PTAB

IPR2015-01701

Apple Inc v. TracBeam LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Location Determination for Cellular Phones
  • Brief Description: The ’153 patent discloses a network-based location system that uses cellular geolocation to determine the position of a mobile station. The system employs a plurality of different location estimators, referred to as "first order models" (FOMs), which can be based on techniques such as distance models, pattern recognition, and adaptive learning, to generate multiple location estimates that are then processed to determine a final, more accurate location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bruno and Geier - Claims 2, 23, and 24 are obvious 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 discloses the core method of the ’153 patent, teaching a hybrid system that combines multiple independent location-detection techniques (cellular timing measurements, GPS, and RF signposts) to determine a mobile unit's location. Bruno’s system generates location estimates from these different techniques. Geier, in the context of a GPS-based ship location system, teaches improving accuracy by performing statistical analysis to weight different estimates and displaying the final location on a map with an "error ellipse" to visually convey the confidence level of the estimate.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Geier’s teachings with Bruno’s system to improve the accuracy of the location estimate and to provide the user with a quick, intuitive understanding of that accuracy. Adding a visual representation of confidence (Geier's error ellipse) to the location estimate produced by a hybrid system (Bruno) was a known method for improving usability.
    • Expectation of Success: Both references operate in the field of location detection by combining multiple inputs. Applying Geier's well-understood statistical weighting and display techniques to the location estimates generated by Bruno's system would have been a straightforward implementation yielding the predictable result of an improved and more user-friendly location system.

Ground 2: Obviousness over Bruno and Olsson - Claims 17, 18, 35, 37-39, and 42 are obvious over Bruno in view of Olsson.

  • Prior Art Relied Upon: Bruno (Patent 5,604,765) and Olsson (Patent 5,564,079).
  • Core Argument for this Ground:
    • Prior Art Mapping: As the primary reference, Bruno provides the hybrid location system with multiple estimators. Olsson discloses a method for locating mobile stations using pattern recognition and a trainable neural network. In Olsson, a measuring vehicle collects cellular signal data and corresponding GPS location data, which is used to train the neural network. The trained network then estimates a mobile station’s location by recognizing patterns in its current cellular signal measurements. This corresponds to the ’153 patent’s claims reciting a pattern recognition location technique.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Olsson's sophisticated pattern recognition and neural network capabilities into Bruno's hybrid system to "supplement" and "augment" its location-finding abilities. Bruno's goal was to improve accuracy, and adding an advanced, data-driven estimator like the one taught by Olsson was a known path to achieving higher precision.
    • Expectation of Success: Combining a neural network-based estimator with other location techniques was a known approach in the art. A POSITA would have reasonably expected that adding Olsson’s pattern recognition technique to Bruno’s multi-faceted system would predictably enhance its overall accuracy.

Ground 3: Obviousness over Loomis - Claims 1, 3, 6, 7, 15, 23, 27, 29, and 35-39 are obvious over Loomis.

  • Prior Art Relied Upon: Loomis (Patent 5,936,572).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Loomis discloses a portable hybrid location system within a single mobile station containing two independent location determination ("LD") units: a satellite-based "outdoor LD unit" and a terrestrial radio signal-based "radio LD unit." Loomis teaches that the system can select between the outputs of the two units or combine them to generate a final location estimate, similar to the independent estimators of the ’153 patent.
    • Motivation to Combine: While Loomis discloses using FM subcarrier signals for its terrestrial unit, it also acknowledges the presence of cellular communication infrastructure. Petitioner argued that a POSITA would find it obvious to use the existing cellular communication infrastructure for positioning signals instead of a separate FM broadcast system. The motivation would be significant economic savings and efficiency gained by leveraging a single, ubiquitous network, representing a simple and predictable substitution of one known element for another.
    • Expectation of Success: Given that cellular signals were known to be usable for positioning, modifying Loomis to use the cellular network for its terrestrial LD unit would have been a straightforward design choice with a high expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Bruno, Olsson, and Geier for claim 36. Further grounds relied on Loomis in view of LeBlanc (Patent 5,602,903) for displaying location information on a map with accuracy data, and Loomis in view of Olsson for using prior location data to calibrate the system.

4. Key Claim Construction Positions

  • General Location Terms: Petitioner argued that several terms added during prosecution—such as "information related to likely geographical approximations," "location estimate," and "geographical location"—are not materially distinct from one another. Under the broadest reasonable construction standard, these terms should all be interpreted to simply mean "information that pertains to location."
  • Dependent Claim 6: Petitioner contended that claim 6, which recites first and second estimators performing "different location determining computational techniques," should be construed as relating to distinct estimators that operate independently. Petitioner argued the claim does not require the estimators to operate differently when provided with identical input data, as the specification shows different models receiving different input data from a signal processing subsystem.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-3, 6-7, 15, 17-18, 20, 23-24, 27, 29, 35-39, and 42 of the ’153 patent as unpatentable.