PTAB

IPR2016-00740

ADT LLC v. Script Security Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Alarm System for Detecting and Reporting Movement
  • Brief Description: The ’078 patent discloses an alarm system for detecting the movement of an object (e.g., a door or window). The challenged claims relate to an "enhanced version" of the system comprising a wireless movement detector, an information gathering device (e.g., a camera) that activates upon receiving a signal from the detector, and a remote notification device that transmits gathered information to a remote host over a network.

3. Grounds for Unpatentability

Ground 1: Claims 1-10 are obvious over Monroe

  • Prior Art Relied Upon: Monroe (Patent 6,970,183).

  • Core Argument for this Ground: Petitioner argued that Monroe, which discloses a comprehensive wireless multimedia surveillance system, teaches every element of the challenged claims. The petition detailed how two distinct embodiments within Monroe—an "Entry Door Embodiment" and a "Pressure Mat Embodiment"—each render the claims obvious. The core of the argument relied on the obvious substitution of wired components with wireless equivalents, a practice explicitly contemplated within Monroe for improved system reliability.

    • Prior Art Mapping (Independent Claim 1):

      • Entry Door Embodiment: Petitioner mapped the claim limitations to a combination of disclosures in Monroe. The "object" was an entry door, and the "detector" was a contact switch. Petitioner argued a POSITA would find it obvious to replace Monroe's wired contact switch (CN1) with its disclosed wireless door contact sensor (ADR4), which includes a "first transmitter." The "information gathering device" was mapped to two separate Monroe components: a wireless contact receiver that receives the signal from the door sensor, and a wireless camera that gathers video of the event. The "remote notification device" was identified as Monroe’s wireless access point, which receives information from the camera and establishes communication with the "remote host," identified as Monroe’s central security server.
      • Pressure Mat Embodiment: Alternatively, Petitioner argued Monroe’s pressure mat system also rendered the claims obvious. The "object" was the top layer of the pressure mat, and the "detector" was the internal contact switch. The pressure mat's inherent wireless transmitter served as the "first transmitter." Monroe’s wireless camera was identified as the single "information gathering device," as it is adapted to receive the signal from the mat, gather video, and transmit the information. As with the other embodiment, the wireless access point and central security server were mapped to the "remote notification device" and "remote host," respectively.

    • Motivation to Combine: The argument was not a combination of different references but rather an obvious combination of elements within Monroe itself. Petitioner argued a POSITA would be motivated to substitute wired components (door sensor, camera) with their wireless counterparts as disclosed in Monroe. Monroe itself provided the motivation by teaching a system using a "combination of wired and wireless appliances" and noting that "hardwired network[s]" can be "interrupted," making wireless alternatives desirable for reliability.

    • Expectation of Success: Petitioner asserted that substituting known wireless components for wired ones within Monroe's system was a "mere application of a known technique" that would have yielded predictable results and therefore carried a high expectation of success.

    • Dependent Claims Mapping: Petitioner argued that Monroe also taught the additional limitations of dependent claims 2-10, including the use of a digital camera with memory (claim 3), a wireless transmitter in the information gathering device (claim 4), a wireless receiver in the remote notification device (claim 5), and various network interfaces for communicating with the remote host (claims 6-9). For claim 10, Monroe's disclosure of cameras with microphones was alleged to teach the transmission of "one or more of image information and audio information."

4. Key Claim Construction Positions

  • "information gathering device": Petitioner argued that, consistent with the Patent Owner's infringement contentions in related litigation, this term should be construed to mean "one or more physical components adapted to gather information." This construction was critical to the obviousness argument for the Entry Door Embodiment, which maps the single claimed "device" to two separate physical components in Monroe: a wireless receiver and a wireless camera.
  • "remote notification device": Petitioner proposed construing this term as "a device that provides the received information to the remote host, either directly or indirectly." This construction was intended to encompass embodiments in both the patent and the prior art where the device first communicates with a local computer or firewall, which then establishes the final connection to the remote host.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Entitlement: A central contention of the petition was that the challenged claims were not entitled to the benefit of their earliest claimed priority dates. Petitioner argued that the parent applications, specifically the March 1999 application, failed to provide written description support for key limitations of the "enhanced system," such as the "information gathering device" and "remote notification device" recited in claim 1. By successfully arguing for a later effective priority date of February 16, 2001, Petitioner established that Monroe, filed on June 14, 2000, qualifies as prior art under pre-AIA 35 U.S.C. §102(e). This argument was a necessary predicate for the entire obviousness challenge.

7. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-10 of the ’078 patent as unpatentable.