PTAB

IPR2016-01397

Juniper Networks Inc v. Chrimar Systems Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Equipment Asset Tracking and Management
  • Brief Description: The ’838 patent describes a system for providing power and communicating information over pre-existing network wiring, such as Ethernet cables. The system uses a central module to supply DC power to a remote module and communicates status by modulating the voltage or current on the power lines.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 7, 26, 29, 38, 39, 40, 47, 55, and 69 are obvious over Hunter in view of Bulan.

  • Prior Art Relied Upon: Hunter (WO 96/23377) and Bulan (Patent 5,089,927).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hunter disclosed a system for supplying DC "phantom power" over an Ethernet cable from a central hub to remote terminal equipment. Hunter’s system included a basic protective device, such as a thermistor or polyfuse, to guard against overcurrents. Bulan disclosed a sophisticated "current control apparatus" designed for use in phantom-powered systems. This apparatus could intelligently distinguish between a genuine fault (e.g., a short circuit) and a temporary, high inrush current typical of a DC-DC converter powering up. The combination of Hunter's phantom power system with Bulan's current control apparatus would meet the limitations of independent claim 1, as Bulan's device detects different magnitudes of DC current flow and controls the circuit by switching a high impedance path in or out in response.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would be motivated to replace Hunter’s simple protective device with Bulan’s superior current control apparatus. Bulan was explicitly designed to solve a known problem in phantom power systems—distinguishing normal startup current surges from fault conditions, a deficiency inherent in Hunter's simple thermistor. The combination represented a simple substitution of one known element for another to improve functionality and yield a predictable result.
    • Expectation of Success: A POSITA would have a high expectation of success, as Bulan's apparatus was intended to be a replacement for existing current limiting circuits, like Hunter's, without requiring further modification. Both references describe similar phantom power arrangements (transformer center-taps) in network environments, making the integration straightforward.

Ground 2: Claims 1, 2, 7, 26, 29, 38, 39, 40, 47, 55, and 69 are obvious over Bloch in view of Huizinga and IEEE 802.3.

  • Prior Art Relied Upon: Bloch (Patent 4,173,714), Huizinga (Patent 4,046,972), and the IEEE 802.3 standard (1993 and 1995 editions).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Bloch, though directed to a key telephone system, taught the core concepts of the ’838 patent. Bloch disclosed a "phantom circuit arrangement" to supply DC power and enable bi-directional data signaling over the same conductors used for the primary communication channel (voice). The remote terminal unit in Bloch could send status information by modulating its current draw, creating different magnitude current pulses detected by the control unit. In response, the control unit could send voltage pulses back to control the terminal. The IEEE 802.3 standards provided the well-known architecture for Ethernet networks, including central equipment like repeaters and remote data terminal equipment (DTEs) connected via twisted-pair wiring. Huizinga was cited to provide additional context for the type of status signaling (e.g., line key status) taught in Bloch.
    • Motivation to Combine: A POSITA would be motivated to apply Bloch's established phantom power and out-of-band signaling techniques to the widely adopted Ethernet standard defined by IEEE 802.3. Bloch itself suggested its invention could find application in "many different control unit/terminal applications." The combination was motivated by the obvious benefits of powering network devices over existing Ethernet cables (eliminating separate power supplies) and enabling status/control signaling without consuming valuable data bandwidth—both known design goals at the time.
    • Expectation of Success: The combination would have been straightforward. A POSITA would understand how to implement Bloch's phantom circuit, which uses transformer center-taps, within the transformer-coupled architecture of a standard 10BASE-T Ethernet system as described in IEEE 802.3. Applying Bloch’s signaling method to an Ethernet DTE was a predictable application of a known technique to a similar system.

4. Key Claim Construction Positions

  • "BaseT" (claim 1): Petitioner argued this term should be construed as "10BASE-T and 100BASE-T." This construction was based on the ’838 patent’s consistent use of "BaseT" in the context of "10BASE-T" and its general reference to "existing Ethernet communications," which would have included 100BASE-T at the time of the invention.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1, 2, 7, 26, 29, 38, 39, 40, 47, 55, and 69 of the ’838 patent as unpatentable.