PTAB

IPR2018-01281

Apple Inc v. Qualcomm Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Learning Situations Via Pattern Matching
  • Brief Description: The ’865 patent discloses a machine learning system for mobile devices to recognize user situations through pattern matching. The system aims to conserve computational resources by first detecting a general condition and then initiating a more focused process to recognize a specific pattern associated with that condition.

3. Grounds for Unpatentability

Ground 1: Anticipation by Wang - Claims 1-4, 15-17, 21-23, 28, 29, 46, and 47 are anticipated by Wang under 35 U.S.C. §102.

  • Prior Art Relied Upon: Wang (a 2009 journal article, "A Framework of Energy Efficient Mobile Sensing for Automatic User State Recognition").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wang, which describes an Energy Efficient Mobile Sensing System (EEMSS) for smartphones, discloses every limitation of the challenged claims. Wang’s EEMSS monitors input signals from multiple sources (accelerometer, GPS, microphone) to detect a condition, such as a user state of "Walking." Based on this detected condition, it identifies a first pattern defined by a collection of parameter values (e.g., Location = "Keep on changing" and Motion = "Moving Slowly"). The system then fixes this subset of parameters to represent the "Walking" condition. Petitioner further contended that Wang teaches recognizing a second pattern (e.g., transitioning to a "Vehicle" state) based on the first identified pattern, anticipating dependent claims. For example, upon detecting the "Walking" pattern, Wang’s system monitors only GPS signals to detect an increase in speed, which indicates a transition to the "Vehicle" pattern.

Ground 2: Obviousness over Wang and Nadkarni - Claims 5, 6, 8-11, 18-20, 24, 25, 27, 30, 48, 49, and 51-53 are obvious over Wang in view of Nadkarni under 35 U.S.C. §103.

  • Prior Art Relied Upon: Wang, and Nadkarni (Application # 2010/0217533).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that this combination renders obvious the claims requiring a "database" for storing patterns and the identification of "irrelevant patterns." Wang’s system stores user states and state transition rules in an XML file, which Petitioner argued a person of ordinary skill in the art (POSITA) would understand to be a form of database. Nadkarni explicitly teaches storing motion signatures (patterns) in a "library of signatures" within a database for comparison, making the use of a database with Wang’s system obvious. For claims requiring the identification of irrelevant patterns, Petitioner argued Wang’s EEMSS inherently performs this by design; it selectively activates only the minimum necessary sensors (e.g., only GPS for the "Walking" state, ignoring microphone data) to conserve energy, thereby treating patterns associated with other sensors as irrelevant. Nadkarni reinforces this by teaching techniques to filter signals and reduce the number of possible signature matches, thereby eliminating irrelevant patterns to improve efficiency.
    • Motivation to Combine: A POSITA would combine Nadkarni's explicit database storage and pattern filtering techniques with Wang's overall framework to achieve the shared goals of improving efficiency and accuracy in user activity recognition. Both references exist in the same field and address the same computational challenges.
    • Expectation of Success: A POSITA would have a high expectation of success, as implementing a database for storing patterns is a well-known and predictable technique in pattern recognition systems.

Ground 3: Obviousness over Wang, Nadkarni, and Greenhill - Claims 12-14 are obvious over Wang in view of Nadkarni and Greenhill under §103.

  • Prior Art Relied Upon: Wang, Nadkarni, and Greenhill (Application # 2008/0297513).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets claims requiring the database to comprise a "condition database" and a "correlation database." Petitioner argued that the base system of Wang and Nadkarni already establishes the use of a database for storing patterns. Greenhill, which describes a Process Data Management System, is added to teach the specific database structure. Greenhill explicitly discloses a system architecture that includes an "event database" (for storing condition data) and a "correlation database" (for storing similarities between variables). Petitioner mapped Greenhill's "event database" to the claimed "condition database" and its "correlation database" to the claimed feature of the same name.
    • Motivation to Combine: A POSITA seeking to implement the database suggested by the Wang/Nadkarni combination would be motivated to consult known data management architectures like Greenhill's. Incorporating Greenhill's structured database would be a logical design choice to organize condition and correlation data, thereby facilitating the pattern recognition operations of Wang’s system.
    • Expectation of Success: Success would be reasonably expected because applying a known database architecture (Greenhill) to a system already determined to benefit from a database (Wang/Nadkarni) is a standard and predictable engineering step.

4. Key Claim Construction Positions

Petitioner proposed several constructions, arguing they reflect the plain and ordinary meaning consistent with the patent’s specification. These constructions were central to mapping the prior art.

  • "condition": Petitioner argued this term should be construed broadly to encompass events or user states, such as "walking," "driving," or a specific time of day, as expressly disclosed in the specification.
  • "pattern": This term was construed as "a collection of one or more parameter values." This construction allows a pattern to be defined by sensor data values, such as sound intensity being "Loud" and motion being "Running," as shown in the patent's figures.
  • "fixing a subset of varying parameters...": Petitioner argued this phrase is satisfied by "associating at least one parameter of said subset of varying parameters with said first pattern to represent said at least one detected condition." This broad interpretation, supported by the prosecution history, was crucial for arguing that Wang’s association of state features (parameters) with a user state (condition) met this limitation.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1-6, 8-25, 27-30, 46-49, and 51-53 of the ’865 patent as unpatentable.