PTAB

IPR2016-01744

Cisco Systems Inc v. ChanBond LLC

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1. Case Identification

2. Patent Overview

  • Title: Intelligent Device System and Method for Distribution of Digital Signals on a Wideband Signal Distribution System
  • Brief Description: The ’822 patent discloses a radio frequency (RF) data transmission system where a high-rate data stream is divided into smaller streams, transmitted over multiple RF channels, and then selectively received and recombined by an intelligent device. The system uses channel identification information sent over the RF signal to inform the device which channels contain the relevant data streams.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tiedemann and Gilhousen - Claims 1-2, 5-6, 19, 20, 23, and 29 are obvious over Tiedemann in view of Gilhousen.

  • Prior Art Relied Upon: Tiedemann (Patent 5,859,840) and Gilhousen (Patent 5,103,459).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tiedemann taught the core elements of the challenged claims, including a multi-channel cellular RF system for bidirectional communication. Tiedemann’s system divides a high-rate data stream into smaller streams, sends them over multiple wireless channels to a mobile station, and sends a "channel assignment message" to identify which channels contain the data. The mobile station’s receive-side circuitry then selectively receives and demodulates the designated channels and uses a multiplexer to recombine the data streams. Petitioner asserted this maps to the claimed input, demodulator unit, and combiner. Gilhousen, which is incorporated by reference into Tiedemann, was cited to explicitly teach the addressability of mobile devices, disclosing signals "addressed to a particular user" and the use of a "mobile unit address or user ID" to discriminate among users.
    • Motivation to Combine: Petitioner contended that Tiedemann itself suggested the combination by expressly incorporating Gilhousen to describe its exemplary CDMA system. A person of ordinary skill in the art (POSA) would have understood that implementing Tiedemann's system would require the addressing schemes taught by Gilhousen to ensure data reached the correct mobile station in a multi-user cellular network. Modifying Tiedemann’s mobile stations to be explicitly addressable as taught by Gilhousen was presented as a predictable solution to a known requirement in cellular communications.
    • Expectation of Success: A POSA would have had a high expectation of success because Gilhousen's addressing scheme was designed for the very type of CDMA cellular system described in Tiedemann, making the integration straightforward and yielding predictable results.

Ground 2: Obviousness over Tiedemann, Gilhousen, and Gorsuch - Claims 1-2, 5-6, 19, 20, 23, and 29 are obvious over Tiedemann in view of Gilhousen and Gorsuch.

  • Prior Art Relied Upon: Tiedemann (Patent 5,859,840), Gilhousen (Patent 5,103,459), and Gorsuch (Patent 6,081,536).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1, adding Gorsuch to provide further teaching for the "at least one addressable device" limitation. Petitioner argued that Gorsuch disclosed a multi-channel cellular RF system that transmits high-rate data streams to multiple addressable end-user devices, such as portable computers and telephones, connected through a subscriber unit. Gorsuch explicitly taught using the Q.931 network layer protocol, which requires devices to have addresses for communication over a network like the PSTN. This was argued to provide an explicit example of a system connecting multiple, distinct, addressable devices over a multi-channel RF link.
    • Motivation to Combine: Petitioner asserted that a POSA would combine the teachings of Gorsuch with the Tiedemann/Gilhousen system to enhance its functionality. The motivation stemmed from market demand in the late 1990s for connecting devices like computers to the internet via cellular modems. A POSA would have looked to a system like Gorsuch, which taught connecting computers and phones via a subscriber unit, and applied its modem and protocol converter functionality to Tiedemann's efficient multi-channel transmission system. This combination would predictably allow multiple addressable devices to access a network over the RF link provided by Tiedemann's mobile station.
    • Expectation of Success: A POSA would expect success in combining Gorsuch's subscriber unit functionality with Tiedemann’s mobile station. The combination involved integrating known networking protocols (taught by Gorsuch) with a known RF transmission scheme (taught by Tiedemann) to achieve the predictable result of enabling internet and network access for peripheral devices.

4. Key Claim Construction Positions

  • "Channel": Petitioner proposed the construction "a path for transmitting electric signals." This construction was argued as critical to ensure the term was not improperly limited to frequency bands, but also encompassed other known channel types in the art, such as the code channels used in the CDMA systems of the prior art references (Tiedemann and Gilhousen).
  • "Address," "addressed," "addressable device": Petitioner proposed construing "address" as "information that identifies a device or location" and "addressable device" as "a device to which data can be sent using an address." This construction was central to Petitioner's argument that the mobile stations in the prior art, identifiable by telephone numbers or user IDs, met this limitation, and that the term should be interpreted broadly according to its plain meaning in the context of telecommunications networks.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 5-6, 19, 20, 23, and 29 of the ’822 patent as unpatentable.