PTAB

IPR2016-00742

ADT LLC v. Script Security Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Portable Security Alarm System
  • Brief Description: The ’909 patent discloses a portable security alarm system using multiple movement detectors that wirelessly signal a receiver when an object moves. The challenged claims relate to a feature where each detector transmits a unique identifier that is converted into human-readable "object identification information" (e.g., "FRONT DOOR") for display to a user, either locally or via a remote security administration system.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rietkerk and SX-V Owner's Manual - Claims 1-6, 9, 11-12

  • Prior Art Relied Upon: Rietkerk (Patent 5,748,083) and SX-V Owner's Manual (a 1991 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rietkerk disclosed all elements of independent claim 1 except for the local conversion and display of a unique identifier into object identification information. Rietkerk taught a portable security system with motion sensors (Asset Protection Devices or "APDs") that each have a unique ID and transmit an alarm signal to a local wireless receiver. Petitioner asserted that Rietkerk expressly identified the "Model SX-V Wireless Alarm Receiver" as a suitable component for its system. The SX-V Owner's Manual, in turn, taught that this specific receiver includes an alphanumeric display capable of processing a unique sensor number and displaying a corresponding, user-programmed name (e.g., displaying "40 ALARM-DEN DOOR"). The combination therefore allegedly taught a local receiver that processes a unique identifier for conversion to, and visual output of, object identification information.
    • Motivation to Combine: A POSITA would combine these references because Rietkerk explicitly suggested using the SX-V receiver in its system. This provided a direct and compelling reason to consult the SX-V Owner's Manual to understand the receiver's full capabilities and integrate it into Rietkerk's system.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the primary reference expressly identified the component described in the secondary reference as being compatible.

Ground 2: Obviousness over Rietkerk, SX-V Owner's Manual, and SX-V Installation Manual - Claim 13

  • Prior Art Relied Upon: Rietkerk (Patent 5,748,083), SX-V Owner's Manual (1991), and SX-V Installation Manual (a 1993 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued claim 13 was obvious over the combination from Ground 1, further in view of the SX-V Installation Manual. Claim 13 adds a "programming means for receiving and storing" object identification information. Petitioner contended this means-plus-function language corresponds to a data entry interface and a data store. The SX-V Installation Manual provided detailed instructions showing how the SX-V receiver’s keypad and visual display (the data entry interface) are used to associate a sensor number with a custom name, which is then stored in the receiver’s CPU memory (the data store).
    • Motivation to Combine: A POSITA implementing Rietkerk's system with the suggested SX-V receiver would naturally consult both the Owner's and Installation manuals to fully utilize the product. The manuals are complementary documents for the same commercial product.
    • Expectation of Success: Success would be expected, as the references describe the integrated features of a single, commercially available product identified in the primary reference.

Ground 3: Obviousness over Rietkerk, SX-V Owner's Manual, and Saylor - Claims 15, 19-23, 26-29

  • Prior Art Relied Upon: Rietkerk (Patent 5,748,083), SX-V Owner's Manual (1991), and Saylor (Patent 6,400,265).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that this combination rendered obvious the claims directed to a remote security administration system that performs automated alerts and allows remote subscriber registration. While the Rietkerk/SX-V combination taught a basic remote monitoring station, Saylor taught a sophisticated central security network. Saylor’s system allowed users to register security devices over the internet, and its computer host was programmed to execute an automated security alert sequence (e.g., contacting a user’s phone with interactive options) in response to an alarm, without human intervention.
    • Motivation to Combine: A POSITA would combine the references to enhance the functionality of Rietkerk's conventional alarm system. Saylor explicitly stated its invention could be applied to existing systems to overcome their inflexibility, such as the inability to proactively contact a homeowner. Adding Saylor's network features would provide the significant benefit of automated, personalized notifications to the user of the Rietkerk system.
    • Expectation of Success: Saylor disclosed a clear mechanism for registering various security systems with its network, providing a clear path for integration and a high expectation of success.

4. Key Claim Construction Positions

  • "programming means for receiving and storing...": For claim 13, Petitioner argued this means-plus-function term should be construed based on the ’909 patent’s specification, with the corresponding structure being a data entry interface (e.g., keypad and display) and a data store (e.g., memory with a look-up table).
  • "location": For claims 19, 20, and 22, Petitioner asserted this term should be construed to include a telephone number or email address, based on explicit definitions in the ’909 patent’s specification.
  • "provisioned": For claims 12, 15, and 26, Petitioner argued this term should be construed to mean "provided by the subscriber," consistent with descriptions of a "provisioning program" in the specification.

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 priority dates of earlier-filed applications (dating back to 1996) listed on the face of the ’909 patent. Petitioner argued that the key concepts underlying all challenged claims—namely the use of a "unique identifier," corresponding "object identification information," and the "conversion" between them—were first disclosed in a continuation-in-part application filed on April 8, 2002. As the earlier applications allegedly lacked written description support for these limitations, Petitioner contended the effective filing date for all challenged claims is April 8, 2002, thus making Rietkerk, the SX-V manuals, and Saylor (filed 2001) valid prior art under 35 U.S.C. §102.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6, 9, 11-13, 15, and 19-29 of the ’909 patent as unpatentable.