LG Electronics Inc v. Koninklijke KPN NV

1. Case Identification

• Case #: IPR2018-00558
• Patent #: 9,014,667
• Filed: February 1, 2018
• Petitioner(s): LG Electronics, Inc.
• Challenged Claims: 31, 33, and 35

2. Patent Overview

• Title: Telecommunications Network and Method for Time-Based Network Access
• Brief Description: The ’667 patent discloses a system for managing access to a telecommunications network to regulate resource use during periods of high demand. The system uses a register to store unique terminal identifiers and associated "deny access time intervals" to block access from specific terminals, particularly those used for machine-to-machine (M2M) applications, during peak network load.

3. Grounds for Unpatentability

Ground 1: Obviousness over Obhan, Shatzkamer, and Budka - Claims 31 and 33 are obvious over Obhan in view of Shatzkamer and Budka.

• Prior Art Relied Upon: Obhan (Patent 6,275,695), Shatzkamer (Application # 2008/0220740), and Budka (E.P. Publication # EP1009176 A2).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Obhan discloses the core system of the ’667 patent: a telecommunications network that manages access based on monitored network load. Obhan teaches denying access to low-priority users during peak load intervals using an Admission Control Block (ACB) that functions as a register. However, Obhan uses access class identifiers, not unique terminal identifiers. Petitioner asserted that Shatzkamer remedies this by teaching access control based on unique identifiers (e.g., IMSI) stored in a list to deny service for specific periods. Finally, Budka was cited to supply the well-known, standard practice in GSM networks (the type disclosed in Obhan) where a terminal initiates access by sending a request containing its unique identifier. The combination, therefore, taught a network that stores unique identifiers with deny access time intervals and denies access based on receiving an access request from a terminal with a matching identifier within that interval, as claimed.
  • Motivation to Combine: A POSITA would combine Obhan with Shatzkamer to increase the granularity of Obhan’s access control. Replacing Obhan’s class-based system with Shatzkamer’s unique identifier-based method was presented as a predictable modification to achieve finer, terminal-specific control. A POSITA would have incorporated Budka’s teachings on access requests because it described the standard and necessary procedure for a terminal to initiate contact in the GSM network environment of Obhan, making it a natural and obvious implementation detail.
  • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because the combination involved substituting known elements (unique identifiers for class identifiers) and applying standard industry protocols (GSM access requests) for their intended purposes, yielding predictable improvements in access control resolution and functionality.

Ground 2: Obviousness over Obhan, Taniguchi, and Budka - Claim 35 is obvious over Obhan in view of Taniguchi and Budka.

• Prior Art Relied Upon: Obhan (Patent 6,275,695), Taniguchi (Patent 7,505,755), and Budka (E.P. Publication # EP1009176 A2).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground focused on claim 35, which requires the terminal itself to comprise a message receiver for receiving information relating to the deny access time interval. Petitioner argued that while Obhan teaches a network that controls access, it does not explicitly disclose sending the deny access interval information to the terminal. Taniguchi was asserted to teach this missing element by disclosing a system where a terminal receives a "communication restriction signal" that includes "communication restriction period information." This signal informs the terminal of the denial period, causing it to be "restricted or inhibited from getting access," thereby preventing futile access attempts. Obhan provided the foundational load-based access control system, and Budka again supplied the standard association of a terminal with a unique identifier.
  • Motivation to Combine: A POSITA would be motivated to modify Obhan’s system with the teachings of Taniguchi to improve overall network efficiency. By proactively informing terminals of access denial periods, as taught by Taniguchi, the network avoids wasting resources processing access requests that are certain to be rejected. This modification directly serves Obhan's primary goal of managing network load and preserving resources during peak times.
  • Expectation of Success: There would be a high expectation of success, as implementing a notification message to terminals is a straightforward and known technique for improving network performance. Combining Taniguchi's notification method with Obhan's load management system would predictably result in a more efficient network by reducing unnecessary signaling.

4. Key Claim Construction Positions

• deny access time interval: Petitioner proposed this term be construed as "a time slot during which access to the telecommunications network is denied." This construction was argued to be consistent with the specification, which describes the intervals as "time slots" and states that grant and deny intervals are equivalents.
• machine-to-machine applications: Petitioner proposed this term encompass "applications that allow for data communication between devices and that normally operate without human intervention." This was based on the patent’s description of M2M applications involving devices like electricity meters that rarely require access and do not need immediate data transfer.
• register: Petitioner argued this term should be construed broadly as "a device with storage." This was supported by the claim language requiring the register to "store" identifiers and the specification providing examples like a home location register (HLR), a known storage device.