PTAB

IPR2017-01891

Amazon.com, Inc. v. M2M Solutions LLC

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1. Case Identification

2. Patent Overview

  • Title: System and Method for Remote Asset Management
  • Brief Description: The ’007 patent discloses a system for autonomously monitoring and managing a plurality of "consumer device assets" that are registered with a remote computer server platform. The assets communicate operational status and consumer usage information to the server, which processes the information and sends back management instructions to automatically modify the assets.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kloba and Multer - Claims 1, 2, 5, 8-11, 13, and 14 are obvious over Kloba in view of Multer.

  • Prior Art Relied Upon: Kloba (Patent 6,421,717), Multer (Patent 6,671,757).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kloba taught a client-server system for remotely managing and synchronizing content (e.g., applications, files, channels) on a plurality of consumer mobile devices, meeting most limitations of independent claim 1. Kloba’s system involved devices sending "state" information (operational status) and user preferences (consumer usage) to a server, which then compiled and sent back "instructions" to modify the device content. However, Petitioner contended Kloba’s primary embodiment focused on manual synchronization initiated by a user pressing a "sync" button. Multer was argued to cure this deficiency by teaching automatic synchronization triggered by an event or the passage of time, thus rendering the claimed "autonomously monitoring" limitation obvious.
    • Motivation to Combine: A POSITA would combine Multer with Kloba to improve Kloba’s system. Kloba disclosed synchronizing non-PDA devices (like cellular phones) that typically lack a dedicated "sync" button. Multer’s teaching of automatic synchronization provided a known and logical solution to enable this functionality for such devices. This combination would predictably result in a more robust system that keeps device content updated without requiring user intervention, a well-known goal in the art.
    • Expectation of Success: Given that both references addressed the same fundamental problem of data synchronization between a server and mobile devices using similar network architectures, a POSITA would have a reasonable expectation of success in integrating Multer’s automatic triggering mechanism into Kloba’s synchronization framework.

Ground 2: Obviousness over Kloba, Multer, and Loughran - Claims 3, 6, 7, 12, 16-18, 20, and 22-30 are obvious over Kloba and Multer in view of Loughran.

  • Prior Art Relied Upon: Kloba (Patent 6,421,717), Multer (Patent 6,671,757), and Loughran (Application # 2002/0129107).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the Kloba/Multer combination by adding Loughran's teachings to meet limitations in various dependent claims. Petitioner asserted Loughran taught using a specific cellular network (GSM) for communication (claim 3), which inherently requires devices to have a SIM card (claims 16, 17) and process incoming messages for a unique identifier (claim 6). Loughran also disclosed using an SMS message to power up a device from a low-power standby mode to receive data (claim 12) and authenticating messages via a digital signature, which corresponds to a "required coded number" (claim 7).
    • Motivation to Combine: A POSITA would be motivated to incorporate Loughran's teachings as a routine design choice to implement the Kloba/Multer system. As of 2002, GSM was a dominant cellular technology. Implementing the system on a GSM network as taught by Loughran was a logical way to enable the cellular communication disclosed generally in Kloba and Multer. Features like powering up a device to receive critical updates and authenticating messages would have been seen as valuable enhancements to the security and reliability of the base system.
    • Expectation of Success: Integrating these specific, well-understood cellular features from Loughran into the general synchronization framework of Kloba and Multer would have been a predictable implementation for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Chow (Application # 2002/0191557) for its teachings on WCDMA and WLAN networks (claims 19, 21) and VPNs (claim 4), and Fong (Patent 7,197,011) for its disclosure of monitoring and reporting device battery levels (claim 15).

4. Key Claim Construction Positions

  • "Consumer Device Asset": Petitioner proposed this term be construed as "any fixed or mobile electronic device." This broad construction was argued to be consistent with the specification's varied examples (e.g., security devices, utility meters, laptops) and necessary to encompass the types of devices disclosed in the prior art.
  • "Operational Status Information": Proposed as "data relating to the performance or functionality of a device asset." This construction allowed Petitioner to map prior art disclosures of device state—such as memory specifications, network profiles, and screen size—to this claim limitation.
  • "Consumer Usage Information": Proposed as "data relating to an individual's interactions with a device asset or related devices." This broad interpretation was used to argue that user preferences and channel subscriptions taught in the prior art met this limitation.
  • "Management Instructions": Proposed as "commands for a device asset to perform particular actions." This construction was used to argue that the synchronization and update commands sent from servers in the prior art constituted the claimed "management instructions."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the grounds in this petition were not redundant with those in a concurrently filed IPR (IPR2017-01894) against the same patent. It was noted that this petition is based on the primary reference Kloba, while the other petition is based on a different primary reference (Saylor). Petitioner asserted this difference in foundational art leads to distinct combinations, rationales, and motivations to combine, thereby justifying separate proceedings.

6. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-30 of Patent 8,504,007 as unpatentable under 35 U.S.C. §103.