PTAB

IPR2015-01444

Samsung Electronics Co., Ltd. v. IXI IP, LLC

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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), such as one using Bluetooth, and a wide area network (WAN), such as the Internet, via a cellular network. The gateway manages service discovery and access between devices on the PAN and the WAN.

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 under 35 U.S.C. §103.

  • 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: a mobile phone acting as a gateway between a local ad-hoc Bluetooth network (the PAN) and an external 3G wireless IP network (the WAN). The gateway in Marchand has two IP addresses (one public, one private) and performs network address translation (NAT). Petitioner asserted that a person of ordinary skill in the art (POSITA) would modify Marchand by incorporating the teachings of Nurmann, which discloses a gateway with a DHCP server to automatically allocate private IP addresses to devices on a local network, and Vilander, which teaches a GPRS network allocating a public IP address to a mobile terminal. The combination allegedly taught all limitations of independent claim 1, including the gateway allocating a second address (private IP) to a local device while being provided a first address (public IP) from the cellular network.
    • Motivation to Combine: A POSITA would combine these references to improve the functionality of Marchand's system using known, predictable techniques. Adding Nurmann’s DHCP functionality would provide a standard method for managing private IP addresses, preventing conflicts. Incorporating Vilander’s method for obtaining a public IP from the GPRS network was merely applying a known technique to a similar system to yield a predictable result.
    • Expectation of Success: The combination involved applying standard networking protocols (DHCP, GPRS IP allocation) to a gateway system for their conventional purposes, leading to a high expectation of success.

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

  • Prior Art Relied Upon: Marchand (WO 01/76154), Nurmann (’642 patent), Vilander (’635 patent), and RFC 2543 (a 1999 Internet standards document for SIP).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address claim 5, which added a domain naming service (DNS) software component. Petitioner argued that Marchand disclosed a SIP client on its gateway device to enable cellular calls. RFC 2543, the defining standard for SIP, taught that a SIP client queries a DNS server to translate a human-readable name (e.g., company.com) into an IP address.
    • Motivation to Combine: A POSITA implementing the SIP client disclosed in Marchand would naturally look to the SIP standard (RFC 2543) to implement its full capabilities, including DNS resolution. This was presented as a straightforward implementation of a standard protocol to achieve its known function.

Ground 3: Obviousness over Marchand, Nurmann, Vilander, and Larsson - Claims 6 and 23 are obvious over the combination of Ground 1 and Larsson.

  • Prior Art Relied Upon: Marchand (WO 01/76154), Nurmann (’642 patent), Vilander (’635 patent), and Larsson (Patent 6,836,474).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted claims 6 and 23, which required a security software component (e.g., firewall or VPN) to control access. Larsson disclosed a gateway with a firewall and two-stage proxy system for providing secure, authenticated access for a mobile terminal to a private network. Petitioner argued this security architecture would be added to the Marchand gateway.
    • Motivation to Combine: A POSITA would be motivated to add Larsson's security features to the Marchand gateway to provide secure access between the untrusted cellular network and the trusted local ad-hoc network. This was framed as adding a known solution to a known problem (network security) to improve the system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including:

    • Ground 4: Claims 12, 15, 22, 34, 39, 40, 42, and 46 are obvious over Marchand, Nurmann, Vilander, and the JINI Specification. This ground argued that Marchand’s use of JINI technology would be fully implemented according to the JINI Spec., which teaches plug-and-play service discovery, registration via a Lookup Service (LUS), and searching for services by class, attribute, or instance.
    • Ground 5: Claims 25 and 28 are obvious over Marchand, Larsson, and the JINI Specification. This ground combined the security teachings of Larsson with the service architecture of the JINI Spec.

4. Key Claim Construction Positions

  • "identifies whether the service is available at a particular time" (Claim 4): Petitioner argued this phrase should be construed broadly to encompass the mere registration of a service. The petition contended that according to the ’033 patent’s specification, registration describes services that are available at a particular time, even if not currently accessible. This broad construction allowed Petitioner to map prior art service discovery mechanisms (like Marchand’s JINI LUS, which lists registered services) to the claim limitation.

5. Relief Requested

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