PTAB

IPR2018-01639

HTC America Inc v. KonINKLikje KPN NV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Telecommunications Network and Method for Regulating the Use of Network Resources
  • Brief Description: The ’667 patent discloses a system for managing access to a telecommunications network to regulate resource use. The system uses a register to store "deny access time intervals" associated with specific terminals and denies access requests received during these intervals, which can be adapted based on monitored network load, particularly for machine-to-machine (M2M) applications.

3. Grounds for Unpatentability

Ground 1: Obviousness over Obhan, Shatzkamer, and Budka - Claims 31 and 33 are obvious over Obhan in view of Shatzkamer and Budka.

  • Prior Art Relied Upon: Obhan (Patent 6,275,695), Shatzkamer (Application # 2008/0220740), and Budka (E.P. Publication # EP1009176).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Obhan is a comprehensive base reference teaching a telecommunications network that manages access to regulate network load. Obhan discloses an Admission Control Block (ACB), functioning as the claimed "register," that stores time intervals (termed "good till" time) associated with terminal "access classes." During these intervals, terminals below a minimum access class are denied access. Crucially, Obhan teaches that these time intervals are updated based on monitored network load and discloses denying access to low-priority M2M applications (e.g., vending machines) during peak load intervals to preserve resources.
    • Motivation to Combine: Petitioner contended that while Obhan teaches access control based on broad "access classes," the claims require control based on a "unique identifier" for each terminal. Shatzkamer was introduced to supply this limitation, as it explicitly discloses using a unique identifier (e.g., an IMSI) to deny service to a specific device for a certain period. A POSITA would combine Shatzkamer with Obhan to increase the granularity and flexibility of the access control system, moving from class-based to device-specific management, which was a known method for achieving finer control. Budka was introduced to supply the well-known, routine practice in GSM networks (the type disclosed in Obhan) that a terminal's "call origination" inherently involves sending an access request containing its unique IMSI. A POSITA would have understood Obhan's system to operate using this standard procedure.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved substituting Obhan's class identifiers with Shatzkamer's well-known unique identifiers and incorporating the standard access procedures described by Budka, all to achieve the predictable result of more granular network access control.

Ground 2: Obviousness over Obhan, Taniguchi, and Budka - Claim 35 is obvious over Obhan in view of Taniguchi and Budka.

  • Prior Art Relied Upon: Obhan (Patent 6,275,695), Taniguchi (Patent 7,505,755), and Budka (E.P. Publication # EP1009176).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets claim 35, which recites a terminal configured to receive a message containing "information relating to a deny access time interval." Petitioner again relied on Obhan as the base system for load-based access control for M2M applications. While Obhan teaches that terminals receive "service option signals" that alter their accessibility, it does not explicitly state that these signals contain the specific deny access time interval information.
    • Motivation to Combine: Petitioner asserted that Taniguchi remedies this deficiency. Taniguchi discloses a system where a terminal receives a "communication restriction signal" that explicitly includes "communication restriction period information" to inform the terminal when it is restricted from accessing the network. A POSITA would combine Taniguchi’s notification method with Obhan's access control system for the clear benefit of improved network and device efficiency. By informing terminals of the specific denial periods, the system prevents them from expending resources on access requests that are certain to be denied, directly furthering Obhan's stated goal of managing network resources. Budka was included for the same purpose as in Ground 1: to supply the standard teaching of an access request containing a unique identifier.
    • Expectation of Success: Combining a known notification technique (Taniguchi) with a known access control system (Obhan) would predictably result in a more efficient overall system, a goal readily understood and sought by a POSITA.

4. Key Claim Construction Positions

  • "deny access time interval" (claims 31, 33, 35): Petitioner proposed this term be construed as "a time slot during which access to the telecommunications network is denied." This construction was argued to be consistent with the specification's description and its statement that deny intervals are equivalent to the inverse of grant intervals.
  • "machine-to-machine applications" (claims 31, 33, 35): Petitioner proposed a construction of "applications that allow for data communication between devices and that normally operate without human intervention." This was based on the specification's examples, such as electricity meters and vending machines.
  • "register" (claim 31): Petitioner proposed this term be construed as "a device with storage." This broad construction was justified because the claim requires the register to "store" information, and the specification provides examples like a home location register (HLR), which is fundamentally a storage device.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 31, 33, and 35 of Patent 9,014,667 as unpatentable.