PTAB

IPR2018-01124

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

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1. Case Identification

2. Patent Overview

  • Title: Method for Power Saving in Mobile Devices by Optimizing Wakelocks
  • Brief Description: The ’254 patent discloses methods for managing power consumption in mobile devices by controlling "wakelocks," which are mechanisms that prevent a device's CPU from entering a low-power sleep state. The technology purports to identify applications exhibiting "bad behavior," such as excessively long or frequent use of wakelocks, and then manages these applications to conserve battery life.

3. Grounds for Unpatentability

Ground 1A: Claims 1, 4, 9, and 16 are obvious over Tian in view of Gou.

  • Prior Art Relied Upon: Tian (Patent 9,229,522) and Gou (CN Application # 103324519).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tian taught the core limitations of independent claim 1, including a mobile device that detects an activity state (screen being off) and enters a power optimization state to manage power-hungry applications. Tian’s system managed "disproportionate apps" by killing them when the screen turned off, thereby releasing the system wakelock. However, Tian lacked a mechanism for a user to exempt certain applications. Petitioner asserted that Gou addressed this deficiency by disclosing a system that clears malicious power-consuming applications unless they are on a user-configurable whitelist (a "list of applications...to be ignored").
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Gou’s whitelist functionality with Tian’s power management system to improve user experience. This combination would allow users to prevent essential applications from being terminated by Tian's system, even if they were flagged for high power consumption, representing a predictable enhancement.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved applying a known technique (a user-managed whitelist) to improve a known system (an application power manager) to achieve a predictable result (selective application management).

Ground 1B: Claims 2, 3, 6-8, 10, 11, 13-15, 28, 29, and 31-33 are obvious over Tian in view of Gou and Backholm.

  • Prior Art Relied Upon: Tian (Patent 9,229,522), Gou (CN Application # 103324519), and Backholm (Application # 2012/0023190).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Tian/Gou combination to address dependent claims that further define the "activity state." Petitioner argued that the challenged dependent claims added limitations based on detecting keystrokes or motion. Backholm was cited for its disclosure of a conventional mobile device that detects a detailed activity state using multiple parameters, including sensing motion, keystrokes, and backlight status, to more accurately determine when to adjust device behavior for power optimization.
    • Motivation to Combine: A POSITA would be motivated to incorporate Backholm's multi-parameter activity detection into the Tian/Gou system. Tian’s reliance on only the screen status is a coarse proxy for user inactivity. Using Backholm’s more granular inputs would allow the system to more accurately discern when a user is truly inactive, improving the system by preventing it from erroneously terminating applications when the device is still in use (e.g., playing audio with the screen off).
    • Expectation of Success: Integrating additional, well-understood sensor inputs (motion, keystrokes) to refine the determination of a device's activity state was a common and predictable design choice for improving power management systems.

Ground 2A: Claims 1-4, 6-11, 13-16, 28, 29, and 31-33 are unpatentable in view of Gou and Backholm.

  • Prior Art Relied Upon: Gou (CN Application # 103324519) and Backholm (Application # 2012/0023190).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative invalidity theory using Gou as the primary reference. Petitioner asserted Gou taught a base system for managing power by monitoring wakelock duration when the screen is off and using a whitelist to exempt certain applications from being "cleared." The combination with Backholm supplied the teachings for more advanced activity detection based on screen status, motion, and keystrokes, as required by various independent and dependent claims.
    • Motivation to Combine: The motivation for this combination was similar to that of Ground 1B. A POSITA would have been motivated to enhance Gou's system, which relied on the screen being off as an indicator of inactivity, with Backholm's more robust multi-sensor approach. This would improve Gou's ability to discern true user inactivity, thereby preventing its power-saving features from being triggered erroneously and degrading the user experience.
    • Expectation of Success: Applying Backholm's known techniques for activity detection to improve Gou's known power management system would have been a straightforward integration with predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including Ground 1C, 1D, and 2B, which introduced Marcellino (Application # 2010/0216434). Marcellino was used to teach that the power optimization state could be further responsive to whether the mobile device is connected to an external power source, a known technique for conserving battery life only when necessary.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because this petition relied on a different set of prior art and invalidity theories than a concurrently filed petition (IPR2018-01125). Petitioner contended that presenting these distinct grounds, while relying on some overlapping references like Gou and Backholm, would mitigate any additional burden on the Patent Trial and Appeal Board and the Patent Owner.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-16 and 28-33 of the ’254 patent as unpatentable.