PTAB

IPR2018-01050

Google LLC v. Seven Networks LLC

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1. Case Identification

2. Patent Overview

  • Title: Mobile Application Traffic Optimization
  • Brief Description: The ’019 patent discloses systems and methods for reducing network traffic and conserving battery power on a mobile device. The technology achieves this by aligning content requests from multiple applications based on observed user activity and then suppressing transmissions for defined periods to minimize radio activations.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5, 11, 12, 16, 19, and 20 are obvious over Black in view of Beninghaus.

  • Prior Art Relied Upon: Black (Application # 2011/0185202) and Beninghaus (Patent 8,185,165).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Black taught the core limitations of claim 1, including a mobile device that reduces traffic by delaying and aligning content requests from multiple applications to save battery life. Black's system synchronized polling transmissions based on observed user activity (e.g., detecting an active keypad or backlight) to establish "active times" with shorter synchronization intervals and "dormant times" with longer intervals. This dormant mode, where synchronous communication is disabled, corresponded to the claimed "first suppression period." However, Black did not explicitly teach a second, longer suppression period. Petitioner asserted that Beninghaus supplied this missing element by disclosing a two-tiered power-saving scheme: a standard "power save mode" (first suppression period) entered after an initial period of inactivity, and an "extended power save mode" (a longer, second suppression period) entered after a longer period of inactivity, during which transceivers are disabled for multiple consecutive beacon events.
    • Motivation to Combine: A POSITA would combine these references to solve the well-known problem of conserving mobile device battery power. Petitioner contended that a POSITA would have been motivated to incorporate Beninghaus's more advanced, two-level power-saving modes into Black's traffic alignment system to further minimize transceiver activity and improve power efficiency, which was a stated goal of Black.
    • Expectation of Success: The combination involved applying a known power management strategy (Beninghaus) to a known traffic optimization system (Black). This integration was argued to be a predictable implementation that would have yielded the expected benefit of enhanced battery conservation, well within the grasp of a POSITA.

Ground 2: Claims 1-3, 5, 11, 12, 16, 19, and 20 are obvious over Luoma in view of Black and Beninghaus.

  • Prior Art Relied Upon: Luoma (Application # 2010/0322124), Black (Application # 2011/0185202), and Beninghaus (Patent 8,185,165).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Luoma disclosed a system for conserving power by buffering non-real-time data and scheduling its transmission to occur during the radio's next active state or at a pre-scheduled time. This buffering and delayed transmission met the claim limitations of aligning and suppressing content requests for a first suppression period. However, Luoma's system determined the radio's active/inactive state based on radio events (like a phone call) rather than user interface interaction. Black was argued to supply this teaching by disclosing the monitoring of user interface activity—specifically "time since a last keypress"—to determine when a device is active or dormant. Finally, as in Ground 1, Beninghaus was cited for its teaching of an "extended power save mode," which provided the claimed second suppression period that is longer than the first.
    • Motivation to Combine: A POSITA would be motivated to combine these references to create a more robust and efficient power-saving solution. Petitioner argued a POSITA would integrate Black's user-activity detection into Luoma's system to more accurately predict periods of radio inactivity, thereby improving power conservation. Further incorporating Beninghaus's two-tiered power-saving modes would be a logical next step to further enhance battery life, a shared goal of all three references.
    • Expectation of Success: The proposed combination represented the integration of complementary and known power-saving techniques. Combining user interface monitoring (Black) with radio state management (Luoma) and multi-level power-down modes (Beninghaus) was a predictable path to achieving enhanced power management with a high expectation of success.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 11, 12, 16, 19, and 20 of the ’019 patent as unpatentable.