Google LLC v. Seven Networks LLC

1. Case Identification

• Case #: IPR2018-01051
• Patent #: 9,516,127
• Filed: May 18, 2018
• Petitioner(s): Google LLC
• Patent Owner(s): SEVEN Networks, LLC
• Challenged Claims: 10-23

2. Patent Overview

• Title: Systems and Methods for an Intelligent Alarm Manipulator
• Brief Description: The ’127 patent discloses methods for conserving mobile device resources, such as battery and CPU, by manipulating the timing of triggers (e.g., alarms, timers) used by applications. During a "power save mode," the system delays and groups these triggers to execute together within a specific window of time, reducing resource consumption.

3. Grounds for Unpatentability

Ground 1: Obviousness over Giaretta, Felker, and Lando - Claims 10-15, 17-20, and 22-23 are obvious over Giaretta in view of Felker and Lando.

• Prior Art Relied Upon: Giaretta (Patent 9,264,868), Felker ("Reminding the User with AlarmManager," a 2011 book), and Lando (Application # 2008/0242370).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Giaretta taught the core invention: a mobile device that conserves battery power by delaying and aggregating network-access requests from multiple applications when the device is in a "background mode." Giaretta disclosed entering this mode based on various inactivity indicators, including display status and lack of motion sensed by an accelerometer. To meet the specific "backlight status" limitation, Petitioner asserted a POSITA would look to Lando, which explicitly taught entering a power-saving mode based on backlight status and motion. To meet the "wakelocks" limitation, Petitioner relied on Felker, which described how Android’s standard Alarm Manager holds a CPU wakelock, a feature Petitioner argued was a known and obvious implementation choice for any power management system on the dominant Android platform.
  • Motivation to Combine: A POSITA implementing Giaretta's power-saving concepts on an Android device would have been motivated to consult standard references like Lando for common inactivity triggers (e.g., backlight status) and Felker for standard platform features (e.g., wakelocks). The motivation was to use well-known, predictable components to achieve the known goal of power conservation on a popular mobile operating system.
  • Expectation of Success: Combining these elements was argued to be a predictable application of known techniques. Using backlight status and motion to detect inactivity and using standard wakelocks to manage device sleep state were established functions that would predictably enhance Giaretta's power-saving framework.

Ground 2: Obviousness over Lin, Lando, and Felker - Claims 10-12, 14, 15, 17-20, and 22-23 are obvious over Lin in view of Lando and Felker.

• Prior Art Relied Upon: Lin (Patent 9,474,022), Lando (Application # 2008/0242370), and Felker (a 2011 publication).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner presented Lin as an alternative primary reference that disclosed a method for saving power by delaying and aligning "wakeup events" from various applications to commence at specific "alignment processing moments." Lin taught entering this standby mode when the phone's display screen is off. Petitioner argued a POSITA would find it obvious to supplement Lin's display-off trigger with the "sensed motion" trigger taught by Lando for more robust inactivity detection. As with the Giaretta-based ground, Petitioner argued that because Lin was implemented on an Android platform, a POSITA would naturally incorporate the standard wakelock functionality described in Felker.
  • Motivation to Combine: The motivation was to improve Lin's power-saving system. A POSITA would combine Lin with Lando to create a more accurate inactivity detection mechanism by using multiple sensors (display/backlight and motion). Since Lin's system operated on Android, incorporating standard Android features like the wakelock mechanism described by Felker was presented as a straightforward implementation step.
  • Expectation of Success: The combination involved applying known sensor inputs (Lando) and OS features (Felker) to an existing power management framework (Lin), which would predictably result in improved power savings without undue experimentation.

Ground 3: Obviousness over Giaretta, Lando, Felker, and Sengottaiyan - Claims 16 and 21 are obvious over the combination of Giaretta, Lando, and Felker in further view of Sengottaiyan.

• Prior Art Relied Upon: Giaretta (Patent 9,264,868), Lando (Application # 2008/0242370), Felker (a 2011 publication), and Sengottaiyan (EP 2343930).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed dependent claims 16 and 21, which required entering and exiting the power-save mode based on the "charging status" of the device. Petitioner argued that while the primary combination established the core power-saving features, Sengottaiyan explicitly taught a battery-aware algorithm that did precisely what the claims required: entering a power-save mode when the device is on battery power and exiting when it is plugged into an external power source (i.e., charging).
  • Motivation to Combine: A POSITA would have been motivated to incorporate Sengottaiyan's teachings for a simple and logical reason: power-saving measures are only necessary when a device is draining its battery. Disabling these measures when the device is charging is an obvious optimization to improve performance when power is not a constraint. This modification would make the power-saving system of Giaretta/Lando more efficient and context-aware.
• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations based on Lin in further view of Black (for optimizing CPU/memory use) and Lin in further view of Sengottaiyan (for charging status), which relied on similar motivation and design modification theories.

4. Key Claim Construction Positions

• "Triggers": Petitioner proposed this term, found in the independent claims, be construed as "alarms and timers used by applications to schedule tasks," based on explicit definitions in the ’127 patent specification.
• "Alarm": For dependent claims, Petitioner proposed this term be construed as "a trigger used by applications to schedule tasks at a particular time," distinguishing it from a timer that elapses, which was argued to be consistent with a POSITA's understanding.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 10-23 of the ’127 patent as unpatentable.