PTAB

IPR2017-01896

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 registered with a remote computer server. The assets transmit operational status and consumer usage information to the server, which processes the information and sends management instructions back to the assets.

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 a central security server that monitors and manages security devices (e.g., cellular phones, home security panels), which automatically send operational status (e.g., on/off status) and consumer usage (e.g., alarm triggers) information to the server via packet-switched networks. Petitioner asserted Loughran supplemented Saylor by teaching a server that sends "management instructions" via SMS to a mobile device, causing it to autonomously download and store new content files. This combination, Petitioner argued, taught the automatic modification of stored data content files as required by the independent claims.
    • Motivation to Combine: A POSITA would combine the references because they share a common goal of promptly notifying users of important messages. Loughran’s teaching of an "alert module" that can power up a device from a low-power state to receive an SMS would have been a known, complementary solution to enhance Saylor's system, ensuring the timely delivery of security alerts even to powered-down devices.
    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success because combining a known remote monitoring system (Saylor) with a known data delivery mechanism (Loughran) involves familiar elements performing their expected functions to achieve the predictable result of enhanced alert delivery.

Ground 2: Claims 4, 19, and 21 are obvious over Saylor and Loughran in view of 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: Petitioner argued this combination rendered obvious claims that require communication over a Virtual Private Network (VPN) or compliance with specific wireless standards like WCDMA or WLAN. While Saylor and Loughran provided the base system, Chow was asserted to teach the use of VPNs to allow mobile users to access home or office network resources remotely. Chow also explicitly disclosed using newer wireless standards like WCDMA and IEEE 802.11b (WLAN) for high-speed network access.
    • Motivation to Combine: A POSITA would combine Chow with the Saylor/Loughran system to improve its functionality, security, and performance. Incorporating a VPN as taught by Chow would enable the secure remote access functionality contemplated by Saylor and Loughran. Adopting newer, faster network standards like WCDMA and WLAN from Chow was a predictable evolution to improve data transfer speeds, which is crucial for transmitting the surveillance video taught by Saylor.
    • Expectation of Success: The combination was presented as predictable, as it involved upgrading a communication system with well-known, superior technologies (VPN, WCDMA, WLAN) to achieve their known benefits of enhanced security, flexibility, and speed.

Ground 3: Claim 5 is obvious over Saylor and Loughran in view of 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 specifically addressed claim 5, which requires that communications are encrypted according to a key-pair scheme. Petitioner asserted that the GSM Security standard taught a key-pair encryption scheme (using a key Kc generated by both the mobile device and the network) to "cipher and decipher" communications over a GSM network, a network technology Loughran taught as preferred.
    • Motivation to Combine: A POSITA would combine the encryption taught by GSM Security into the Saylor/Loughran system to secure the communications. Given the private and sensitive nature of the data being exchanged in Saylor’s system (e.g., images and video from inside a user's home), securing those communications would have been a recognized need and a primary motivation for the combination.
    • Expectation of Success: Petitioner argued success would be expected because applying a standard encryption method (GSM Security) to a communication system (Saylor/Loughran) to achieve data security is a well-understood and predictable design choice.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 22, adding Kuskin (Patent 7,185,196) to the combination of Saylor, Loughran, and GSM Security to teach key-pair encryption for communications over the Internet (WLAN).

4. Key Claim Construction Positions

  • Petitioner proposed the broadest reasonable interpretation for several key terms to encompass the teachings of the prior art.
  • “Consumer Device Asset”: Petitioner argued for a broad construction of "any fixed or mobile electronic device," based on the patent's varied examples (security devices, utility meters, laptops) and the prosecution history of a related patent.
  • “Operational Status Information”: Construed as "data relating to the performance or functionality of a device asset," including examples like battery level or automobile performance parameters.
  • “Consumer Usage Information”: Construed broadly as "data relating to an individual's interactions with a device asset or related devices," not limited to the use of the communicating device itself but also including data from related sensors or meters.
  • “Management Instructions”: Construed as "commands for a device asset to perform particular actions," such as locking doors or recording a TV show.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that its grounds are not redundant with those in a concurrently filed IPR petition (IPR2017-01893). This petition's grounds are based on Saylor as the primary reference, whereas the other petition's grounds are based on a different primary reference (Kloba). Petitioner asserted the references and motivations to combine are distinct.

6. Relief Requested

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