PTAB

IPR2018-00199

Unified Patents LLC v. Uniloc Luxembourg SA

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Petition

1. Case Identification

2. Patent Overview

  • Title: Automated Telephone Dialing System
  • Brief Description: The ’671 patent discloses an automated telephone dialing system where a handheld computer system, such as a PDA, displays a list of selectable telephone numbers. The handheld computer is configured to control a separate telephone via a short-range wireless communication link to automatically dial a selected number, removing the need for manual dialing.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yun, Langlois, and Dykes

  • Claims 1-6 and 9-14 are obvious over Yun in view of Langlois and Dykes.
    • Prior Art Relied Upon: Yun (Patent 6,084,949), Langlois (UK Application Publication No. GB 2318703), and Dykes (Patent 5,428,671).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner argued that Yun taught the core system of an electronic pocketbook that wirelessly transmits a selected phone number with an integrated electronic dial request to a telephone, causing it to dial automatically. To address the limitation of selecting a number from a list, Petitioner cited Langlois, which taught a computer executing a software application that displayed user contacts in various list formats (e.g., Phonebook, Speed Dial) from which a user could select a number to dial. To address the specific method of controlling the telephone, Petitioner introduced Dykes, which disclosed the well-known method of controlling a modem or cellular phone from a computer by first sending the telephone number and then sending a separate command (e.g., a "SEND" command from the standard Hayes AT command set) to initiate dialing.
      • Motivation to Combine: A POSITA would combine Yun with Langlois's list-based interface to improve usability and provide a more interactive and conventional user experience for contact selection. A POSITA would further incorporate the teachings of Dykes to replace Yun's integrated control signal with Dykes's more flexible and standardized two-step (number then command) control protocol, which was a well-known design choice for controlling remote dialing functions. This combination represented the routine substitution of one known element for another to obtain a predictable result.
      • Expectation of Success: Petitioner asserted a high expectation of success, as combining a known list-based user interface and a standard command protocol with a basic remote dialing system involved conventional software techniques and would predictably result in an improved, but obvious, system.

Ground 2: Obviousness over Harris, Langlois, and Dykes

  • Claims 1-7 and 9-15 are obvious over Harris in view of Langlois and Dykes.
    • Prior Art Relied Upon: Harris (Patent 6,738,643), Langlois (UK Application Publication No. GB 2318703), and Dykes (Patent 5,428,671).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner presented Harris as an alternative primary reference that disclosed a PDA wirelessly associated with a telephone. When a user selected an icon corresponding to a contact, the PDA would command the telephone to automatically dial the number. As in Ground 1, Petitioner argued that Langlois supplied the explicit teaching of displaying contacts in a selectable list format, a feature not explicitly detailed in Harris. Likewise, Dykes was again cited to teach the conventional method of controlling the telephone by transmitting the number and a separate, subsequent command to dial. This addressed the ’671 patent’s claimed configuration of the handheld computer "controlling" the telephone "such that" it dials.
      • Motivation to Combine: The motivation to combine was analogous to Ground 1. A POSITA would combine Harris with Langlois to enhance the user interface with a conventional and user-friendly list-based selection mechanism. The motivation to incorporate Dykes was to implement a more robust and flexible control system using a standard command set, which was a known and available solution to the problem of remote device control and dialing.
      • Expectation of Success: The combination was a predictable integration of known user interface elements (Langlois) and standard control protocols (Dykes) into the base system of Harris. Petitioner argued this would have been a straightforward implementation for a POSITA with a high likelihood of success.

Ground 3: Obviousness over Core References in view of Husemann

  • Claims 7, 8, 15, and 16 are obvious over the combinations of Yun/Harris, Langlois, and Dykes, in further view of Husemann.
    • Prior Art Relied Upon: Husemann (Patent 7,577,910) added to the combinations from the grounds above.
    • Core Argument for this Ground:
      • Prior Art Mapping: This argument targeted the dependent claims requiring compatibility with specific wireless protocols: Bluetooth (claims 7, 15) and IrDA (claims 8, 16). Petitioner asserted that while the primary references taught short-range wireless communication (infrared in Yun; generic short-range in Harris), Husemann was necessary to explicitly teach the use of these specific, standardized protocols. Husemann disclosed a system for controlling one computing device from another over a wireless network and explicitly identified both Bluetooth and IrDA as suitable communication protocols.
      • Motivation to Combine: A POSITA would be motivated to modify the systems of Yun or Harris to use standardized protocols like Bluetooth or IrDA, as taught by Husemann, to achieve greater interoperability and compatibility with the growing ecosystem of devices using these standards. Using a standardized protocol instead of a proprietary one was a common and obvious design choice to broaden a product's marketability and utility.
      • Expectation of Success: Success was highly likely because Bluetooth and IrDA were well-understood, standardized protocols with defined implementation details. Incorporating these known protocols into the prior art systems would have been a routine task for a skilled artisan.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of Patent 7,092,671 as unpatentable.