PTAB

IPR2015-01695

Apple Inc v. TracBeam LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Location Determination for Cellular Phones
  • Brief Description: The ’327 patent relates to a network-based system for determining the location of a mobile communication device. The system uses measurements from wireless signals communicated between the device and multiple base stations and is designed to employ a plurality of different location techniques to improve overall accuracy.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-4, 17-19, 60-61, 67, 72, and 76 over Bruno in view of Geier

  • Prior Art Relied Upon: Bruno (Patent 5,604,765) and Geier (Patent 5,202,829).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bruno disclosed the core concept of a hybrid location system that combines multiple independent location-detection techniques to determine the position of a mobile unit, including cellular timing measurements, GPS, and short-range RF "signposts." Bruno’s system receives estimated location information from these different sources and combines them to produce a resulting location. Petitioner contended that Geier addressed the problem of improving the accuracy of location estimates derived from multiple sources, specifically in the context of GPS. Geier taught performing statistical analysis to weight different pseudo-range measurements and combining the weighted results to produce a more accurate final location. Geier also disclosed displaying an "error ellipse" to visually convey the statistical quality and reliability of the location estimate to a user.
    • Motivation to Combine: A POSITA would combine Geier’s weighting and error-reporting techniques with Bruno’s hybrid system to achieve a known goal: improving the accuracy of the final location estimate. Geier’s teachings on weighting estimates and conveying their reliability provided a direct solution to improving the performance of a multi-source system like Bruno’s.
    • Expectation of Success: Petitioner asserted that both references operate in the same field of location determination. Because Bruno’s system already employed a GPS back-end, incorporating Geier’s GPS-focused technique of weighting estimates would have been straightforward and yielded the predictable result of a more accurate location output.

Ground 2: Obviousness of Claims 6, 24-25, 47, 50, 54, 62, and 69 over Bruno, Geier, and Olsson

  • Prior Art Relied Upon: Bruno (Patent 5,604,765), Geier (Patent 5,202,829), and Olsson (Patent 5,564,079).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Bruno and Geier by adding the teachings of Olsson for claims reciting a "pattern detection process." Petitioner argued that Olsson disclosed using a neural network for pattern recognition to identify a mobile device’s location. In Olsson, a vehicle equipped with GPS collected location data and corresponding cellular signal measurements to train the neural network. The trained network could then estimate a mobile device's location by analyzing patterns in its live cellular signal measurements and comparing them to the archived training data.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Olsson's neural network and pattern recognition method as an additional location technique within the hybrid framework of Bruno. Bruno’s stated goal was to augment and supplement GPS with other techniques to improve accuracy. Olsson provided an advanced, known method for location determination that would serve this purpose.
    • Expectation of Success: Adding Olsson’s pattern recognition technique to the Bruno/Geier system was a predictable combination of known technologies to enhance accuracy. A POSITA would have reasonably expected that integrating another robust location-finding method into a hybrid system would improve its overall performance and versatility.

Ground 3: Obviousness of Claims 6, 24, and 25 over Loomis in view of Stjernholm

  • Prior Art Relied Upon: Loomis (Patent 5,936,572) and Stjernholm (Patent 5,418,843).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring pattern recognition using a different base reference. Petitioner asserted Loomis disclosed a portable hybrid location system using at least two different location determiners: a satellite-based unit (e.g., GPS) and a terrestrial-based radio signal unit. Loomis explicitly taught that its system could be modified to incorporate other known location techniques, such as Loran-C. To satisfy the pattern-recognition limitations, Petitioner combined Loomis with Stjernholm, which taught a pattern-recognition technique where wireless signal characteristics from mobile stations at known locations are recorded. Signals from devices at unknown locations are then correlated against this recorded data to determine their position.
    • Motivation to Combine: The motivation was a simple substitution of a known element for a similar element to obtain predictable results. A POSITA reading Loomis, which expressly contemplated substituting or adding various location techniques to its hybrid system, would have found it obvious to incorporate the known pattern-recognition technique taught by Stjernholm as one of the location determiners.
    • Expectation of Success: Combining these references was merely applying a known technique (Stjernholm's pattern recognition) to a known system (Loomis's hybrid platform) that was designed to accommodate such additions. The result would have been a predictable improvement in the versatility and redundancy of the location system.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge based on Loomis as a standalone reference for a broader set of claims, arguing it inherently taught using multiple distinct location techniques (satellite vs. terrestrial radio) and combining their outputs.

4. Key Claim Construction Positions

  • Petitioner argued that several similarly-worded claim terms related to location—such as "geographic location information," "actual geographic location," "geographical extent," and "potential geographic location"—should be construed collectively under the broadest reasonable interpretation standard. Petitioner contended that the specification of the ’327 patent did not provide distinct definitions for these terms and that they should all be interpreted to mean simply "information that pertains to location." This broad construction was central to Petitioner’s argument that the prior art met these limitations without needing to disclose nuanced variations of location data.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 6, 17-19, 24-25, 47, 50, 54, 60-62, 67, 69, 72, and 76 of the ’327 patent as unpatentable.