PTAB

IPR2017-01892

Amazon.com Inc v. M2M Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Remote Asset Management
  • Brief Description: The ’358 patent discloses a system for a remote computer server platform to autonomously monitor and manage a plurality of consumer device assets. The assets communicate operational status and consumer usage information to the server, which in turn sends management instructions to the assets to perform actions.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 5, 6, 8-11, 13, and 14 are obvious over Kloba and Multer.

  • Prior Art Relied Upon: Kloba (Patent 6,421,717) and Multer (Patent 6,671,757).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kloba taught a client/server system for managing and synchronizing data on mobile devices ("consumer device assets") that were wirelessly connected to a network. Kloba disclosed the server receiving operational and usage information (device state, user preferences, channel subscriptions) and sending back instructions to modify stored content files. Petitioner contended that while Kloba's primary embodiment focused on manual synchronization (e.g., pressing a "sync" button), Multer taught an automatic synchronization process triggered by an event or the passage of time.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Kloba and Multer as they address the same fundamental problem of synchronizing data across devices and have complementary features. A POSITA would have been motivated to incorporate Multer’s automatic synchronization into Kloba’s system to provide a more seamless user experience and to support devices disclosed by Kloba (like cellular phones) that do not typically have a manual "sync" button.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining these known synchronization techniques, as it involved applying Multer's automatic triggering to Kloba's established data management architecture, yielding the predictable result of an automated remote management system.

Ground 2: Claims 3, 7, 12, 16-18, 20, and 22-30 are obvious over Kloba, Multer, and 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 combination of Kloba and Multer by adding Loughran. Petitioner argued Loughran taught specific details of cellular communication missing from Kloba and Multer. Loughran disclosed using a GSM network to send SMS messages to mobile devices, including instructions to download data. For claim 12, Loughran taught an "alert module" that could power up a device from a low-power state upon receiving an SMS message to facilitate communication. For claim 7, Loughran's disclosure of using a "digital signature" to authenticate the source of an SMS message was argued to teach a "required coded number."
    • Motivation to Combine: A POSITA would combine Loughran with the Kloba/Multer system to provide specific, known implementations for the cellular communications generically disclosed in Kloba and Multer. As GSM was a dominant cellular technology, incorporating it would be a routine design choice to enhance connectivity. Adding Loughran's "power-up" capability would improve the system's reliability by allowing devices to receive updates even when turned off, furthering Kloba's goal of offline content availability.
    • Expectation of Success: Combining these references was argued to be predictable. Integrating a known cellular standard (GSM) and power management technique (power-up via SMS) into an existing data synchronization framework would have been a straightforward implementation for a POSITA.

Ground 3: Claims 19 and 21 are obvious over Kloba, Multer, Loughran, and Chow.

  • Prior Art Relied Upon: Kloba (Patent 6,421,717), Multer (Patent 6,671,757), Loughran (Application # 2002/0129107), and Chow (Application # 2002/0191557).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Chow to the previous combination to teach the use of WCDMA and WLAN standards as recited in claims 19 and 21. Petitioner asserted that Chow explicitly disclosed using a "Wideband CDMA (WCDMA)" network for cellular devices and the "IEEE 802.11b wireless LAN standard" for high-speed internet access for other devices like laptops.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Chow's teachings to upgrade the Kloba/Multer/Loughran system with newer, faster network technologies. WCDMA was a next-generation (3G) cellular protocol offering improvements over the GSM taught by Loughran, and WLAN (Wi-Fi) was a known solution for high-speed local networking. Adopting these standards would have been a natural evolution of the combined system to improve performance.
    • Expectation of Success: A POSITA would have expected success in integrating these well-known communication protocols into the base system, as it represented a predictable substitution of newer, improved network standards for older ones.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including Claim 4 over Kloba, Multer, and Chow (adding VPN capability) and Claim 15 over Kloba, Multer, and Fong (Patent 7,197,011) (adding monitoring of battery charge levels).

4. Key Claim Construction Positions

  • "Consumer Device Asset": Petitioner proposed this term be construed as "any fixed or mobile electronic device," arguing the ’358 patent specification provides a wide variety of examples without limitation.
  • "Operational Status Information": Petitioner proposed this term be construed as "data relating to the performance or functionality of a device asset," citing examples from the specification like battery charge level and automobile performance parameters.
  • "Consumer Usage Information": Petitioner proposed this term be construed as "data relating to an individual's interactions with a device asset or related devices," arguing the specification provides broad examples beyond just the user's direct interaction, such as utility meter readings or motion detection data.
  • "Management Instructions": Petitioner proposed this term be construed as "commands for a device asset to perform particular actions," based on specification examples like locking doors or organizing the programming of a video recorder.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the grounds in this petition were not redundant with those in a concurrently filed IPR petition against the same ’358 patent. It was explained that this petition is based on Kloba as the primary reference, while the other is based on a different reference (Saylor), and that the motivations to combine the secondary references differ significantly between the two petitions.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-30 of the ’358 patent as unpatentable.