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 relates to a method for conserving battery power in mobile devices by managing "wakelocks," which are software mechanisms that prevent a device or its components from entering a low-power sleep state. The invention focuses on selectively releasing or maintaining wakelocks based on application-specific rules and the device's activity state.

3. Grounds for Unpatentability

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

• Prior Art Relied Upon: WakeScope (Kim et al., a 2013 publication on a runtime scheme for Android wakelock management) and Sony (a 2013 blog post describing Sony's "Battery STAMINA Mode").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that WakeScope, a runtime scheme to detect and manage "wakelock anomalies" in Android, disclosed the core limitations of independent claim 1. This included a mobile device with a processor configured to acquire a system wakelock in response to an application request and detect an activity state based on the display screen's status (e.g., screen off). Petitioner contended that Sony taught the remaining key limitations, specifically a "power optimization state" (its STAMINA Mode) that reduces background activities when the screen is off and uses a "whitelist" to allow important applications to continue running and maintain their wakelocks. An application not on the whitelist was deemed "non-critical," and its wakelock would be released upon entering the power optimization state.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine WakeScope's wakelock anomaly detection with Sony's whitelist-based power management to create a more robust and user-friendly power-saving system. The combination would provide the known benefit of reducing battery drain from non-essential applications (as in WakeScope) while preserving the functionality of user-designated critical applications (as in Sony), which is a simple and predictable improvement.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these systems, as it involved the integration of known power-management techniques to achieve the predictable result of improved battery life without sacrificing essential background functionality.

Ground 2: Claim 5 is obvious over WakeScope and Sony, in view of Marcellino.

• Prior Art Relied Upon: WakeScope, Sony, and Marcellino (Application # 2010/0216434).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of WakeScope and Sony asserted in Ground 1 to further address dependent claim 5, which adds the limitation that the power optimization state is entered in response to whether the device is connected to a power source. Petitioner argued that Marcellino, which discloses methods for conserving battery life, explicitly taught that mobile devices may enter a "reduced power mode when not connected to a constant power supply."
  • Motivation to Combine: A POSITA would be motivated to modify the WakeScope/Sony system with the teachings of Marcellino for the common-sense reason of optimizing performance. It was a well-known design choice to disable aggressive power-saving features when a device is connected to an external power source, as battery conservation is no longer a concern. This modification would prevent unnecessary reduction in device functionality when unlimited power is available, representing a predictable trade-off.
  • Expectation of Success: The combination was argued to be predictable, as implementing different power profiles based on the power source (battery vs. AC power) was a standard feature in mobile operating systems.

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

• Prior Art Relied Upon: WakeScope, Sony, and Srinivasan (Application # 2014/0038674).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground added the teachings of Srinivasan to the WakeScope/Sony combination to address claims requiring activity state detection based on motion sensors (e.g., claims 3, 6, and 10). Petitioner asserted that Srinivasan disclosed an "activity recognition system" that used sensors like accelerometers and gyroscopes to determine a user's activity (e.g., idle, walking, running) and could place the device in sleep mode based on detected idleness.
  • Motivation to Combine: A POSITA would combine Srinivasan’s motion-based activity detection with the WakeScope/Sony system to improve the accuracy of determining when a user is truly idle. Relying only on screen status or keystrokes can be insufficient, as a user might be engaged in an activity like listening to music or tracking a run with the screen off. Using motion sensors to confirm a lack of physical movement before entering a power optimization state would prevent unwanted interruptions and improve the overall user experience.
  • Expectation of Success: Integrating motion sensor data into power management decisions was a known technique for creating more context-aware and intelligent mobile devices, and a POSITA would expect to successfully implement this logic to achieve a more accurate power-saving trigger.

• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 12 and 30 based on the combination of all four references: WakeScope, Sony, Marcellino, and Srinivasan. This ground argued that it would have been obvious to create a system incorporating all the previously discussed features: whitelist-based power optimization that is also responsive to both the device's power source connection status and motion-based activity detection.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that inter partes review (IPR) should be instituted on all grounds, noting that it was concurrently filing a separate IPR petition against the same claims of the ’254 patent. That other petition relies on a different primary reference (Patent 9,229,522 to Tian). Petitioner contended that because the petitions present different prior art and arguments, they have different strengths, and institution of both would be appropriate to allow the Board to consider the full range of challenges to the patent's validity.

5. Relief Requested

• Petitioner requested institution of IPR and cancellation of claims 1-15 and 28-33 of the ’254 patent as unpatentable.