PTAB

IPR2017-01894

Amazon.com Inc v. M2M Solutions LLC

Log In
Key Events
Petition
petition

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 system allows devices like security systems, utility meters, and cellular phones to communicate operational status and consumer usage information to the server, which in turn sends management instructions back to the devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 6-18, 20, and 23-30 are obvious over Saylor in view of Loughran.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265) and Loughran (Application # 2002/0129107).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Saylor taught the core system of the ’007 patent, disclosing a central security server that monitors and manages a plurality of consumer security devices (e.g., home control panels, cellular phones) over various communication networks. Saylor’s server received operational status (on/off) and consumer usage (alarm triggers) information and sent notifications. Petitioner contended Loughran supplemented Saylor by teaching a server that sends management instructions (via SMS) to mobile devices, causing them to autonomously download and store data content like software updates. Loughran also taught an "alert module" to power up a device from a low-power standby mode upon receiving an SMS, addressing a gap in Saylor regarding how turned-off devices could receive notifications.
    • Motivation to Combine: A POSITA would combine these references as they addressed the common problem of providing timely information to mobile users. Incorporating Loughran's data delivery and power-up methods into Saylor's security system would facilitate Saylor’s stated goal of promptly notifying users of alarm situations, even if a user's device was in standby mode. Using a GSM network, as taught by Loughran, was also a routine design choice for the cellular network disclosed in Saylor.
    • Expectation of Success: A POSITA would have reasonably expected success in combining these known elements, as it involved applying a known data delivery technique (Loughran) to a known remote monitoring system (Saylor) to achieve the predictable result of enhanced, persistent connectivity for alerts.

Ground 2: Claims 4, 19, and 21 are obvious over Saylor, Loughran, and Chow.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), and Chow (Application # 2002/0191557).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Saylor/Loughran combination by adding Chow. Petitioner asserted that Chow taught the use of a Virtual Private Network (VPN) to allow a user to remotely access home or office network resources. This directly mapped to the VPN limitation in claim 4. Chow also taught using a WCDMA cellular network and a high-speed IEEE 802.11b (WLAN) network, mapping to the limitations in claims 19 and 21.
    • Motivation to Combine: A POSITA would incorporate Chow's teachings to enhance the Saylor/Loughran system. Given the focus on mobile users in Saylor and Loughran, adding Chow's VPN capability was a logical step to allow users to access their home/office environments while mobile. Furthermore, incorporating Chow’s disclosure of newer, faster network technologies like WCDMA and WLAN was a predictable advancement over the base GSM network to improve data speeds for services like remote video viewing, a feature mentioned in Saylor.

Ground 3: Claim 5 is obvious over Saylor, Loughran, and GSM Security.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), and GSM Security (ETSI-GSM Technical Specification, Feb. 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds GSM Security to the base combination to teach the "key pair encryption scheme" of claim 5. Petitioner argued that GSM Security explicitly taught encrypting communications over a GSM network using an algorithm (A8) on both the mobile device and the network side to generate a key (Kc), which constitutes a necessary "pair" of keys for the encryption/decryption process.
    • Motivation to Combine: A POSITA would be motivated to add the encryption taught by GSM Security to the Saylor/Loughran system to protect the sensitive nature of the data being exchanged, such as images or video from a user's home security system. Since Loughran taught using a GSM network, applying the security functions specified for that network (as taught in GSM Security) was a necessary and obvious step to ensure secure communication.

Ground 4: Claim 22 is obvious over Saylor, Loughran, GSM Security, and Kuskin.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), GSM Security (ETSI-GSM Technical Specification, Feb. 1992), and Kuskin (Patent 7,185,196).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 22, which requires encryption over both a cellular network and the Internet. While the combination with GSM Security addressed cellular encryption, Kuskin was added to teach key-pair encryption for Internet communications. Kuskin disclosed a key caching system for WLANs where communications are "encrypted based on a key" and "decrypted using a key," which Petitioner asserted constituted a key-pair scheme.
    • Motivation to Combine: A POSITA would be motivated to add Kuskin's WLAN encryption to secure the Internet-based communications in Saylor's system. Kuskin explained that encryption is critical for wireless communications due to the sensitivity of data and the ease of eavesdropping. This rationale applied directly to the Saylor system, where sensitive home security data could be transmitted over the Internet.

4. Key Claim Construction Positions

  • "Consumer Device Asset": Petitioner argued for the construction "any fixed or mobile electronic device." This broad interpretation was based on the specification's wide-ranging examples (security devices, utility meters, laptops, phones) and the prosecution history of a related patent where the examiner found the term "asset" to be undefined and broad.
  • "Operational Status Information": Petitioner proposed the construction "data relating to the performance or functionality of a device asset." This was supported by specification examples like battery charge level and automobile performance parameters, as well as statements made during prosecution of a great-grandparent patent.
  • "Consumer Usage Information": Petitioner proposed the construction "data relating to an individual's interactions with a device asset or related devices." Petitioner argued the term was not limited to the owner's use of the communicating device itself but could include, for example, data from a utility meter about water usage (a related device) or motion sensor data.
  • "Management Instructions": Petitioner argued for the construction "commands for a device asset to perform particular actions." This was based on specification examples like instructions to lock doors, power down a module, or program a video recorder.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’007 patent as unpatentable.