PTAB

IPR2018-01122

Samsung Electronics Co Ltd v. Seven Networks LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Offloading Application Traffic to a Shared Communication Channel for Signal Optimization in a Wireless Network for Traffic Utilizing Proprietary and Non-Proprietary Protocols
  • Brief Description: The ’600 patent describes a method for conserving network and battery usage on a mobile device by offloading application traffic from a primary, application-specific channel to a second, shared communication channel. The device monitors the shared channel and only re-establishes the primary channel when necessary.

3. Grounds for Unpatentability

Ground 1: Obviousness over Soliman and Bluetooth Specification - Claims 1, 5-7, 11, and 12 are obvious over Soliman in view of the Bluetooth Specification.

  • Prior Art Relied Upon: Soliman (Application # 2012/0173901) and the Bluetooth Specification (Version 4.0, June 2010).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Soliman taught a method to improve transmission performance and conserve resources in a wireless device by using two communication channels. Soliman’s device operated in a "connected mode" using a high-power "primary communication channel" (the claimed "first channel") and a "lowered power mode" that bypassed the primary channel in favor of a low-power "secondary communication channel" (the claimed "second channel"). Petitioner asserted that Soliman’s bypassing or disabling of the primary channel in the lowered power mode constituted the claimed "blocking." While in this mode, application traffic was "offloaded" to the secondary channel, which Soliman disclosed could be a Bluetooth piconet. The Bluetooth Specification was cited to establish that a Bluetooth piconet is inherently a "shared" or "common" channel, thus meeting that claim limitation. Soliman further taught monitoring the secondary channel for data indicators and, upon receipt, reactivating ("unblocking") the primary channel to perform an action, then returning to the power-saving mode ("re-blocking").
    • Motivation to Combine: A POSITA implementing Soliman's teaching of a Bluetooth piconet for the secondary channel would combine it with the official Bluetooth Specification. The motivation would be to ensure the system conformed to the current standard, thereby guaranteeing interoperability with other Bluetooth devices.
    • Expectation of Success: A POSITA would have a high expectation of success because implementing a known communication protocol (Bluetooth) according to its official standard is a routine and predictable engineering task.

Ground 1a: Incremental Obviousness over Soliman, Bluetooth Spec, and Wilson - Claims 6 and 12 are obvious over Soliman, the Bluetooth Specification, and Wilson.

  • Prior Art Relied Upon: Soliman (Application # 2012/0173901), the Bluetooth Specification (Version 4.0, June 2010), and Wilson (Application # 2012/0303774).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address the specific limitation in dependent claims 6 and 12 requiring "notifying a user about application traffic." While Soliman disclosed applications like push email and instant messaging, Petitioner introduced Wilson to explicitly teach an enhanced system for managing and displaying push notifications. Wilson described aggregating push notifications from multiple applications (e.g., email, instant messaging) to increase efficiency and provide notifications to the user.
    • Motivation to Combine: A POSITA would combine Wilson’s notification system with Soliman’s power-saving architecture because both references aimed to improve mobile device efficiency. Wilson’s enhanced push notification management was directly applicable to the types of applications (email, messaging) already present in Soliman, offering a clear benefit of more efficient and organized user notifications.

Ground 2: Obviousness over Calamera, TCP Spec, and IMAP Spec - Claims 1, 5-7, 11, and 12 are obvious over Calamera in view of the TCP Specification and the IMAP Specification.

  • Prior Art Relied Upon: Calamera (Application # 2010/0088387), the IMAP Specification (RFC 3501, March 2003), and the TCP Specification (RFC 793, September 1981).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Calamera disclosed a method for reducing network traffic and battery use by offloading persistent wireless connections. Calamera taught a mobile device disconnecting its direct connection (the "first channel," which was non-common) to an IMAP email server to conserve resources. Petitioner contended this "disconnect" constituted the claimed "blocking." The task of monitoring for new emails was offloaded to a proxy server, which alerted the mobile device via a common "notification push channel" (the "second channel"). Upon receiving a notification, the device would re-establish ("unblock") the direct connection to retrieve the email and then disconnect again ("re-block"). The IMAP and TCP Specifications were cited to show that Calamera's IMAP-based system would rely on TCP for reliable data transfer, and that under the TCP Specification, packets sent to a closed (disconnected) connection are rejected, thus meeting the "rejecting IP packets" limitation of claims 5 and 11.
    • Motivation to Combine: A POSITA implementing Calamera’s email system, which explicitly referenced the IMAP4 protocol, would combine its teachings with the official IMAP and TCP Specifications. The IMAP Specification itself stated that it assumes a reliable data stream as provided by TCP. The motivation was to conform to industry standards to ensure reliable and interoperable email communication.
    • Expectation of Success: Success was expected because the combination involved implementing a standard application protocol (IMAP) using its standard underlying transport protocol (TCP), a common and predictable practice for network engineers.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 5-7, 11, and 12 of the ’600 patent as unpatentable.