PTAB

IPR2018-01120

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

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1. Case Identification

2. Patent Overview

  • Title: Mobile Application Traffic Optimization
  • Brief Description: The ’019 patent relates to a system and method for reducing traffic in a wireless network by managing data requests from multiple mobile applications. The invention achieves this by delaying, aligning, and polling for content based on observed user activity and mobile device properties, and by suppressing requests during specific periods to conserve power.

3. Grounds for Unpatentability

Ground 1: Obviousness over Huang and Black - Claims 1-3, 5, 7, 11, 12, 16, 19, and 20 are obvious over Huang alone or in view of Black.

  • Prior Art Relied Upon: Huang (Application # 2011/0177847) and Black (Application # 2011/0185202).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Huang discloses the core elements of the challenged claims. Huang teaches a power-saving method for a mobile device that uses discontinuous transmission (DTX) by entering sleep modes based on a user inactivity timer. It describes a "shallow sleep mode" and a "deep sleep mode," which correspond to the claimed first and second suppression periods. Petitioner asserted that Huang shows delaying and aligning content requests from multiple applications (e.g., Facebook, Weather) during dormant states within these sleep modes. The transmission of these aligned requests after the dormant state expires was argued to meet the "poll" limitation. Thus, Huang alone was alleged to teach delaying, aligning, polling, and suppressing requests using two different suppression periods based on user inactivity.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Black with Huang to implement more specific and well-known methods for detecting user activity. While Huang taught using a "user inactivity timer," Black provided concrete examples for detecting such activity, including monitoring for a key press, a touch screen press, or backlight status. Petitioner contended that applying Black’s specific detection methods to Huang’s power-saving framework would be a simple application of a known technique to a known system to improve its functionality—specifically, to more accurately trigger the inactivity timer.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because combining the references involved applying conventional user activity detection methods (from Black) to a power-saving system (Huang) to achieve the predictable result of more accurate power management without altering the system’s fundamental operation.

Ground 2: Obviousness over Araujo and Ishak - Claims 1-3, 5-7, 11-13, 15, and 16 are obvious over Araujo alone or in view of Ishak.

  • Prior Art Relied Upon: Araujo (Application # 2009/0217065) and Ishak (Application # 2006/0223593).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Araujo teaches a power management system that uses a "batch" mode to conserve power. In this mode, if an application with low-status requests network access while the network card is off (e.g., due to keyboard inactivity), the system delays the request. Araujo disclosed that multiple such requests made between scheduled network-on intervals are aligned and transmitted together in a burst. This process was argued to meet the limitations of delaying, aligning, and suppressing requests based on observed user activity (keyboard inactivity) and device properties (program status, power state of the network card). The subsequent transmission of batched requests was argued to satisfy the "poll" limitation. Petitioner also contended that varying arrival times of requests within batch intervals naturally creates first and second suppression periods of different lengths, as illustrated in the petition.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to look to Ishak to supplement Araujo’s teachings on inactivity detection. Araujo generally disclosed turning off devices after a period of inactivity (e.g., keyboard inactivity), while Ishak provided explicit implementation details for determining a device's active or inactive status. These details included monitoring the duration since a user last interacted with a keypad or whether the backlight is off. Combining Ishak's robust detection methods with Araujo’s policy-based power management system would improve the system's accuracy in identifying true user inactivity, thereby preventing erroneous entry into a power-saving state and enhancing user experience.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in this combination because it involved integrating well-understood inactivity detection techniques (from Ishak) into a known power-management framework (Araujo) to yield the predictable outcome of a more efficient and reliable system.

4. Key Claim Construction Positions

  • "when [the time exceeds a predetermined time period]": Petitioner argued that this term should be construed to mean "upon and after which [the time exceeds a predetermined time period]." This construction, supported by a dictionary definition, was asserted to be critical for mapping the prior art to claim limitations describing actions (like suppression) that occur after an inactivity timer expires.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-7, 11-13, 15, 16, 19, and 20 of the ’019 patent as unpatentable.