PTAB

IPR2018-01093

Apple Inc v. Uniloc Luxembourg SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Personal Safety Alert System
  • Brief Description: The ’353 patent describes a system and method for detecting a "critical event" using a portable device. The system acquires and continuously analyzes a stream of digitized signature data (e.g., biometric data like heart rate) to determine an event context, assesses the event's priority, and generates a reporting response, such as an alert to a remote location.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-20 over Lemelson in view of Zhou

  • Prior Art Relied Upon: Lemelson (Patent 6,028,514) and Zhou (Patent 6,847,892).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Lemelson disclosed the core invention of the ’353 patent. Lemelson teaches a portable warning unit with a medical monitoring system that receives input data (e.g., biometric signals, audio) and continuously compares it to stored data defining abnormal conditions (a "glossary"). This comparison determines an "event context" (e.g., a medical emergency or distressful situation). Lemelson's system then assesses the "criticality" of the event by determining if a "variance of predefined degree" exists, and in response, determines and transmits a "reporting response" (an alert) to a central command center. Petitioner contended this process met all limitations of independent claim 1.

      For limitations not explicitly taught by Lemelson, Petitioner argued Zhou supplied the missing elements. Specifically, Zhou was cited for its teaching of user-configurable "alert thresholds," which Petitioner mapped to the "configuration setting" required by dependent claims 6, 7, and 18. Zhou also disclosed a two-level alert evaluation system: a basic evaluation at the local device and a more sophisticated evaluation with logical rules at a remote server (ASP). Petitioner argued this remote evaluation, which could inhibit an alert based on complex criteria, taught the "filtering" and "inhibiting the reporting response" limitations of claims 7 and 8. Finally, Zhou's teaching of "periodically" monitoring biological parameters was used to bolster the argument that Lemelson's "monitoring" system inherently performed the "repeatedly analyzing" step of claim 1.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Lemelson and Zhou to create a more comprehensive, intelligent, and commercially desirable warning system. Incorporating Zhou’s user-configurable thresholds into Lemelson's system would be motivated by the desire to allow users to customize alert sensitivity, making the device more adaptable to individual needs (e.g., for elderly users versus athletes). Further, implementing Zhou's two-level filtering (with sophisticated analysis at a remote server) would reduce the processing load and power consumption of the local device, predictably resulting in longer battery life and lower manufacturing costs.

    • Expectation of Success: The petition asserted that a POSITA would have a reasonable expectation of success in combining the references. The proposed modifications involved implementing well-known functionalities, such as user-configurable settings and periodic device operation, which would produce the predictable result of a more versatile and efficient personal alert system without requiring undue experimentation.

4. Key Claim Construction Positions

  • "signature data" (claims 1, 2, 5, 12, 15, 17): Petitioner proposed this term be construed as “data that defines recognizable characteristics of an event.” This construction was argued to be critical for mapping data from Lemelson's system, such as biometric signals indicating a heart attack or specific spoken words like "help," to the claimed "signature data."
  • "glossary" (claims 5, 12, 15, 17): Petitioner proposed the construction “a stored collection of signature data.” This was important for mapping Lemelson’s disclosure of a “speech library” and memory storing data that defines “abnormal medical conditions” to the claimed “glossary.”
  • "configuration data" / "configuration setting" (claims 6, 7, 18): Petitioner argued this phrase requires a “user-configured setting.” This construction was central to the obviousness argument, as it created the need to look beyond Lemelson to a reference like Zhou, which explicitly teaches user-configurable alert thresholds.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of Patent 7,944,353 as unpatentable under 35 U.S.C. §103.