PTAB

IPR2018-00176

Hytera Communications Co. Ltd. v. Motorola Solutions, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Group Radio Communication System and Method Using Interconnected Radio Sub-Networks
  • Brief Description: The ’111 patent discloses a system and method for creating a large-scale group communication network by linking multiple, independent "radio sub-networks." These sub-networks are connected via a packet-switched data network (such as the Internet) and managed by a central group controller to facilitate point-to-multipoint communications across the entire system.

3. Grounds for Unpatentability

Ground 1: Claims 1, 6-7, 11-13, and 15-16 are obvious over Maggenti in view of Shepherd.

  • Prior Art Relied Upon: Maggenti (Patent 6,301,263) and Shepherd (Patent 5,398,248).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Maggenti disclosed a point-to-multipoint communication system with nearly every element of the challenged claims, including multiple radio sub-networks (of different types like radio, data, and satellite), a central "communication manager" (group controller), and a connecting packet-switched network. Petitioner contended that the only element the patent examiner previously found missing in Maggenti was conflict resolution occurring at the decentralized, sub-network level. Shepherd was argued to supply this missing element by teaching a system where each radio sub-network has its own "central station" (sub-network controller) that resolves local conflicts for simultaneous call requests.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Shepherd's decentralized conflict resolution with Maggenti's system to overcome the known problems of performance bottlenecks and a single point of failure associated with purely centralized arbitration. Locating conflict resolution at the sub-network level was a known technique to improve system efficiency and reliability.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved applying a known solution (decentralized arbitration) to a known system architecture (interconnected networks) to achieve the predictable result of a more robust and efficient communication system.

Ground 2: Claims 1, 6-7, 11-13, and 15-16 are obvious over Grube in view of Shepherd.

  • Prior Art Relied Upon: Grube (Patent 5,987,331) and Shepherd (Patent 5,398,248).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Grube, a patent assigned to the Patent Owner, taught a group communication system linking multiple "systems" (analogous to the ’111 patent's sub-networks) with different protocols via a packet-switched network and a central "Inter-Ward Interface." Grube explicitly taught linking systems like Motorola’s own iDEN network and included elements like sub-network controllers ("gateway ward controllers") and converters ("transcoders"). As with Maggenti, Petitioner argued Grube taught all essential elements except for the specific decentralized conflict resolution recited in the claims. Shepherd was again relied upon to teach resolving conflicts at the individual sub-network controller level.
    • Motivation to Combine: A POSITA would be motivated to integrate Shepherd’s decentralized conflict resolution into Grube’s system for the same reasons as with Maggenti: to improve system performance by reducing congestion and to increase reliability by avoiding a single point of failure at the central group controller.
    • Expectation of Success: Combining Shepherd's known conflict resolution method with Grube's highly similar network architecture would predictably yield a more efficient system, as Grube already provided the necessary components at the sub-network level to implement such a feature.

Ground 3: Claims 1, 6-7, 11-13, and 15-16 are obvious over Stubbs in view of Kent.

  • Prior Art Relied Upon: Stubbs (WO 99/63773) and Kent (Patent 5,659,881).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stubbs, which also references Motorola’s iDEN system, taught linking conventional radio sub-networks (PLMNs) using a packet-switched network (an IP network) and converters (GGSN/SGSN nodes). Stubbs disclosed a group controller structure (management terminal, HLR, PUD) and sub-network controllers (BSCs). To supply the specific conflict resolution limitation, Petitioner cited Kent, which taught a "multi-site switch" (a sub-network controller) that performs decentralized arbitration to resolve call contention when multiple callers try to transmit at nearly the same time. Kent’s arbitration scheme, using a "busy flag," was argued to be nearly identical to the "token" system in the ’111 patent.
    • Motivation to Combine: A POSITA would combine Kent's decentralized arbitration with Stubbs's network because Kent explicitly touted its approach as advantageous for avoiding the "performance bottleneck and 'single point of failure'" of conventional centralized arbitration. Given the nearly identical system structures in Stubbs and Kent, a POSITA would be motivated to substitute Kent's arbitration method into Stubbs's system to achieve these known benefits.
    • Expectation of Success: The combination was presented as a straightforward integration. A POSITA would expect success in adding Kent’s well-defined conflict resolution function to the packet handler or GGSN components of the Stubbs system, yielding the predictable result of a more robust group communication network.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 6-7, 11-13, and 15-16 of the ’111 patent as unpatentable.