PTAB

IPR2015-01703

Apple Inc v. TracBeam LLC

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1. Case Identification

2. Patent Overview

  • Title: Location Determination for Cellular Phones
  • Brief Description: The ’231 patent discloses a network-based system for determining the location of a mobile station using cellular geolocation. The system uses measurements from wireless signals communicated between a mobile station and a network of base stations and is designed to employ a plurality of different location techniques to increase accuracy.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bruno and Olsson - Claims 3, 6-7, 11, 20, 24, 39, and 78 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: Petitioner argued that Bruno disclosed a hybrid mobile location system that combined multiple techniques, including cellular timing measurements, GPS, and short-range RF "Signposts." To meet claim limitations related to pattern recognition and the use of archived location data, Petitioner combined Bruno with Olsson. Olsson allegedly taught using a neural network that collects GPS and cellular data to create an "archive" of reference locations, which it then uses with pattern recognition techniques to determine a mobile device's position based on its cellular signal measurements.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the neural network and pattern recognition techniques of Olsson with Bruno’s hybrid system to improve the accuracy of Bruno's location estimates. Bruno’s system explicitly sought to "supplement" and "augment" GPS, and Olsson's accuracy-enhancing techniques provided a known method to do so.
    • Expectation of Success: Petitioner asserted the combination would yield predictable results, as applying Olsson's known accuracy-improving techniques to Bruno's hybrid system was a straightforward implementation of known technologies to achieve a known goal.

Ground 2: Obviousness over Loomis - Claims 1, 17-18, 20, 25, 27, 40, 72, 78, 81, 155, 162, and 215 are obvious over Loomis.

  • Prior Art Relied Upon: Loomis (Patent 5,936,572).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Loomis alone rendered a majority of the challenged claims obvious. Loomis described a "Portable Hybrid Location Determination System" embodied in a mobile station with two distinct location determination (LD) units. One unit, the "outdoor LD unit," was a satellite-based determiner (e.g., GPS), analogous to the claimed first location determiner. The second unit, the "radio LD unit," used terrestrial radio signals, analogous to the claimed second location determiner. Loomis further disclosed combining measurements from the two LD units or selecting between them to generate a final, resulting location estimate.
    • Key Aspects: Petitioner acknowledged that Loomis did not extensively detail the use of satellite timing data for location estimates. However, it was argued that using signal time-of-arrival was the standard, if not only, technique for satellite position acquisition at the time, and its implementation would have been obvious to a POSITA.

Ground 3: Obviousness over Loomis and Stjernholm - Claims 3, 6, 7, and 11 are obvious 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 built upon the hybrid system of Loomis by adding Stjernholm to teach the "pattern-recognition location technique" recited in claims 3, 6, 7, and 11. Stjernholm disclosed a method where wireless signal characteristics (e.g., signal strength) from mobile stations at known locations are recorded to create a database. Signals from a mobile station at an unknown location are then correlated against this database to determine its position.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Stjernholm’s technique into the Loomis system because Loomis explicitly taught that its satellite-based system could be augmented with "any of various known terrestrial techniques" for improved performance. Petitioner argued Stjernholm's pattern-recognition method was precisely such a well-known terrestrial technique.
    • Expectation of Success: Petitioner asserted that combining a known terrestrial location technique (Stjernholm) with a hybrid system expressly designed to incorporate such techniques (Loomis) was a simple combination of familiar elements that would yield predictable and improved results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds that claims 1, 17, 40, and 72 are obvious over Bruno alone; that other claims are obvious over Bruno in view of Geier (Patent 5,202,829), which taught weighting multiple GPS estimates to improve accuracy; and that other claims are obvious over Loomis in view of Olsson.

4. Key Claim Construction Positions

  • Petitioner argued that numerous, similarly-worded claim terms related to location should be construed together to mean simply "information that pertains to location." These terms included "location related information," "geographical indications," "location estimate," and "geographical location approximation." Petitioner contended that these terms were added at different times during a lengthy prosecution history and that the specification did not support materially distinct meanings for them.
  • Similarly, Petitioner argued that the terms "pattern recognition location technique" and "pattern matching technique" should be construed as being the same type of location technique.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 3, 6-7, 11, 17-18, 20, 24-25, 27, 39-40, 72, 78, 81, 155, 162, 165, and 215 of the ’231 patent as unpatentable.