PTAB

IPR2015-01725

Samsung Electronics Co v. Mobile Telecommunications Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Automated Business Data Processing System
  • Brief Description: The ’210 patent discloses a system for managing a multi-location business, such as a franchise. The system uses a central computer that communicates with remote data processing units to collect, process, and manage business information like sales, inventory, and ordering data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Scull and Levine - Claims 1-10 are obvious over Scull in view of Levine.

  • Prior Art Relied Upon: Scull (Patent 5,761,662) and Levine (Patent 5,594,911).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Scull discloses all major elements of the challenged claims, including a central computer communicating with remote processing units to manage a franchise business. Scull specifically teaches collecting sales and inventory data from remote locations, processing it centrally, and generating reports. However, Petitioner contended that Scull's communication method was less detailed. Levine was introduced to supply the teaching of a network sales information system where a central computer communicates with remote point-of-sale (POS) terminals to collect and process data in a networked environment. Petitioner asserted Levine explicitly teaches transmitting sales data from remote terminals to a central database for processing, thus satisfying any specific data transmission limitations of the ’210 patent not explicitly detailed in Scull.
    • Motivation to Combine: A POSITA would combine Scull's franchise management system with Levine's networked data collection methods to improve the efficiency and timeliness of data gathering. The motivation stemmed from the recognized need in the art for centralized, automated business management systems that could leverage existing network infrastructure for real-time data analysis, a clear improvement over the batch-processing methods implied in Scull. Combining Levine's robust network communication with Scull's business logic was presented as a predictable and desirable integration.
    • Expectation of Success: A POSITA would have a high expectation of success because integrating known network data transmission techniques (Levine) with existing business management software platforms (Scull) was a routine practice at the time, utilizing standard hardware and communication protocols.

Ground 2: Obviousness over Scull, Levine, and E-Data - Claims 1, 2, 4-7, 9, and 10 are obvious over Scull in view of Levine and E-Data.

  • Prior Art Relied Upon: Scull (Patent 5,761,662), Levine (Patent 5,594,911), and E-Data (Patent 4,528,643).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on the base combination of Scull and Levine as established in Ground 1. E-Data was added to provide an explicit teaching for the limitation of "transmitting product ordering information" from the central computer to remote units. Petitioner argued that E-Data discloses a general-purpose system for electronically distributing information (e.g., data, software) from a central source to remote locations where it can be used or reproduced.
    • Motivation to Combine: The motivation to add E-Data's teachings to the Scull/Levine combination was to enable a fully automated inventory and ordering cycle. A POSITA, having already created a system for collecting sales data (per Scull and Levine), would naturally seek to use that system to automatically generate and distribute purchase orders back to the remote locations. E-Data provided a well-known method for such electronic information distribution, making it a logical component to complete the automated business management system.
    • Expectation of Success: Success was expected as E-Data's system for distributing information was designed to be broadly applicable and would require only conventional adaptation to transmit ordering data instead of other forms of information.

Additional Grounds

Petitioner asserted additional obviousness challenges against claims 1-10 based on the combination of Scull, Levine, and Martin (Patent 5,499,313), arguing Martin further taught specific user interface and data display functionalities.

4. Key Claim Construction Positions

  • "Data Processing Unit": Petitioner argued this term should be construed broadly to mean a general-purpose computer or terminal capable of performing the claimed functions, such as transmitting and receiving data. This construction was crucial for ensuring the remote terminals disclosed in the prior art (e.g., the POS terminals in Levine) met the claim limitation. Petitioner contended that the patent specification did not provide any special definition that would limit the term to a more specific or specialized device.
  • "Automatically Generating Product Ordering Information": Petitioner proposed this phrase be construed to mean the system generates the ordering information without contemporaneous human input, based on pre-programmed rules (e.g., inventory falling below a set threshold). This interpretation was intended to encompass the automated reporting and data processing capabilities described in Scull, which Petitioner argued would inherently include the logic for determining when new products needed to be ordered.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 of the ’210 patent as unpatentable under 35 U.S.C. §103.