PTAB

IPR2016-01466

Cisco Systems Inc v. TQ Delta LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Multicarrier Transmission System with Low Power Sleep Mode and Rapid-On Capability
  • Brief Description: The ’404 patent discloses a multicarrier transceiver, such as those used in DSL systems, featuring a low-power "sleep mode." The system is designed to reduce power consumption during idle periods and then quickly restore full transmission capabilities by storing and retrieving operational parameters, thereby avoiding a full and time-consuming re-initialization process.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bowie, Yamano, and ANSI T1.413 - Claims 6, 10, 11, 15, 16, and 20 are obvious over Bowie in view of Yamano and the ANSI T1.413 standard.

  • Prior Art Relied Upon: Bowie (Patent 5,956,323), Yamano (Patent 6,075,814), and ANSI T1.413 (an industry standard for ADSL communications).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the challenged claims simply combined known elements from the prior art to achieve a predictable result. Bowie was asserted to teach the foundational system: an ADSL transceiver that enters a low-power mode by shutting down circuitry and stores "loop characteristics" in memory to enable a "rapid resumption" of operation without full re-initialization. However, Bowie did not specify the exact data structure or the types of parameters stored. Petitioner contended that the ANSI T1.413 standard, which defines ADSL communications, supplied these missing details. Specifically, ANSI T1.413 taught the claimed "superframe" structure (a plurality of data frames followed by a synchronization frame) and defined the key initialization parameters as "fine gain" and "bit allocation" parameters. Petitioner asserted that Yamano addressed the final key limitation: receiving a synchronization signal while in low-power mode. Yamano taught a modem that could operate its transmit and receive circuits independently, allowing one to enter a reduced-power "standby mode" while the other could still transmit or receive a timing signal to maintain synchronization.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine these references for several reasons. A POSITA seeking to improve the power-saving functionality of Bowie's ADSL system would look to other art in the field, like Yamano, and incorporate its more efficient technique of independently powering down transmit and receive circuitry. This combination was presented as a predictable enhancement. Furthermore, a POSITA implementing any ADSL system, such as the one described in Bowie or the improved Bowie/Yamano combination, would naturally turn to the prevailing industry standard, ANSI T1.413, to ensure interoperability and to use standard data framing and parameter definitions. Implementing Bowie's system according to the ANSI standard would have been a matter of routine design.
    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in making this combination. The proposed modification involved applying a known power-saving technique (from Yamano) and a well-defined industry standard (ANSI T1.413) to a conventional ADSL power-saving system (Bowie). There was no technical hurdle or unpredictability in combining these compatible technologies, as all three references operate in the same field of DSL communications.

4. Key Claim Construction Positions

  • "store/storing, in a/the low power mode" (claims 6, 11, 16): Petitioner argued that the broadest reasonable interpretation of this term, consistent with the patent's specification, is "maintaining in memory while in a reduced power consumption mode." This construction was important because the prior art (Bowie) teaches storing parameters upon entering low-power mode and retaining them during that mode for later retrieval, directly mapping to this interpretation.
  • "synchronization signal" (claims 6, 11, 16): Petitioner proposed that this term should be construed as "a signal used to maintain timing between transceivers." The petition asserted this construction is consistent with the patent's disclosure of a "synchronizing pilot tone." This interpretation allowed Petitioner to map the term to both the synchronization symbol disclosed in the ANSI T1.413 standard and the periodic timing signals taught by Yamano for maintaining synchronization during low-power operation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 6, 10, 11, 15, 16, and 20 of the ’404 patent as unpatentable.