PTAB

IPR2018-01125

Samsung Electronics 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 describes a method for conserving battery power in mobile devices by managing "wakelocks." The system identifies applications exhibiting "bad behavior," such as the long or frequent use of wakelocks that prevent the CPU from sleeping, and manages these applications to prevent unnecessary power consumption.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gou, Backholm, and Pulapaka - Claims 1-16 and 28-33 are obvious over Gou in view of Backholm and Pulapaka.

  • Prior Art Relied Upon: Gou (CN Application # 103324519), Backholm (Application # 2012/0023190), and Pulapaka (Application # 2014/0380075).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the challenged claims recite a combination of known power-saving techniques disclosed across the three references.

      • Gou was argued to disclose the core reactive power-saving system. Gou teaches a mobile device that monitors applications when the screen is off (an inactive state). If an application holds a wakelock for longer than a predefined threshold, it is deemed "malicious" and is "cleared" (releasing its wakelock) to save power, unless the application is on a user-defined whitelist of applications to be "ignored." This maps to the claimed concepts of entering a power optimization state based on an activity state (screen off), detecting misbehaving applications, and releasing their wakelocks unless they are on a whitelist.
      • Backholm was argued to teach a more sophisticated method for detecting device activity to trigger a "power save mode." Instead of relying solely on screen status like Gou, Backholm discloses using multiple inputs—such as keystrokes, motion sensors, and backlight status—to more accurately determine if a user is active. It also teaches that the power save mode is not applied when the device is connected to a charger. This was asserted to render obvious the claim limitations requiring activity state detection based on motion and/or keystrokes, and making the power-saving features responsive to the device’s charging status.
      • Pulapaka was argued to disclose a proactive and more granular method for managing power. Pulapaka describes a "quiet mode" where the system proactively manages application tasks (not just whole applications). A user can create a whitelist of specific background tasks (e.g., "VoIP call notification," "weather application update") that are permitted to execute and acquire a wakelock, while other, non-whitelisted tasks are "blocked." This proactive, task-level management was asserted to teach the claimed functionality of proactively managing whitelisted applications/tasks to allow them to acquire wakelocks, while preventing non-whitelisted applications/tasks from doing so.

    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to create a more robust and efficient power management system.

      • A POSITA would combine Backholm with Gou to improve the accuracy of inactivity detection. Using Backholm’s multi-sensor approach (motion, keystrokes) avoids incorrectly penalizing applications when a user is active but the screen is off (e.g., listening to music), leading to a better user experience and more intelligent power management.
      • A POSITA would then integrate Pulapaka into the Gou/Backholm system to add a complementary layer of proactive, granular control. Pulapaka’s task-level whitelisting allows the system to preemptively block non-essential background tasks from ever consuming power, which further enhances battery life beyond Gou’s purely reactive, application-level management. This combination would yield a superior system that both proactively prevents unnecessary tasks and reactively cleans up applications that subsequently misbehave.

    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success in making this combination. The integration involved applying known techniques (advanced activity detection, granular task management) to a known system (wakelock management) to achieve the predictable results of improved power efficiency and enhanced user control.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this petition should not be discretionarily denied as duplicative of a concurrently filed petition (IPR2018-01124). It was asserted that this petition relies on a different set of prior art by including Pulapaka, which satisfies certain claim limitations in a different manner than the other petition. Petitioner claimed this approach mitigates the burden on the Board and Patent Owner by reusing analysis for the common references (Gou and Backholm) while presenting a distinct invalidity theory.

5. Relief Requested

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