PTAB

IPR2018-01108

Samsung Electronics Co., Ltd. v. SEVEN Networks, LLC

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1. Case Identification

2. Patent Overview

  • Title: INTELLIGENT ALARM MANIPULATOR AND RESOURCE TRACKER
  • Brief Description: The ’127 patent describes systems and methods for intelligently manipulating alarms and timers to optimize resource usage on a mobile device. The technology centers on an intelligent alarm manager that adjusts the timing of triggers across multiple applications, causing them to execute concurrently to conserve resources like battery power and network bandwidth.

3. Grounds for Unpatentability

Ground 1: Claims 1-23 are obvious over Chueh in view of Backholm and Srinivasan.

  • Prior Art Relied Upon: Chueh (Application # 2014/0195839), Backholm (Application # 2012/0023236), and Srinivasan (Application # 2014/0038674).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chueh taught the core concept of the ’127 patent: managing and aligning wake-up events (triggers) for multiple applications to occur at the same time, thereby reducing power consumption. To address claim limitations not explicitly in Chueh, Petitioner asserted that Backholm taught entering a power save mode based on detecting user inactivity via backlight status and sensed motion, as well as exiting power save mode upon detecting user activity. Furthermore, Petitioner argued Srinivasan taught the use of "wakelocks" in conjunction with alarms to ensure a mobile device remains awake to complete a scheduled task.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Chueh with Backholm because both references address reducing resource usage and power consumption on mobile devices. A POSITA would have been motivated to incorporate Backholm's conventional power-saving triggers into Chueh’s system to achieve the predictable benefit of enhanced power management. Similarly, a POSITA would combine Chueh with Srinivasan because adding the well-known functionality of wakelocks is a necessary and obvious step to ensure that the tasks initiated by Chueh's grouped alarms could run to completion without interruption.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success, as the combination involved applying known techniques (power save triggers, wakelocks) to a similar system (alarm management) to achieve their known, predictable functions.

Ground 2: Claims 24-50 are obvious over combinations based on Chueh, Jiang, and Kim.

  • Prior Art Relied Upon: Chueh (Application # 2014/0195839), Jiang (Application # 2012/0260118), and Kim (Application # 2012/0315960).

  • Core Argument for this Ground:

    • Prior Art Mapping: For a different set of claims, Petitioner again relied on Chueh as the primary reference teaching the alignment of wake-up events. Petitioner argued that Jiang taught providing a user interface for selecting whether to optimize background traffic of specific applications, thus teaching the user-selection limitations for optimizing background tasks. To address limitations related to battery-level-based power saving, Petitioner asserted Kim taught a system where a user can select, via a menu, whether to enter a power save mode, and this mode can be automatically triggered based on a predetermined battery level.
    • Motivation to Combine: Petitioner argued that a POSITA would combine Chueh with Jiang to provide users with greater control and flexibility over background traffic management, a known method for improving power management systems. A POSITA would also have been motivated to combine Chueh with Kim to incorporate Kim’s conventional power-saving menus and battery-level triggers. This would provide enhanced user control over power consumption, a direct and predictable benefit sought by both references.
    • Expectation of Success: Petitioner claimed success would be predictable because the combination merely integrated conventional user-interface and power-management features into Chueh's system to achieve the expected benefits of enhanced user control and improved battery life.

  • Additional Grounds: Petitioner asserted additional obviousness challenges by adding references to the Chueh, Jiang, and Kim combination. These included adding Hackborn (Patent 8,280,456) to teach displaying an indication of battery consumption per application, and adding Backholm (’236 application) to teach that optimizing background traffic also optimizes the use of CPU and memory resources.

4. Key Technical Contentions (Beyond Claim Construction)

  • A central contention of the petition was that the ’127 patent is not entitled to the filing date of its provisional application (the ’070 Provisional). Petitioner argued that key limitations recited in the challenged claims—specifically those related to entering and exiting a "power save mode" based on backlight status, sensed motion, battery level, or user selection—lacked written description support in the provisional specification. Because this subject matter was allegedly new matter introduced in the later non-provisional application, Petitioner contended the effective filing date for the challenged claims is March 24, 2014. This argument was critical to establishing that the asserted prior art references, published between 2012 and early 2014, qualify as prior art under 35 U.S.C. §102.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30, 32-38, 40-48, and 50 of the ’127 patent as unpatentable.