PTAB

IPR2016-00573

AMX LLC v. Chrimar Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Detecting and Controlling Power in Network Equipment
  • Brief Description: The ’838 patent describes a central piece of network equipment, such as a switch or hub, that includes an Ethernet connector. The system is designed to detect different magnitudes of DC current flow through the connector's contacts and, in response to a specific magnitude, control an electrical condition, such as supplying power to a connected end device.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 7, 26, 29, 38, 40, 47, 55, and 69 are anticipated by or obvious over Katzenberg.

  • Prior Art Relied Upon: Katzenberg (Patent 6,218,930).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Katzenberg discloses every limitation of the challenged claims. Katzenberg describes a system for automatically detecting and remotely powering equipment over an Ethernet network. Its "network data node" or 8-port Ethernet switch constitutes the claimed "central piece of network equipment" with an RJ45 Ethernet connector. The system detects if a connected device can accept power by delivering a low-level current and measuring the voltage drop in the return path. A varying "sawtooth" voltage drop indicates different magnitudes of DC current, signifying a compatible device. In response to detecting this specific sawtooth pattern, the system controls an electrical condition by delivering full remote power over the data signaling pairs. Petitioner asserted this mapping meets all limitations of independent claim 1, and that Katzenberg’s disclosure of using this detection scheme as part of a protocol to distinguish compatible from incompatible devices meets the limitations of the challenged dependent claims.
    • Key Aspects: This ground relies on the assertion that Katzenberg’s filing date (March 1999) predates the effective priority date of the ’838 patent.

Ground 2: Claims 1, 2, 7, 26, 29, 38, 40, 47, 55, and 69 are obvious over De Nicolo ’468 in view of De Nicolo ’666.

  • Prior Art Relied Upon: De Nicolo ’468 (Patent 6,115,468) and De Nicolo ’666 (Patent 6,134,666).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that De Nicolo ’468 teaches a "central piece of network equipment" for supplying DC power to remote Ethernet telephones over existing 4-wire connections using Ethernet connectors. However, ’468 lacks a specific mechanism for detecting device power requirements. De Nicolo ’666 remedies this by teaching a power supervisor that detects a remote module's power requirement by measuring current magnitudes on a query conductor; the current varies based on a resistor in the module. The supervisor then controls the application of power based on this detection. Petitioner argued that combining ’666’s detection and control logic with ’468’s Ethernet power delivery system would result in the claimed invention.
    • Motivation to Combine: A POSITA would combine these references to improve the basic power delivery system of De Nicolo ’468 with the more sophisticated device-detection and power-management capabilities of De Nicolo ’666. The motivation is strengthened because both patents share the same inventor, making it natural for a POSITA to review them together to understand the inventor’s related work in powering remote devices.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves the straightforward integration of known electronic modules—'666’s power supervisor into ’468’s power supply—to achieve the predictable result of a more intelligent Power over Ethernet system.

4. Key Claim Construction Positions

  • "BaseT": Petitioner argued the term "BaseT" in the phrase "BaseT Ethernet communication signals" should be construed to mean "10BASE-T." This construction is based on the consistent usage within the ’838 patent specification and its incorporated-by-reference provisional application, where the term "BaseT" appears only within the specific phrase "10BASE-T."

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central technical contention was that the ’838 patent is not entitled to its claimed April 10, 1998, priority date from the ’279 provisional application. Petitioner argued the ’279 provisional fails to provide adequate written description for the limitation of controlling an electrical condition "in response to at least one of the magnitudes of the DC current flow." This is because the provisional’s sole disclosed communication method, Manchester encoding, relies on detecting transitions between high and low levels (i.e., multiple magnitudes) to convey any information, making a control decision based on a single magnitude impossible under its teachings. This argument is critical to establishing both Katzenberg and the De Nicolo references as prior art.

6. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 2, 7, 26, 29, 38, 40, 47, 55, and 69 of the ’838 patent as unpatentable.