Samsung Electronics Co Ltd v. Script Security Solutions LLC

1. Case Identification

• Case #: IPR2016-01881
• Patent #: 6,828,909
• Filed: September 23, 2016
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Script Security Solutions, LLC
• Challenged Claims: 15, 24, 26-29

2. Patent Overview

• Title: Portable Security System
• Brief Description: The ’909 patent discloses a security alarm system for detecting the movement of an object, such as a door or window. The system uses wireless motion detectors that transmit an alarm signal containing a unique identifier to a receiver, which can then be processed by a remote security administration system.

3. Grounds for Unpatentability

Ground 1: Claims 15 and 26-29 are obvious over Glidewell, Greenwaldt, and Saylor

• Prior Art Relied Upon: Glidewell (Patent 5,319,698), Greenwaldt (Patent 5,499,014), and Saylor (Patent 6,400,265).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Glidewell taught the foundational wireless security system, including motion sensors that transmit a unique identifier (a twelve-bit code) to a receiver and a remote security station. However, Glidewell’s system was not explicitly portable. Greenwaldt, which addresses wireless alarm systems, was argued to supply the portability limitation by teaching removable mounting members (e.g., adhesives) that permit easy installation and relocation of sensors. To meet limitations related to converting unique identifiers into user-friendly object information (e.g., "Front Door") and providing subscriber registration and provisioning functions, Petitioner relied on Saylor. Saylor was alleged to teach a security system where subscribers can register devices and associate sensor identification codes with user-defined zone names (e.g., "Basement") in a subscriber database, which are then displayed in status reports.
  • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Glidewell and Greenwaldt to gain the known advantages of a portable security system, which Greenwaldt explicitly states is desirable for ease of installation and use in various locations. A POSITA would then be motivated to incorporate Saylor’s features into the combined Glidewell/Greenwaldt system to improve its usefulness and convenience by replacing cryptic codes with descriptive location names and enabling modern, web-based subscriber registration and provisioning, which were known methods for enhancing security system management.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in making these combinations. Modifying Glidewell's sensors to be portable using Greenwaldt's well-understood adhesive mounting techniques was presented as a straightforward design choice. Similarly, integrating Saylor's database and web-based interface functionalities into the Glidewell/Greenwaldt system was argued to be a predictable application of known software and networking principles to improve a known system.

Ground 2: Claim 24 is obvious over Glidewell, Greenwaldt, Saylor, and Monroe

• Prior Art Relied Upon: Glidewell (Patent 5,319,698), Greenwaldt (Patent 5,499,014), Saylor (Patent 6,400,265), and Monroe (Patent 6,970,183).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Glidewell, Greenwaldt, and Saylor from Ground 1 to address the limitations of claim 24, which additionally requires that the motion sensor itself includes "RF receiving means" and "control means" for two-way communication with the receiver. Petitioner asserted that the base combination lacked this feature, as Glidewell’s sensors only transmit signals. Monroe was argued to remedy this deficiency by disclosing wireless appliance sensors (including motion sensors) that contain transceivers ("RF receiving means") and microcontrollers ("control means"). These components in Monroe allow the sensor to receive wireless transmissions from a monitoring station for purposes like remote diagnosis, testing, and reconfiguration, and to transmit operational information back to the station.
  • Motivation to Combine: A POSITA would have been motivated to incorporate Monroe's two-way communication capabilities into the sensors of the Glidewell/Greenwaldt/Saylor system. This modification would improve reliability and add a wider range of system monitoring and maintenance functions, such as remote diagnostics, without requiring the physical presence of personnel. Petitioner argued this was a common-sense approach to enhance the functionality of a security system.
  • Expectation of Success: The combination was presented as predictable. Integrating a known transceiver and microcontroller, as taught by Monroe, into a wireless sensor was a well-understood engineering task. A POSITA would have reasonably expected that adding this capability would successfully enable two-way communication for remote management without negatively affecting the existing alarm-reporting functions of the base system.

4. Key Claim Construction Positions

• Petitioner argued that two terms in claim 24 are means-plus-function limitations under 35 U.S.C. § 112(6) and proposed the following constructions:
  • "RF receiving means for receiving wireless transmissions": The function is "receiving wireless transmissions," and the corresponding structure disclosed in the ’909 patent is "a radio receiver or a transceiver" and its equivalents.
  • "control means responsive to said wireless transmissions for implementing control functions and providing operational information wirelessly to said receiver": The function is "implementing control functions and providing operational information wirelessly to said receiver," and the corresponding structure is "a control logic circuit that could be implemented as a programmable processor" and its equivalents.

5. Key Technical Contentions (Beyond Claim Construction)

• A central contention of the petition was that the challenged claims were not entitled to a priority date earlier than the April 8, 2002 filing date of the application that matured into the ’909 patent.
• Petitioner argued that key claim limitations—including "unique identifier," "conversion" of the identifier to object information, "subscriber database," and "subscriber registration function"—were not disclosed in any of the parent applications dating back to 1996. Because this subject matter was allegedly new matter added in the 2002 application, Petitioner contended that references like Saylor (filed 2001) and Monroe (filed 2000) qualify as prior art.

6. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 15, 24, and 26-29 of the ’909 patent as unpatentable.