PTAB

IPR2018-00176

Hytera Communications Co Ltd v. Motorola Solutions Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Group Radio Communication System and Method Using Interconnected Radio Sub-Networks
  • Brief Description: The ’111 patent describes a group communication system that links multiple, independent radio sub-networks (e.g., conventional dispatch radio systems) using a packet-switched data network like the Internet. The system uses a central group controller to manage communications between sub-networks, while local sub-network controllers manage communications and resolve conflicts within their respective domains.

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 nearly all elements of the challenged claims, including a group communication system with multiple sub-networks, a group controller ("communication manager"), sub-network controllers ("MSCs"), and a packet-switched network. Petitioner contended that the key limitation added during prosecution—resolving communication conflicts at the local sub-network level—was also expressly taught by Maggenti, which stated its "arbitration device" could be located at the MSC (the sub-network controller). To the extent Maggenti was found insufficient, Shepherd was introduced as teaching a point-to-multipoint system where each radio sub-network has its own "central station" that explicitly resolves conflicts caused by simultaneous calls within that sub-network.
    • Motivation to Combine: A POSITA would combine Shepherd’s decentralized conflict resolution with Maggenti’s architecture to solve the known problem of performance bottlenecks caused by purely centralized processing. Placing conflict resolution at the sub-network level was a known technique for improving system efficiency and was a simple design choice.
    • Expectation of Success: A POSITA would have reasonably expected success in implementing Shepherd's well-understood local conflict resolution within Maggenti's system, as it involved applying a known solution to a known problem to achieve a predictable improvement in performance.

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 taught a group call system linking multiple communication "systems" (sub-networks) of different protocols, specifically referencing public projects like TETRA and Project 25. Grube disclosed linking these systems via a packet-switched network using sub-network controllers ("gateway ward controllers") and a group controller ("inter-ward interface"). Petitioner argued Grube disclosed all essential elements of the challenged claims except for the explicit, decentralized conflict resolution at the sub-network controller level. Shepherd was again relied upon to supply this teaching of local conflict resolution via its "central station" controllers.
    • Motivation to Combine: A POSITA would be motivated to add Shepherd's transmission privilege and conflict resolution scheme to the sub-network controllers in Grube's system for the obvious benefit of reducing network congestion and allowing urgent communications to take precedence.
    • Expectation of Success: The combination was argued to be predictable, as Grube’s system already contained the necessary components (the "gateway ward controllers") to implement Shepherd's conflict resolution logic, allowing for more efficient management of group calls within a single sub-network.

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 Stubbs was highly relevant because it explicitly taught linking conventional radio infrastructure, such as Motorola's own iDEN system, using a packet-switched network and converters. Stubbs disclosed the core architecture of multiple sub-systems linked via an external network with group control components. While Stubbs mentioned conflict resolution, Petitioner introduced Kent as teaching the specific advantages of decentralizing this function. Kent described a "distributed call arbitration process" at the sub-network level (a "multi-site switch") to avoid the performance bottlenecks and "single point of failure" inherent in a centralized arbitration scheme.
    • Motivation to Combine: A POSITA would be motivated by Kent's explicit teachings to implement its decentralized conflict resolution in the system of Stubbs. Kent’s clear articulation of avoiding bottlenecks and single points of failure provided a strong rationale for modifying Stubbs’s architecture to improve reliability and performance.
    • Expectation of Success: Petitioner asserted that the network structures in Stubbs and Kent were nearly identical, making the substitution of Kent's "Multi-Site Switch" for Stubbs's controller a straightforward and predictable design choice that would yield the expected benefits described in Kent.

4. Relief Requested

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