Google LLC v. Seven Networks LLC

1. Case Identification

• Case #: IPR2018-01117
• Patent #: 9,351,254
• Filed: May 18, 2018
• Petitioner(s): Google LLC
• Patent Owner(s): Seven Networks, LLC
• Challenged Claims: 1-15, 28-33

2. Patent Overview

• Title: Method for Power Saving in Mobile Devices by Optimizing Wakelocks
• Brief Description: The ’254 patent discloses methods for conserving power in mobile devices by managing "wakelocks," which are mechanisms that prevent a device from entering a low-power sleep state. The invention involves detecting a device's activity state and, if inactive, entering a power optimization state where system wakelocks acquired by non-critical applications are released.

3. Grounds for Unpatentability

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

• Prior Art Relied Upon: WakeScope (Kim et al., a 2013 journal article on Android wakelock management) and Sony (Aleryd, a 2013 blog post on STAMINA Mode).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that WakeScope, a runtime scheme for managing wakelock anomalies in Android, teaches the core limitations of independent claim 1. This includes acquiring a system wakelock in response to an application request and detecting an activity state based on the display screen status (e.g., screen off) to prevent energy waste. Petitioner contended that WakeScope lacks a mechanism to differentiate between critical and non-critical applications. The Sony reference was argued to supply this missing element by teaching a "Battery STAMINA Mode" that includes a user-configurable "whitelist." This whitelist allows important, user-selected applications to continue running background processes and receive notifications even when the power-saving mode is active.
  • Motivation to Combine: A POSITA would combine Sony's whitelist feature with WakeScope's wakelock management system to improve user experience and power efficiency. This combination would create a more intelligent system that releases wakelocks for non-whitelisted applications upon entering a power-saving state (e.g., when the screen is off), while preserving the functionality of user-selected critical applications. Petitioner presented this modification as a predictable solution to a known problem in mobile power management.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success, as the combination involved applying a known user-customization technique (a whitelist) to a known power management scheme to achieve the predictable benefit of selective background operation.

Ground 2: Obviousness over WakeScope, Sony, and Marcellino - 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 builds on the WakeScope/Sony combination to address dependent claim 5, which adds the limitation that entering the power optimization state is also responsive to whether the device is connected to a power source. Petitioner argued that Marcellino explicitly teaches this concept, disclosing that mobile devices enter a "reduced power mode when not connected to a power supply" specifically to conserve battery life.
  • Motivation to Combine: A POSITA would be motivated to incorporate Marcellino's teaching to avoid unnecessarily restricting device functionality when battery conservation is not a concern. Petitioner argued it is common sense in power management to disable aggressive power-saving modes when the device has access to a continuous power source, as the trade-off between functionality and battery life is obviated.
  • Expectation of Success: Adding this condition was argued to be a simple, predictable modification to the base system that would make its power-saving logic more practical and efficient.

Ground 3: Obviousness over WakeScope, Sony, and Srinivasan - 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 targets claims that require basing the device's activity state on motion sensing. Petitioner asserted that Srinivasan teaches using integrated motion sensors, such as accelerometers and gyroscopes, to detect a user's physical activity (e.g., idle vs. walking). Based on this detected activity, Srinivasan's system transitions the mobile device into a sleep mode if the user is determined to be idle.
  • Motivation to Combine: A POSITA would combine Srinivasan's motion-based activity detection with the WakeScope/Sony system to improve the accuracy of determining user inactivity. Relying solely on the screen status is insufficient, as a user may be actively using the device for activities like fitness tracking or listening to audio with the screen off. Adding motion detection provides another data point for a more reliable determination, preventing the device from incorrectly entering the power optimization state and interrupting the user experience.
  • Expectation of Success: Petitioner argued that integrating motion sensor data into activity detection logic was a well-known technique to improve contextual awareness in mobile devices, and its application here would yield predictable improvements in the system's accuracy.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claims 12 and 30 based on the combination of WakeScope, Sony, Srinivasan, and Marcellino, which relied on combining the teachings and motivations from the grounds detailed above.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-15 and 28-33 of the ’254 patent as unpatentable.