PTAB

IPR2016-01878

Samsung Electronics Co Ltd v. Script Security Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Security System
  • Brief Description: The ’078 patent discloses a security system for detecting the movement of an object, such as a door or window. The system uses movement detectors that wirelessly signal an information gathering device, which in turn transmits information about the movement to a remote notification device that communicates with a remote host computer.

3. Grounds for Unpatentability

Ground 1: Obviousness over Glidewell - Claim 1 is obvious over Glidewell.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Glidewell, a security system patent, taught every limitation of claim 1. Glidewell disclosed a system with sensors for detecting movement (e.g., opening a window) that wirelessly transmit a coded signal to a local receiver. This local receiver unit gathers information (sensor ID, location ID) and functions as the claimed "information gathering device." It then transmits this information to a remote "security station 54," which Petitioner asserted met the limitations of the claimed "remote notification device" that communicates with a "remote host" (Glidewell's master control unit 60).
    • Motivation to Combine: Not applicable as this is a single-reference ground.
    • Key Aspects: Petitioner contended that even if elements like a power supply or memory were not explicitly detailed for every component in Glidewell, a person of ordinary skill in the art (POSITA) would have understood their necessity for operation and found it obvious to include them.

Ground 2: Obviousness over Glidewell in view of Lai - Claims 1-6 and 10 are obvious over Glidewell in view of Lai.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698), Lai (Patent 5,610,580).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplemented the teachings of Glidewell to address limitations in dependent claims requiring a camera and the processing of image information. Petitioner asserted that Lai disclosed a motion detection and imaging device for surveillance that included a digital camera, a microprocessor, a memory bank, and a power supply. Lai’s device was designed to capture, compress, and store a digitized image triggered by its motion detector. The combination of Glidewell's networked security system with Lai's imaging capabilities was argued to render claims 1-6 and 10 obvious.
    • Motivation to Combine: A POSITA would combine these references to improve the functionality of Glidewell's alarm system. Both patents addressed security systems that detect movement. A POSITA would have been motivated to add the camera functionality taught by Lai to Glidewell’s system to provide visual verification of an alarm event, thereby creating a more robust and reliable security product.
    • Expectation of Success: There was a high expectation of success, as adding a camera to a security system was a well-known and straightforward integration of existing technologies. The combination was a predictable solution that would not have negatively impacted the functionality of the underlying Glidewell system.

Ground 3: Obviousness over Glidewell, Lai, and Wadhwani - Claims 7, 8, and 9 are obvious over Glidewell, Lai, and Wadhwani.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698), Lai (Patent 5,610,580), and Wadhwani (Patent 3,925,763).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Wadhwani to address claim limitations requiring the remote notification device to include a modem (claim 7) and communicate with a remote host via a local computer (claims 8-9). Petitioner argued that Wadhwani taught a security system that used modem components (modulators/demodulators) to transmit digitally coded messages over a telephone network to a central station. This teaching would supply the modem limitation missing from the Glidewell-Lai combination. Further, Petitioner mapped Glidewell’s master control unit to the "local computer" limitation, arguing it communicates indirectly between the "remote notification device" and the "remote host."
    • Motivation to Combine: A POSITA would incorporate Wadhwani’s modem technology into the Glidewell-Lai system to enable reliable data transmission over conventional telephone or cellular networks. This was a common and known method for connecting a local security system to a remote monitoring station, making it an obvious modification to improve the system's communication capabilities.
    • Expectation of Success: Integrating a modem was a predictable application of a well-known component to achieve a known result (remote communication). The combination represented a common-sense design choice for enhancing the connectivity of the security system.

4. Key Claim Construction Positions

  • Petitioner argued that while the challenged claims should be given their plain and ordinary meaning, they were unpatentable even under the constructions proposed by the Patent Owner or adopted by the District Court in related litigation.
  • "information gathering device" and "remote notification device": Petitioner noted these were treated as means-plus-function terms. Petitioner’s primary argument was that Glidewell disclosed the required structure (e.g., RF receiver, RF transmitter, power supply). The addition of Lai in Ground 2 was presented as an alternative to satisfy constructions that might require a camera as part of the structure for the "information gathering device."
  • "remote host": Petitioner contended that Glidewell's master control unit or the remote entities it contacts (e.g., police) met the "remote host" limitation. To the extent the term was construed to require server-like functionality, Petitioner argued it would have been obvious to implement such features.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention was that the challenged claims were not entitled to the ’078 patent’s claimed priority date earlier than February 16, 2001. Petitioner argued that the parent applications did not disclose key limitations recited in the challenged claims, including the "information gathering device," "remote notification device," camera, and network interface features. This argument was critical to establishing that Glidewell, Lai, and Wadhwani, all published before 2001, qualified as prior art against the challenged claims.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-10 of the ’078 patent as unpatentable.