioned in Marchand would naturally turn to the JINI Spec. for the authoritative architectural details. The motivation was to fully realize the JINI technology already incorporated by Marchand, enabling each device on the network to register, search for, and execute services in a robust, standardized manner.
    • Expectation of Success: Combining the JINI Spec. with Marchand was merely the full implementation of a technology already chosen by the primary reference, leading to the predictable result of a functional JINI service network.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 6 and 23 are obvious over the Ground 1 combination in view of Larsson (Patent 6,836,474) for adding known security components like a firewall and proxy. Petitioner also argued claims 25 and 28 are obvious over Marchand in view of Larsson and the JINI Spec.

4. Key Claim Construction Positions

  • Petitioner argued for a broad construction of the phrase "identifies whether the service is available at a particular time" (claim 4). Petitioner contended that under the broadest reasonable interpretation, this phrase should encompass the mere fact of a service being registered with a service repository. This construction was supported by the patent’s specification and was crucial for mapping the functionality of the JINI LUS in the prior art, which contains a list of registered (i.e., "available") services, to the claim limitation.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) for claims 1, 4-7, 12, 14-15, 22-23, 25, 28, 34, 39-40, 42, and 46 of the ’033 patent and requests the cancellation of these claims as unpatentable.