PTAB

IPR2016-00989

RPX Corp v. Sockeye Licensing TX LLC

Title: System, Method And Apparatus For Using A Wireless Cell Phone Device To Create A Desktop Computer And Media Center
Brief Description: The ’342 patent discloses using a wireless communication device, such as a cell phone, to provide network connectivity to and control standard desktop peripherals like a monitor and keyboard. The system allows a user to access web-based applications or other information using the peripherals, with the cell phone functioning as the central processing unit and internet gateway.

Prior Art Relied Upon: Tee (Application # 2006/0203758) and Acharya (Application # 2005/0036509).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Tee discloses the core method of independent claim 1: a mobile terminal that receives multimedia data from a server and transmits that data to an external peripheral device, such as a larger display, under user control. To the extent the claim limitation of "operating" the peripheral device requires a specific user interface application, Petitioner asserted Acharya supplies this element by teaching a user interface on a wireless device for controlling external displays, including multi-user access.
- Motivation to Combine (for §103 grounds): Petitioner contended a person of ordinary skill in the art (POSITA) would combine Tee with Acharya's known techniques to improve the functionality and user experience of Tee's system. Acharya was presented as a natural extension, providing a detailed description of a user interface for controlling external displays, which would predictably enhance Tee's more foundational system.
- Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because the combination involved implementing a known user interface (from Acharya) into a compatible system (Tee) to achieve the predictable result of improved usability.

Prior Art Relied Upon: Tee (Application # 2006/0203758), Acharya (Application # 2005/0036509), and Benco (Application # 2005/0135393).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the Tee/Acharya combination, adding Benco to address claims reciting the creation of a "desktop computing environment." Petitioner argued that Benco explicitly teaches interfacing a mobile phone with a "peripheral hub" to connect to a monitor, printer, and keyboard for the express purpose of acting as a "replacement for a desktop computer." This teaching was mapped directly to the desktop environment limitation in claims such as claim 3.
- Motivation to Combine (for §103 grounds): While Tee mentioned an I/O interface for a "docking station," it lacked implementation details. Petitioner argued a POSITA would combine Tee with Benco to realize this feature, as Benco provided specific teachings on using a peripheral hub to create the exact desktop-like functionality described. The architectures of Tee and Benco were asserted to be similar, making integration a predictable design choice.
- Expectation of Success (for §103 grounds): Success was expected because Benco's hub would predictably connect to Tee's disclosed I/O interface to allow users to connect to a wider variety of peripherals, a well-understood technological goal.

Prior Art Relied Upon: Soin (Application # 2005/0091359) and Wang (Application # 2006/0077310).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Soin discloses a system where a computing device (e.g., a laptop) downloads content from a server via a Web-enabled interface and wirelessly projects it to an alternate display device (e.g., a projector) under user control. Soin further taught that mouse and keyboard events from the peripheral system could be redirected back to the primary computing device. Petitioner argued that Wang supplied the teaching of a "mobile terminal signal conversion module" (MTSCM), a hardware hub designed to connect a mobile terminal to various displays.
- Motivation to Combine (for §103 grounds): A POSITA would have been motivated to improve Soin's system by incorporating a hub device like Wang's MTSCM. Soin lacked a dedicated hub, and Petitioner argued that adding Wang's device would provide increased flexibility and allow any standard mobile terminal to interface with any standard display, a clear benefit explicitly taught by Wang.
- Expectation of Success (for §103 grounds): The combination was argued to be predictable, as incorporating a peripheral hub into Soin's architecture to increase device compatibility was a common and well-understood design choice for improving such systems.

Petitioner proposed constructions under the Broadest Reasonable Interpretation standard for several key terms crucial to its invalidity arguments.
"operating said peripheral device from said wireless device": Argued to include both (i) using the wireless device to navigate user information that is displayed on the peripheral, and (ii) using the wireless device to directly control the peripheral within a desktop computing environment. This construction was central to mapping prior art where the mobile device acts as the "CPU" for otherwise "dumb" peripheral components.
"means for receiving..." and "means for employing...": Petitioner argued these "means-for" terms under 35 U.S.C. §112(f) should be construed to cover the corresponding structures disclosed in the ’342 patent specification. For wireless communication, this was hardware/software for the 802.11 protocol; for wireline, it was hardware/software for USB or 1394 protocols.

Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 3-10, 20-43, 45-53, and 55-57 of the ’342 patent as unpatentable under 35 U.S.C. §103.