PTAB

IPR2017-01893

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 ’359 patent discloses a system for autonomously monitoring and managing a plurality of “consumer device assets” (e.g., security devices, utility meters, laptops, cellular phones) registered with a remote computer server. The devices send operational and usage data to the server, which processes the data and sends back management instructions.

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 the foundational system of a remote server managing and synchronizing data with various mobile "consumer device assets" over a network. Kloba’s system, however, primarily relied on manual user-initiated synchronization (e.g., pressing a "sync" button). Multer was argued to cure this deficiency by teaching automatic synchronization triggered by events or the passage of time, which was particularly applicable to devices like cellular phones that lacked a dedicated sync button.
    • Motivation to Combine: A POSITA would have been motivated to combine the references to improve upon Kloba's system. Because Kloba disclosed managing non-PDA devices (like cell phones) that do not typically have sync buttons, a POSITA would have looked to known solutions like Multer’s automatic synchronization to provide a predictable and more user-friendly method for keeping these devices updated. The combination was presented as a predictable application of a known technique (automatic sync) to improve a similar system (Kloba's).
    • Expectation of Success: Given that both Kloba and Multer addressed the same fundamental problem of data synchronization between a server and mobile devices using similar client-server architectures, a POSITA would have had a reasonable expectation of success in integrating Multer’s automatic triggering mechanism into Kloba’s 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 Kloba/Multer combination by adding the teachings of Loughran to address specific claim limitations related to cellular network technology and functionality. Petitioner asserted Loughran taught using a specific cellular network (GSM) for communication, sending an SMS message to a device to cause it to power up from a low-power standby mode, and using a "required coded number" (a digital signature) to authenticate communications. For example, claim 3 requires a GSM-compliant connection, and claim 12 requires using an SMS to power up a device.
    • Motivation to Combine: The motivation to add Loughran’s teachings was to implement specific, well-known cellular communication features into the base synchronization system. A POSITA seeking to enable robust communication for the cellular phones in the Kloba/Multer system would have naturally looked to dominant, contemporary cellular technologies like GSM, as taught by Loughran. Adding features like SMS-based power-up and digital signatures was argued to be a logical, complementary enhancement to improve power efficiency and security, addressing known issues in mobile computing.
    • Expectation of Success: Loughran’s teachings were presented as complementary to the Kloba/Multer system. Incorporating a specific network standard (GSM) or a power-saving feature (SMS wake-up) were routine design choices for mobile device systems at the time, leading to a high expectation of success.

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 other specific wireless network standards required by claims 19 and 21. Petitioner argued that Chow disclosed using next-generation cellular networks (WCDMA) and non-cellular wireless networks like WLAN (specifically, IEEE 802.11b). This combination allegedly rendered obvious claims requiring a system with devices connected via both WCDMA and WLAN standards.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Chow’s teachings to upgrade the Kloba/Multer/Loughran system with newer, faster, and more capable network technologies. As of the patent's priority date, there was a clear trend toward adopting 3G technologies like WCDMA and high-speed wireless LANs. A POSITA would have viewed incorporating these networks as a predictable evolution to enhance data transfer speeds and enable more advanced services, representing a routine design choice from a limited number of known, available options.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including Ground 4 (Claim 4 is obvious over Kloba, Multer, and Chow, arguing Chow teaches the use of a VPN) and Ground 5 (Claim 15 is obvious over Kloba, Multer, and Fong, arguing Fong teaches communicating data indicative of battery charge levels).

4. Key Claim Construction Positions

Petitioner argued for broad constructions of several key terms, asserting they were essential to understanding the scope of the prior art.

  • “Consumer Device Asset”: Proposed as "any fixed or mobile electronic device." Petitioner contended the specification provides a wide, non-limiting variety of examples, from security systems to laptops and cell phones, indicating the term is not restricted to any particular set of devices.
  • “Operational Status Information”: Proposed as "data relating to the performance or functionality of a device asset." This was based on specification examples like traffic speed indicators and battery charge levels, and prosecution history where the applicant equated it with "performance or functionality."
  • “Consumer Usage Information”: Proposed as "data relating to an individual's interactions with a device asset or related devices." Petitioner argued the specification’s examples, such as utility meter readings or motion detection, show that the data is not limited to the user's direct interaction with the communicating device itself.
  • “Management Instructions”: Proposed as "commands for a device asset to perform particular actions." This was based on specification examples like instructions to lock a door, power down a module, or program a video recorder.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-30 of the ’359 patent as unpatentable under 35 U.S.C. §103.