PTAB

IPR2018-01093

Apple Inc. v. Uniloc Luxembourg S.A.

Log In

1. Case Identification

2. Patent Overview

  • Title: System and Method for Detecting and Signaling a Critical Event
  • Brief Description: The ’353 patent discloses a personal safety alert system, typically in a small, portable device. The system acquires and continuously analyzes a stream of "digitized signature data" (e.g., biometric or audio data) to determine an "event context," assess its criticality, and generate an appropriate reporting response, such as an alert to a remote location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lemelson in view of Zhou - Claims 1-20 are obvious 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 argued that Lemelson discloses the core features of the challenged claims. Lemelson teaches a portable medical monitoring system that receives input data (e.g., heart rate, spoken words like "help"), compares it to stored "abnormal medical conditions" or a "speech library" (a glossary of signature data), determines if a medical alert is warranted (assessing criticality), and alerts a remote command center (a reporting response). Petitioner contended that Lemelson's continuous "monitoring" inherently teaches repeatedly analyzing a "stream" of data. To the extent Lemelson is deficient, Zhou was argued to supply the missing elements. Zhou explicitly teaches a system for tracking individuals that "periodically" monitors biological parameters (e.g., every ten minutes), which Petitioner asserted constitutes "repeatedly analyzing." Zhou also discloses user-configurable "alert thresholds" and a two-level evaluation system where an initial alert from a user device is filtered by a more sophisticated evaluation at a remote server using logical rules, which could inhibit the final alert.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Zhou's teachings with Lemelson's system to create a more comprehensive, intelligent, and marketable product, consistent with Lemelson's own stated goals. Specifically, incorporating Zhou's user-configurable periodic analysis would improve power efficiency for a battery-powered device. Adding Zhou's user-configurable alert thresholds would make the device more versatile and desirable to a wider range of consumers, allowing users to customize alert sensitivity for different situations (e.g., post-surgery recovery versus intense physical training). The ability to perform sophisticated, second-level filtering at a remote location, as taught by Zhou, would reduce the processing burden and cost of the local warning unit.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Implementing periodic monitoring and user-configurable thresholds were well-known functionalities at the time. Combining them with Lemelson's established monitoring framework would have involved applying known techniques to a known system to achieve predictable improvements in power consumption and user customizability, without requiring undue experimentation.

4. Key Claim Construction Positions

  • "signature data": Petitioner argued this term should be construed as “data that defines recognizable characteristics of an event.” This construction was based on the specification's examples, such as biometric data indicating an abnormal medical condition or audio data matching a "scream signature."
  • "glossary": Petitioner proposed this term means a “stored collection of signature data.” This was based on the patent's description of a glossary being like a "database or other file repository" that organizes signature data, such as a collection of biometric data or sounds.
  • "configuration data" / "configuration setting": Petitioner asserted these terms must include a “user-configured setting.” This position relied on the specification's teaching that the configuration database settings, which control system sensitivity and thresholds, may be "user-configured."

5. Key Technical Contentions (Beyond Claim Construction)

  • "Monitoring" Implies Repeated Analysis of a "Stream": A central technical contention was that a POSITA would have understood that the term "monitoring" as used in the prior art (e.g., Lemelson's system that "monitors" medical conditions) inherently implies a continuous or periodic process of analyzing a "stream" of data. Petitioner argued that a single, isolated observation would fail to "monitor" a user's condition effectively and would almost certainly miss critical events, making repeated analysis a necessary and implicit feature of such a system.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-20 of the ’353 patent as unpatentable.