PTAB

IPR2016-01882

Samsung Electronics Co Ltd v. Script Security Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Portable Wireless Security Alarm System
  • Brief Description: The ’909 patent is directed to a portable security alarm system. The system uses wireless motion detectors that, upon detecting movement of an object (e.g., a door or window), transmit a signal containing a unique identifier to a local receiver which processes the information.

3. Grounds for Unpatentability

Ground 1: Obviousness over Glidewell and Greenwaldt - Claims 1-3, 9, 11, 19-21, and 23 are obvious over Glidewell in view of Greenwaldt.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698) and Greenwaldt (Patent 5,499,014).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Glidewell taught the core elements of a security system as claimed, including motion sensors that detect movement and wirelessly transmit a coded signal to a local receiver. This signal serves as a unique identifier (a 12-bit code identifying the specific sensor and system unit) which the receiver processes and displays. Glidewell also disclosed a remote security station with a computer host that could automatically dial designated numbers in response to an alarm, mapping to limitations in claims 11 and 19.
    • Motivation to Combine: Petitioner asserted that while Glidewell taught the functional system, it did not explicitly disclose portability. Greenwaldt was cited to remedy this deficiency, as it taught a wireless security system with transmitter units designed for easy and removable attachment to doors or windows using adhesives. A POSITA would combine Greenwaldt’s portability features with Glidewell’s system to satisfy the known market need for alarm systems that are easy to install, remove, and relocate, particularly for temporary housing like apartments.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because incorporating removable mounting methods (e.g., adhesives) from Greenwaldt into Glidewell’s sensors was a simple, predictable modification using well-known components to achieve the desired portability.

Ground 2: Obviousness over Glidewell, Greenwaldt, and Pacheco - Claims 1-4, 11-13, 19-21, and 23 are obvious over Glidewell and Greenwaldt in view of Pacheco.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698), Greenwaldt (Patent 5,499,014), and Pacheco (Patent 5,499,196).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Glidewell and Greenwaldt, adding Pacheco to teach the conversion of a numeric unique identifier into a descriptive word or phrase, as required by claims 4 and 12. While Glidewell’s receiver displayed a numeric code, Pacheco disclosed an alarm system that used a look-up table to associate a sensor’s code with a user-defined location name (e.g., “Main Entrance”) for display. Pacheco also taught storing this provisioned information in a subscriber database.
    • Motivation to Combine: A POSITA would be motivated to integrate Pacheco’s look-up table functionality into the Glidewell/Greenwaldt system to improve usability and security. Displaying a descriptive location name instead of a numeric code allows a user to more quickly and intuitively understand where a security breach has occurred. This was a known technique to improve the convenience and effectiveness of alarm systems.
    • Expectation of Success: The proposed modification involved implementing a simple and common database look-up table, a well-understood technique at the time. A POSITA would have predictably achieved a system with a more user-friendly output.

Ground 3: Obviousness over Glidewell, Greenwaldt, and Marman - Claim 24 is obvious over Glidewell and Greenwaldt in view of Marman.

  • Prior Art Relied Upon: Glidewell (Patent 5,319,698), Greenwaldt (Patent 5,499,014), and Marman (WO 00/21053).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 24, which requires the motion sensor to include "RF receiving means" and "control means" for two-way communication (i.e., the ability to receive signals from the base station). The Glidewell/Greenwaldt sensors were transmit-only. Petitioner argued Marman taught this missing element by disclosing a wireless security system where sensors include transceivers, enabling two-way communication with the base station for functions like interrogation and remote arming/disarming.
    • Motivation to Combine: A POSITA would combine Marman’s two-way communication capability with the Glidewell/Greenwaldt system to improve system reliability and add advanced functionality. Marman explicitly noted that two-way message exchange was more reliable than the one-way "Shout and Pray" method. This modification would enable a wider range of system monitoring and control functions, a clear advantage.
    • Expectation of Success: Implementing transceivers in place of transmitters was a known design choice for improving wireless communication systems. A POSITA would have reasonably expected success in applying this established technology to create a more robust and feature-rich portable alarm system.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including adding Rietkerk to the Pacheco combination to further teach a remote subscriber database for claim 12, and adding Pacheco to the Marman combination to teach conversion to a word or phrase for claim 24.

4. Key Claim Construction Positions

  • "portable security alarm system": Petitioner argued its unpatentability contentions under the District Court's construction in a related case, which defined the term as a "removable alarm system...physically configured to be easily installed, easily removed, and easily transported...and capable of being easily carried by an individual." This construction was central to the motivation to combine Glidewell with Greenwaldt.
  • Means-Plus-Function (Claim 24): For claim 24, Petitioner proposed constructions for two means-plus-function limitations:
    • "RF receiving means for receiving wireless transmissions": Function is "receiving wireless transmissions"; corresponding structure is a "radio receiver" or "transceiver."
    • "control means responsive to said wireless transmissions...": Function is "implementing control functions and providing operational information wirelessly"; corresponding structure is a "control logic circuit that could be implemented as a programmable processor."

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention of the petition was that the challenged claims were not entitled to the 1996 priority date of their parent applications. Petitioner argued that key limitations—including "unique identifier," the "conversion" of that identifier to object information, and automated computer host functions—lacked written description support in the parent applications and were first disclosed in the 2002 application that matured into the ’909 patent. Petitioner contended the claims' effective filing date is therefore April 8, 2002, which establishes the asserted prior art references (all published before 2002) as valid prior art.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 9, 11-13, 19-21, 23, and 24 of the ’909 patent as unpatentable.