Google LLC v. Seven Networks LLC

1. Case Identification

• Patent #: 9,351,254
• Filed: May 18, 2018
• Petitioner(s): Google LLC
• Patent Owner(s): Seven Networks, LLC
• Challenged Claims: 1-15 and 28-33

2. Patent Overview

• Title: Method for Power Saving in Mobile Devices by Optimizing Wakelocks
• Brief Description: The ’254 patent describes methods for conserving battery power in mobile devices by managing "wakelocks," which are mechanisms that prevent a device from entering a low-power sleep mode. The invention involves detecting the device's activity state and determining whether an application requesting a wakelock is critical, thereby deciding whether to release the wakelock to save power.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, and 9 are obvious over Tian in view of Zhang.

• Prior Art Relied Upon: Tian (Patent 9,229,522) and Zhang (Chinese Application # 103402027).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Tian teaches the core elements of a power-saving system for a mobile device. Tian discloses identifying applications that prevent the device from sleeping while the screen is off, acquiring a system "wakelock" in response to an application request, detecting an activity state based on screen status, and entering a power optimization state (sleep mode). However, Tian does not explicitly disclose using a "whitelist" to manage wakelock releases. Petitioner argued that Zhang remedies this by teaching a power-saving system that uses an "application white list" to prevent the forced release of wakelocks for essential applications. The combination of Tian's power management framework with Zhang's whitelist functionality allegedly rendered the core limitations of independent claim 1 obvious.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Tian's power-saving system with Zhang's whitelist feature to achieve predictable benefits. The combination would improve Tian's system by preventing the termination of applications critical to the user experience, while still aggressively managing non-critical applications to conserve battery life. This modification was presented as a simple combination of known elements to solve a known problem.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in integrating Zhang's whitelist into Tian's system. The combination involved applying a known technique (whitelisting) to a known system (power management via wakelock control) to yield a predictable result: a more refined and user-friendly power management system.

Ground 2: Claim 5 is obvious over Tian in view of Zhang and Marcellino.

• Prior Art Relied Upon: Tian (Patent 9,229,522), Zhang (Chinese Application # 103402027), and Marcellino (Application # 2010/0216434).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on the combination of Tian and Zhang and adds Marcellino to teach the limitation of claim 5, which requires the power optimization state to be responsive to whether the device is connected to a power source. Petitioner argued that the base Tian/Zhang combination teaches a system focused on conserving limited battery power. Marcellino was cited for its explicit disclosure that a mobile device enters a reduced power mode "when not connected to a constant power supply."
  • Motivation to Combine: A POSITA would be motivated to modify the Tian/Zhang system with Marcellino's teaching as a matter of common sense and good design. When a device is connected to an external power source, the trade-off between functionality and battery life is eliminated. Therefore, it would have been obvious to disable the aggressive power-saving features of the Tian/Zhang system when the device is charging to provide a better user experience without any downside.

Ground 3: Claims 3, 6-8, 10, 11, 13-15, 28, 29, and 31-33 are obvious over Tian in view of Zhang and Srinivasan.

• Prior Art Relied Upon: Tian (Patent 9,229,522), Zhang (Chinese Application # 103402027), and Srinivasan (Application # 2014/0038674).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses claims requiring the device's activity state to be based on motion sensing. While Tian discloses that mobile devices can include motion sensors like accelerometers, Petitioner relied on Srinivasan for its detailed teaching of an "activity recognition system" that uses such sensors to determine if a user is idle (e.g., reading) or active (e.g., walking, running). Srinivasan explicitly teaches transitioning the device to a sleep mode based on this sensor data. Petitioner argued that adding Srinivasan’s motion-based activity detection to the Tian/Zhang system rendered these claims obvious.
  • Motivation to Combine: A POSITA would be motivated to incorporate the motion-sensing techniques of Srinivasan to improve the accuracy of activity detection in the Tian/Zhang system. Relying solely on screen status or keyboard input is insufficient for modern use cases like fitness tracking or navigation, where the user is active but not directly interacting with the screen. Adding motion detection would create a more robust and intelligent power management system, avoiding unwanted interruptions.
• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 12 and 30 based on the combination of Tian, Zhang, Srinivasan, and Marcellino. This ground relied on the collective rationales of the grounds above to meet all the combined limitations of the claims.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should institute review on all grounds in this petition, even though it was concurrently filing a second IPR petition against the same patent. It contended that the two petitions, while having some overlap, rely on different primary references (this petition on Tian; the other on a reference called WakeScope) and present different strengths and weaknesses. Petitioner asserted that both should be instituted to allow for a full consideration of the patent's validity in light of the different prior art approaches.

5. Relief Requested

• Petitioner requested institution of an inter partes review (IPR) for claims 1-15 and 28-33 of the ’254 patent and cancellation of all challenged claims as unpatentable.