PTAB

IPR2016-01920

SecureNet Technologies LLC v. iControl Networks Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Forming a Security Network Including Integrated Security System Components and Network Devices
  • Brief Description: The ’619 patent describes an integrated security system featuring a local gateway that automatically discovers and forms a network with security components. The gateway processes data from these components and communicates with a remote security server, enabling remote access and control of the system.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Combination - Claims 17, 18, 21-22, 29-31, 33, 36, and 58 are obvious over Wimsatt in view of Johnson, Severson, and Naidoo.

  • Prior Art Relied Upon: Wimsatt (Application # 2004/0260427), Johnson (Patent 6,580,950), Severson (Patent 4,951,029), and Naidoo (Application # 2003/0062997).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued the base combination discloses the core system of the independent claims. Wimsatt taught a local home automation control panel ("gateway") that discovers and integrates devices, including a security system. Johnson added a remote data center ("security server") that allows a user to monitor and control the local system via a network, satisfying the remote server limitations. Severson was cited to explicitly teach "self-learning" or automatic discovery of individual security sensors, which Petitioner contended renders obvious the claimed automatic discovery of security components. Naidoo was used for dependent claims, teaching the transmission of event data, including alarm video, from a gateway to a central monitoring station or remote client devices.
    • Motivation to Combine: A POSITA would combine Johnson with Wimsatt to add highly desirable remote monitoring and control capabilities to a local automation system, a recognized need for mobile homeowners. Severson would be incorporated to improve the system's reliability and ease of installation by implementing its robust auto-discovery for sensors. Naidoo would be combined to enhance the system's security functionality by enabling detailed event reporting to a central monitoring station, which improves first-responder effectiveness.
    • Expectation of Success: Petitioner asserted success was expected because the combination involved integrating known, analogous technologies using standard networking principles to achieve the predictable benefits of remote access and improved automation.

Ground 2: Adding GPRS Communication - Claims 20 and 35 are obvious over Wimsatt in view of Johnson, Severson, Naidoo, and Anthony.

  • Prior Art Relied Upon: Wimsatt (Application # 2004/0260427), Johnson (Patent 6,580,950), Severson (Patent 4,951,029), Naidoo (Application # 2003/0062997), and Anthony (Application # 2003/0137426).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the base combination from Ground 1 to address claims requiring a General Packet Radio Service (GPRS) coupling for a secondary communication link. While the base combination established communication with a remote monitoring station, Petitioner argued Anthony explicitly taught using GPRS—a well-known mobile communication mode—to transmit signals from a security system for the purpose of remote monitoring.
    • Motivation to Combine: A POSITA would be motivated to use the GPRS technology taught by Anthony as a communication mode for the system's secondary link. This would predictably provide the system with a known, available, and advantageous mobile communication option, thereby increasing the system's flexibility and redundancy.

Ground 3: Adding Server Management Features - Claims 37-41 and 48-53 are obvious over Wimsatt in view of Johnson, Severson, and Alexander.

  • Prior Art Relied Upon: Wimsatt (Application # 2004/0260427), Johnson (Patent 6,580,950), Severson (Patent 4,951,029), and Alexander (Patent 6,748,343).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims directed to the security server's management functions. The Wimsatt/Johnson/Severson combination established the core system with a local gateway and a remote server. Petitioner asserted that Alexander taught a similar system where its remote central server provides a user interface for creating, modifying, deleting, and configuring monitoring devices (e.g., sensors and cameras) and user accounts. Alexander also disclosed creating notification rules and logging event data in a server-side database.
    • Motivation to Combine: A POSITA would integrate the advanced server-side management features of Alexander into the Wimsatt/Johnson system to enhance functionality. This combination would predictably result in a more powerful and user-friendly system, allowing users to remotely customize devices, manage user access, and log data, thereby simplifying installation and improving the overall user experience.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53, and 58 of the ’619 patent as unpatentable.