PTAB

IPR2016-00808

Samsung Electronics Co., Ltd. v. KONINKLIJKE KPN N.V.

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1. Case Identification

  • Patent #: 8,886,772
  • Filed: March 30, 2016
  • Petitioner(s): Samsung Electronics Co., Ltd.
  • Patent Owner(s): Koninklijke KPN N.V.
  • Challenged Claims: 1, 2, 8-16

2. Patent Overview

  • Title: Remote Device Management System
  • Brief Description: The ’772 patent describes methods and systems for remote device management. The invention proposes an "auto-configuration server managing device" (ACSMD) that acts as a centralized intermediary, controlling a manageable electronic device's access to a plurality of "auto-configuration servers" (ACSs), thereby avoiding the need to pre-configure each device with a specific ACS address.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, and 10-16 are obvious over Bates.

  • Prior Art Relied Upon: Bates (Regis J. "Bud" Bates, GPRS, McGraw-Hill (2002)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the well-known architecture of a General Packet Radio Service (GPRS) network, as detailed in Bates, taught every element of the challenged claims. Petitioner asserted that Bates’s “mobile station” is the claimed “manageable electronic device.” The “plurality of auto-configuration servers (ACSs)” corresponds to the multiple Gateway GPRS Support Nodes (GGSNs) that Bates discloses can be deployed in a GPRS network to provide configuration data (e.g., an IP address and Quality of Service parameters). Crucially, Petitioner mapped the claimed “auto-configuration server managing device (ACSMD)” to Bates’s Serving GPRS Support Node (SGSN). Bates described the SGSN as a computer in a wide-area network that functions as an intermediary or relay. The SGSN receives an “Activate PDP Context Request” from the mobile station, authenticates the device by checking a database (such as a Home Location Register or HLR), selects an appropriate GGSN from a list, relays the request to the selected GGSN, receives a reply with configuration data from the GGSN, and relays that reply back to the mobile station. This process directly maps to the functionalities recited in independent claims 1, 10, 12, and 15, and dependent claims 2 and 16.

Ground 2: Claim 8 is obvious over Bates in view of Barakat.

  • Prior Art Relied Upon: Bates (2002) and Barakat (Application # 2003/0040310).
  • Core Argument for this Ground:
    • Prior Art Mapping: Dependent claim 8 requires the manageable electronic device to be on a local area network (LAN) coupled to the wide area network (WAN) via a specific signal carrier, such as a digital subscriber line (DSL). Petitioner argued that while Bates taught the general architecture of a mobile station in a cell (the LAN) connecting to a wider network (the WAN) via an "Abis interface," it did not specify the signal carrier for that interface. Barakat, which addresses improving performance in cellular networks, explicitly disclosed using an HDSL or DSL link for the Abis interface between a base station and its controller.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Barakat with Bates for the predictable purpose of increasing data throughput. Implementing a known high-speed connection technology (DSL) taught by Barakat for the generic Abis interface in Bates was an obvious design choice to improve network performance.
    • Expectation of Success: A POSITA would have had a high expectation of success, as applying a well-known, high-speed connection technology to a standard network interface to achieve improved speed is a routine and predictable engineering task.

Ground 3: Claim 9 is obvious over Bates in view of Bauchot and Applicant's Admitted Prior Art (AAPA).

  • Prior Art Relied Upon: Bates (2002), Bauchot (Patent 5,912,918), and AAPA.

  • Core Argument for this Ground:

    • Prior Art Mapping: Dependent claim 9 adds the limitation that the manageable electronic device has a "default address" for obtaining configuration data, with that address being the address of the ACSMD. Petitioner asserted that Bates did not expressly teach a "default address," but rather a connection via a specific channel (PRACH). The combination of Bauchot and AAPA supplied this element. The ’772 patent’s specification admitted that pre-configuring devices with a default address was a well-known practice (the AAPA). Bauchot further taught a method where a mobile station stores a base station address to efficiently select a "home station" in a multicellular network.
    • Motivation to Combine: A POSITA would be motivated to modify the system of Bates using the teachings of Bauchot and the knowledge from AAPA to simplify the initial network connection process for the mobile station. Using a default address to contact the ACSMD (the SGSN/BTS combination in Bates) was an obvious design choice to improve the efficiency and reliability of initiating packet transfer, a known problem solved by the techniques in Bauchot and AAPA.
    • Expectation of Success: A POSITA would reasonably expect success, as applying the well-known technique of using a default address for initial network access to the system in Bates would predictably simplify communication and device design.

  • Additional Grounds: Petitioner asserted an additional challenge to claim 8 as obvious over Bates in view of Yla-Mella (Patent 6,526,290), which, similar to Barakat, taught using an HDSL connection for the Abis interface to improve throughput. Petitioner also challenged claim 9 as obvious over Bates in view of AAPA alone.

4. Key Claim Construction Positions

  • "a plurality of auto-configuration servers (ACSs)": Petitioner argued this term should be construed as “two or more computers in the WAN, each of which automatically provides configuration data to a manageable electronic device in response to a request from it for configuration data.” This construction was based on the ’772 patent’s specification and its reliance on the TR-069 standard, and was critical for mapping the term to the multiple GGSNs disclosed in Bates.
  • "auto-configuration server managing device (ACSMD)": Petitioner argued this term should be construed as a “computer in the WAN which, in response to a request for configuration data, relays the request to the dedicated ACS, receives a reply with the requested configuration data from the dedicated ACS and transmits the reply to a manageable electronic device.” This construction focused on the specific intermediary and relay functions described for the second embodiment in the ’772 patent’s specification, allowing Petitioner to map the term to the SGSN in Bates.

5. Relief Requested

  • Petitioner requested institution of IPR and cancellation of claims 1, 2, and 8-16 of the ’772 patent as unpatentable.