PTAB

IPR2016-00574

AMX LLC v. Chrimar Systems Inc

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: BaseT Ethernet System
  • Brief Description: The ’760 patent describes a BaseT Ethernet system that uses existing network wiring to detect and identify connected devices. The system employs a central equipment piece with a DC supply that creates a current loop over conductor pairs to a terminal equipment piece, which can draw different current magnitudes to communicate information back to the central equipment.

3. Grounds for Unpatentability

Ground 1: Obviousness over De Nicolo Combination - All challenged claims 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 argued that De Nicolo ’468 discloses the fundamental structure of the challenged claims: a BaseT Ethernet system for supplying DC power over twisted-pair conductors from a central equipment piece (e.g., power supply 144) to a remote terminal device (e.g., load 98 and power processor 149). This reference teaches the central and terminal equipment, the data signaling pairs, the DC supply, and a path for current flow. Petitioner contended that De Nicolo ’666 teaches the specific functional elements missing from ’468. Specifically, ’666 discloses a power supervisor that detects at least two different magnitudes of current from a remote module to determine its power requirements and controls the application of an electrical condition (voltage) to the module. The different current magnitudes are generated based on whether a transistor (Q1) is enabled, which a microprocessor (24) detects.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to improve the power delivery system of De Nicolo ’468. De Nicolo ’666 provides a known technique for determining a remote device’s power requirements. A POSITA would incorporate this technique into the Ethernet-based power system of ’468 to provide power more efficiently and selectively, satisfying the specific needs of the remote device. Petitioner noted that both patents share the same sole inventor, making it more likely a POSITA would consider their teachings together.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining the power detection and control circuitry of ’666 with the power delivery system of ’468 would be a routine integration of known electronic components for their intended purposes.

Ground 2: Obviousness over Auto-Negotiation References - All challenged claims are obvious over Patel in view of the DP83840 Datasheet and IEEE standards.

  • Prior Art Relied Upon: Patel (Patent 5,883,894), the DP83840 Data Sheet (a 1996 National Semiconductor technical datasheet), IEEE 802.3u-1995, and IEEE 802.3-1993.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of Auto-Negotiation references discloses all claim limitations. Patel describes a system with central equipment (network intermediate device 100) and terminal equipment (end stations 107) that use the Auto-Negotiation protocol. The DP83840 Datasheet provides chip-level implementation details for such equipment. The functional limitations are met by the inherent operation of the Auto-Negotiation protocol defined in the IEEE standards. This protocol uses Fast Link Pulse (FLP) bursts, which consist of a series of current pulses and non-pulses transmitted over the conductor loop. The presence or absence of a pulse creates at least two different magnitudes of current. A receiving device detects these different current magnitudes to interpret the FLP burst. The transmitting device applies a voltage to the conductors to create the pulses, thereby controlling an electrical condition.
    • Motivation to Combine: A POSITA would combine these references as they all operate in the same field and are designed to work together. The Patel system patent and the IEEE standards describe the Auto-Negotiation protocol, while the DP83840 Datasheet provides a known commercial chip for implementing that exact protocol. A POSITA would naturally look to the datasheet and the underlying standard to implement the system disclosed in Patel. This combination was argued to be a common-sense design choice for creating a functional, standard-compliant Ethernet device.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves implementing a standardized protocol (from IEEE) in a system (from Patel) using a chip specifically designed for that purpose (from the DP83840 Datasheet).

4. Key Claim Construction Positions

  • "BaseT": Petitioner argued that the term "BaseT" should be construed to mean "10BASE-T." This construction is based on the consistent use of the term within the ’760 patent’s specification and in the prior art patents it incorporates by reference (e.g., the ’260 patent), which only use "BaseT" as part of the phrase "10BASE-T." This construction is critical for mapping the claims to prior art focused on that specific Ethernet standard.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date: Petitioner contended that the challenged claims are not entitled to a priority date earlier than April 8, 1999, the filing date of the priority PCT application. Petitioner argued that the Patent Owner’s asserted earlier priority date (based on a 1998 provisional application) fails because the provisional application lacks written description support for key limitations, such as "detect[ing] at least two different magnitudes of the current flow," which is recited in every challenged claim. This contention is central to establishing that the De Nicolo references, filed in March 1998, qualify as prior art.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 31, 37, 58, 59, 69, 72, 73, 106, 112, 134, 142, and 145 of the ’760 patent as unpatentable.