PTAB

IPR2018-01051

Google LLC v. SEVEN Networks, LLC

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1. Case Identification

2. Patent Overview

  • Title: Power Management Based on Application Triggers
  • Brief Description: The ’127 patent describes systems 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 aligns these triggers to execute within a common time window, reducing resource consumption.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Giaretta (Patent 9,264,868), Lando (Application # 2008/0242370), and Felker ("Android Application Development for Dummies" (2011)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Giaretta taught the core concept of the invention: delaying and aggregating application timers (the patent’s "triggers") to execute within a "communication window" to conserve battery power when a device is in a background or "power save" mode. Lando was cited to teach entering this power-save mode based on sensing user inactivity, specifically by monitoring both the device’s backlight status and its motion (or lack thereof). Felker, a guide for the Android OS, was asserted to teach the "wakelocks" limitation, explaining that Android’s AlarmManager holds a CPU wakelock to prevent the phone from sleeping while a task executes, a known technique for managing scheduled events.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to implement Giaretta’s power-saving techniques on the Android platform, which was the dominant mobile OS. To do so, a POSITA would logically incorporate well-known Android features for managing power and tasks. This would include using Lando's conventional methods for detecting user inactivity (backlight and motion) and implementing event handling using Android's native AlarmManager, which, as taught by Felker, inherently uses wakelocks.
    • Expectation of Success: A POSITA would have reasonably expected success, as combining these elements involved applying known power-saving principles (Giaretta), standard inactivity detection methods (Lando), and a standard OS-level feature (Felker's wakelocks) for their intended and predictable functions.

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 ("Android Application Development for Dummies" (2011)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Lin as an alternative primary reference that, like Giaretta, disclosed the core concept of delaying and aligning "wakeup events" (i.e., triggers) for multiple applications in an Android device to reduce power consumption. Lin teaches aligning events to common "processing moments" after the device enters a standby mode, which is triggered when the display screen is off. The arguments for combining Lin with Lando and Felker mirrored those in Ground 1: Lando supplied the explicit teaching of using both backlight status and sensed motion to trigger power-save mode, and Felker provided the known use of wakelocks within the Android framework specified by Lin.
    • Motivation to Combine: The motivation was to improve upon Lin’s power-saving method. A POSITA would enhance Lin's standby detection (screen off) by incorporating Lando's more comprehensive inactivity detection (motion and backlight) to create a more effective power-saving mode. As Lin's system was designed for Android, a POSITA would naturally consult a reference like Felker to implement wakeup events, thereby incorporating the standard use of wakelocks.
    • Expectation of Success: The combination was argued to be a predictable integration of known techniques on a single platform (Android) to achieve the expected result of improved power management.

Ground 3: Obviousness over Giaretta, Lando, Felker, and Sengottaiyan - Claims 16 and 21 are obvious over the combination for Ground 1 in further view of Sengottaiyan.

  • Prior Art Relied Upon: Giaretta (Patent 9,264,868), Lando (Application # 2008/0242370), Felker ("Android Application Development for Dummies" (2011)), and Sengottaiyan (EP 2343930).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address dependent claims 16 and 21, which add the limitation of entering and exiting power-save mode based on the device's "charging status." Petitioner asserted that Sengottaiyan taught a battery-aware algorithm that explicitly considered a device's charging status to manage power. Sengottaiyan’s system enters power-save mode when on battery power and exits when plugged into an external power source.
    • Motivation to Combine: A POSITA implementing the power-saving system of Giaretta and Lando would be motivated to add charging status awareness as taught by Sengottaiyan for a simple reason: the primary goal of conserving battery is irrelevant when the device is actively charging. Adding this logic would be an obvious and desirable improvement to make the power-saving feature more intelligent and efficient.
    • Expectation of Success: A POSITA would have had a high expectation of success in adding this feature, as it is a straightforward and predictable enhancement to any battery conservation system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Lin with Lando, Felker, and Black (Application # 2010/0274507) to teach optimizing CPU/memory resources, and Lin with Lando, Felker, and Sengottaiyan to teach using charging status. These grounds relied on similar rationales of combining a primary system with references teaching specific, known technological improvements.

4. Key Claim Construction Positions

  • "Triggers": Petitioner proposed this term, found in independent claims 10 and 17, should be construed as "alarms and timers used by applications to schedule tasks." This construction was based on the patent’s specification and was crucial for mapping the claims onto prior art references like Giaretta and Lin, which explicitly discuss managing timers and alarms for power savings.
  • "Alarm": For dependent claims 11 and 18, Petitioner proposed construing "alarm" as "a trigger used by applications to schedule tasks at a particular time." This distinguished alarms from timers (which trigger after an elapsed duration) and aligned with how a POSITA would understand the different trigger types discussed in the prior art.

5. Relief Requested

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