PTAB

IPR2016-00808

Samsung Electronics Co Ltd v. Koninklijke KPN NV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remote Device Management
  • Brief Description: The ’772 patent discloses systems and methods for remotely managing electronic devices. The invention proposes an intermediary "auto-configuration server managing device" (ACSMD) that receives a configuration request from a device, selects an appropriate "auto-configuration server" (ACS) from a plurality of available servers, and relays communications between the device and the selected ACS.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Bates (Regis J. “Bud” Bates, GPRS, published by McGraw-Hill in 2002).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the claimed system is an obvious implementation of the well-known General Packet Radio Service (GPRS) architecture described in Bates. Bates’s mobile station was equated to the claimed "manageable electronic device." The Gateway GPRS Support Nodes (GGSNs), which provide configuration data (e.g., an IP address) to mobile stations, were argued to be analogous to the claimed "plurality of auto-configuration servers" (ACSs). The Serving GPRS Support Node (SGSN), which acts as an intermediary by receiving requests from the mobile station, selecting the appropriate GGSN, and relaying messages, was mapped to the claimed "auto-configuration server managing device" (ACSMD). Bates also disclosed databases like the Home Location Register (HLR) used by the SGSN to identify and authenticate the mobile station, meeting the database limitations of the claims.
    • Motivation to Combine (for §103 grounds): This ground relies on a single reference. The motivation was to apply the known GPRS architecture for its intended purpose of managing and configuring remote devices.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success as this ground asserted that the claimed invention was merely a relabeling of existing, functional components of the GPRS network standard.

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

  • Prior Art Relied Upon: Bates (a 2002 publication) and Barakat (Application # 2003/0040310).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the GPRS architecture disclosed in Bates. Dependent claim 8 requires the manageable electronic device's local network to be coupled to the wide area network (WAN) via a specific signal carrier, such as a digital subscriber line (DSL). While Bates disclosed the connection between the local cell (LAN) and the wider network (WAN) via an "Abis interface," it did not specify the carrier type. Barakat, which addressed increasing performance in mobile networks, explicitly taught using a DSL or HDSL connection for the Abis interface between a base transceiver station and a base station controller.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Bates with Barakat to improve the performance of the system. Specifically, one would be motivated to use the DSL connection taught by Barakat for the Abis interface in Bates's system to increase data throughput between the local cell and the core network.
    • Expectation of Success (for §103 grounds): The combination was a predictable application of a known connection technology (DSL) to a standard network interface (Abis) to achieve a known benefit (increased throughput).

Ground 3: Obviousness over Bates in view of AAPA - Claim 9 is obvious over Bates in view of Applicant's Admitted Prior Art.

  • Prior Art Relied Upon: Bates (a 2002 publication) and Applicant's Admitted Prior Art (AAPA).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claim 9, which requires the manageable electronic device to have a "default address" for the ACSMD. Bates described a mobile station initiating contact with the network using a specific channel (the PRACH, or Packet Random Access Channel) but did not explicitly label this a "default address." The ’772 patent specification, however, admitted that it was well-known in the prior art to preconfigure devices with default addresses to obtain configuration data. Petitioner argued this admission constituted AAPA.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the known concept of using a default address (from the AAPA) with the GPRS system in Bates for the predictable benefits of simplifying device design and network communication. Applying this known solution to the ACSMD (Bates's SGSN) was presented as an obvious design choice to solve the problem of initial device configuration.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success, as using a default address for an initial network connection was a common and well-understood technique at the time of the invention.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claim 8 over Bates and Yla-Mella (Patent 6,526,290) for similar reasons as the Barakat combination, and claim 9 over Bates, Bauchot (Patent 5,912,918), and AAPA to further support the use of a stored default address for network selection.

4. Key Claim Construction Positions

  • "a plurality of auto-configuration servers (ACSs)": Petitioner proposed this term 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 central to mapping the GGSNs of the GPRS architecture in Bates to the claimed ACSs.
  • "auto-configuration server managing device (ACSMD)": Petitioner proposed this term 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 was critical for mapping the relay and selection functions of the SGSN in Bates to the claimed ACSMD.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 8-16 of the ’772 patent as unpatentable.