PTAB

IPR2016-01746

Cisco Systems Inc v. ChanBond LLC

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Key Events
Petition
petition

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 describes systems for receiving high-rate data streams addressed to a specific device. The system divides the stream into smaller streams, transmits them over a multi-channel radio frequency (RF) signal, and includes channel identification information. A receiving device then selectively receives and recombines the channels to reconstruct the original high-rate data stream.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tiedemann and Gilhousen - Claims 13-14 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 disclosed a multi-channel cellular RF communication system that taught the core limitations of the challenged claims. Tiedemann’s system divides a high-rate data stream for a mobile station into smaller streams, transmits them over a primary channel and multiple additional channels, and sends a "channel assignment message" to identify which channels carry the data. The mobile station’s receive-side circuitry then demodulates and recombines the data from these channels. Petitioner asserted that while addressability was inherent in Tiedemann’s mobile stations (as cellular phones), Gilhousen was cited to explicitly teach this element. Gilhousen, which is incorporated by reference into Tiedemann, described how mobile units in a CDMA system have addresses or user IDs to which signals are directed.
    • Motivation to Combine: A POSITA would combine Gilhousen with Tiedemann because Tiedemann explicitly incorporated Gilhousen as describing an exemplary system. The combination was presented as necessary to fully understand the operation of Tiedemann's system. Furthermore, Petitioner argued a POSITA would have been motivated to ensure the mobile stations in Tiedemann’s high-rate data system were addressable to improve their utility and allow them to communicate with other devices over standard networks like the PSTN or the Internet.
    • Expectation of Success: The combination would have yielded predictable results, as it involved applying the known addressing schemes taught by Gilhousen to the communication system described in Tiedemann.

Ground 2: Obviousness over Tiedemann, Gilhousen, and Gorsuch - Claims 13-14 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 supplemented the teachings of Tiedemann and Gilhousen with Gorsuch to provide additional, stronger evidence for the "addressable device" limitation. Petitioner asserted that Gorsuch taught a system for transmitting high-rate data over multiple RF channels to subscriber units connected to multiple, separately addressable devices, such as portable computers and telephones. Gorsuch explicitly disclosed using the OSI protocol stack and the Q.931 network layer standard for addressing these devices, allowing them to connect to the PSTN and Internet. The combination of Gorsuch’s protocol converter and modem with Tiedemann’s mobile station was argued to render the claimed invention obvious.
    • Motivation to Combine: A POSITA would combine Gorsuch's teachings with the Tiedemann/Gilhousen system to meet the clear market demand for connecting portable computers to the Internet via high-speed cellular networks. Petitioner argued that combining Gorsuch’s protocol converter, which enables standard network communications for devices like laptops, with Tiedemann’s high-rate multi-channel RF system was a combination of known elements to achieve a predictable result. This was further supported by evidence of contemporaneous commercial products, such as Qualcomm's data connectivity kits, which enabled this exact functionality.
    • Expectation of Success: A POSITA would have reasonably expected success in implementing Gorsuch’s addressing and device interface protocols within Tiedemann’s mobile station to allow various addressable devices to access the Internet over a multi-channel RF link.

4. Key Claim Construction Positions

  • "Channel": Petitioner proposed the construction "a path for transmitting electric signals." This broad construction was argued as necessary to encompass the various types of channels known in the art at the time (e.g., frequency bands in FDMA, time slots in TDMA, and codes in CDMA), all of which were mentioned in the ’822 patent specification. This construction prevented the claims from being narrowly limited to one specific type of channel.
  • "Addressable device": Petitioner proposed construing this term as "a device to which data can be sent using an address," with "address" being "information that identifies a device or location." This construction was crucial for mapping prior art cellular phones and connected computers, which use telephone numbers, IP addresses, or unit IDs, to the claimed "addressable device." Petitioner contended this aligned with the patent’s own examples, such as an IP address for a NIC card.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 13-14 of the ’822 patent as unpatentable.