PTAB

IPR2017-01896

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 ’359 patent discloses a system for autonomously monitoring and managing a plurality of "consumer device assets" (e.g., security devices, utility meters, cellular phones) registered with a remote server platform. The assets transmit "consumer usage" and "operational status" information to the server, which in turn processes the information and sends "management instructions" back to the assets.

3. Grounds for Unpatentability

Ground 1: Obviousness over Saylor and Loughran - 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 independent claim 1: a central security server that autonomously monitors and manages a plurality of consumer devices (e.g., home security panels, mobile phones). Saylor's server receives operational status (on/off) and consumer usage (alarm triggers) information and sends notifications. Petitioner asserted that Loughran supplied the missing limitation of the server sending "management instructions" that cause stored data files on an asset to be automatically modified. Loughran disclosed a server that sends SMS messages containing instructions for a mobile device to autonomously download and store new data, such as software updates or emails. The combination of Saylor's monitoring system with Loughran's data-pushing instruction method rendered the claims obvious.
    • Motivation to Combine: Petitioner contended a POSITA would combine Saylor and Loughran to solve the common problem of promptly and reliably delivering important information to mobile users. Loughran’s teachings on how to deliver data even when a device is off (via a low-power "alert module") and without user action were seen as a natural and complementary improvement to Saylor’s alarm notification system. Incorporating Loughran’s method would further Saylor’s goal of "promptly notifying" users by ensuring alarm-related data (images, videos) was pre-loaded and ready for viewing, a predictable combination of known elements.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the known server-client monitoring architecture of Saylor with the well-understood data delivery protocol of Loughran to yield a predictable improvement in notification speed and reliability.

Ground 2: Obviousness over Saylor, Loughran, and Chow - Claims 4, 19, and 21 are obvious over the combination of 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 built upon the Saylor/Loughran combination to address claims requiring specific network technologies. Petitioner argued that Chow taught the use of a Virtual Private Network (VPN) for communications between a device and server (claim 4). Chow also disclosed the use of more advanced cellular networks like Wideband CDMA (WCDMA) and wireless local area networks (WLAN) based on the IEEE 802.11b standard to provide high-speed internet access (claims 19 and 21).
    • Motivation to Combine: A POSITA would combine Chow with the primary references to improve the Saylor/Loughran system with newer, faster, and more secure networking technologies. Incorporating a VPN as taught by Chow would enhance security, while using WCDMA or WLAN would increase data transfer speeds for services like remote video surveillance—a feature disclosed in Saylor. Petitioner argued this was a predictable design choice reflecting the general trend toward adopting more advanced communication protocols.

Ground 3: Obviousness over Saylor, Loughran, and GSM Security - Claim 5 is obvious over the combination of Saylor, Loughran, and GSM Security.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), and GSM Security (an ETSI technical specification published in 1992).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted claim 5, which recites that communications are encrypted according to a key-pair encryption scheme. Loughran taught using a GSM network. Petitioner asserted that the GSM Security standard, which defines the security functions for such networks, explicitly disclosed an optional key-pair encryption scheme. In this scheme, both the mobile device and the network use a shared algorithm to generate a key (Kc), which forms a "pair" used to encrypt and decrypt communications.
    • Motivation to Combine: A POSITA would have been motivated to implement the encryption scheme taught by GSM Security into the Saylor/Loughran system to protect the sensitive data being transmitted, such as images or video from a user's home security system. Securing communications was a known and important consideration, and applying the standard-defined security features of the underlying GSM network was an obvious step to enhance system security.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 22 based on the combination of Saylor, Loughran, GSM Security, and Kuskin (Patent 7,185,196). Kuskin was added to teach key-pair encryption for communications over the Internet via a WLAN, complementing GSM Security's teachings for cellular networks.

4. Key Claim Construction Positions

  • "Consumer Device Asset": Petitioner argued for a broad construction of "any fixed or mobile electronic device." This construction was asserted to be consistent with the specification's varied examples (security devices, laptops, phones) and necessary to prevent the Patent Owner from improperly narrowing the claims to distinguish the prior art.
  • "Consumer Usage Information": Petitioner proposed the construction "data relating to an individual's interactions with a device asset or related devices." This broad interpretation was based on specification examples like utility meter readings and motion detection, which relate to devices other than the primary communicating asset.
  • "Management Instructions": Petitioner proposed the construction "commands for a device asset to perform particular actions." This interpretation was based on specification examples like instructing a module to power down or a video recorder to program itself, framing the term as a simple command structure.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-30 of Patent 8,577,359 as unpatentable under 35 U.S.C. §103.