PTAB

IPR2018-01645

Lenovo United States Inc v. Koninklijke KPN NV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Telecommunications Network And Method For Time-Based Network Access
  • Brief Description: The ’667 patent discloses a system for regulating access to a telecommunications network for multiple terminals. The system uses a "register" that stores unique terminal identifiers in association with specific "deny access time intervals" to manage network resources and deny access based on monitored network load, particularly for machine-to-machine (M2M) applications during peak hours.

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 (EP Patent Publication # EP1009176 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Obhan taught the core invention: a network access control system that monitors load and denies access to certain classes of terminals, including low-priority M2M devices like vending machines, during peak load intervals. Obhan's system used an "Admission Control Block" (register) to store access rules associated with terminal "access classes." Petitioner contended that Shatzkamer supplied the missing limitation by teaching a similar access control system that denies service based on a list of unique identifiers (e.g., an IMSI) rather than general access classes. Budka was cited to show that standard network access procedures in a GSM network, like the one in Obhan, inherently required a terminal to transmit its unique IMSI in an access request, making the identifier readily available to the network.
    • Motivation to Combine: A POSITA would combine Shatzkamer's unique identifier-based control with Obhan's load-based system to increase the granularity and flexibility of access management, enabling device-specific restrictions instead of broad class-based ones. Petitioner asserted this was a common-sense modification to achieve finer, more effective control. Incorporating Budka’s disclosure of standard access request protocols was merely implementing a known technique for its intended purpose within Obhan’s existing GSM framework.
    • Expectation of Success: The combination involved substituting known elements (class identifiers for unique identifiers) to achieve a more precise version of an existing system, which would have produced predictable results without undue experimentation.

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 (EP Patent Publication # EP1009176 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground, targeting claim 35, focused on the functionality within the terminal itself. Petitioner again used Obhan as the primary reference for the overall load-based access control system. The combination added Taniguchi, which explicitly taught sending terminals a "communication restriction signal" that includes "communication restriction period information." This notification informs the terminal when it will be denied access, thereby preventing it from making futile access attempts. While Obhan disclosed sending general "service option signals" to terminals to alter accessibility, Petitioner argued Taniguchi provided the specific teaching of including the deny access time interval in such a message. Budka again provided the well-known context for standard GSM access requests.
    • Motivation to Combine: A POSITA would combine Taniguchi's specific notification method with Obhan's system to improve overall network efficiency. By proactively informing terminals when they cannot connect, the system avoids wasting resources on processing and denying access requests that are known to fail. This modification served the stated goal of efficiently managing network resources, providing a clear reason for the combination.
    • Expectation of Success: Petitioner argued that adding this notification feature was a straightforward design choice that would predictably improve the efficiency of Obhan's network management system.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for three key terms under the Broadest Reasonable Interpretation (BRI) standard, which it argued were central to its obviousness arguments.
    • "deny access time interval": Construed broadly as a "time slot during which access to the telecommunications network is denied." Petitioner asserted this construction was critical because Obhan disclosed an equivalent "grant access" interval, and denying access outside a grant interval is functionally equivalent to denying access within a defined deny interval.
    • "machine-to-machine applications": Construed as "applications that allow for data communication between devices and that normally operate without human intervention." This broad construction allowed Petitioner to map the claim limitation to Obhan's disclosure of managing access for "low priority data users," which included automated devices such as vending machines and electronic billboards.
    • "register": Construed broadly to mean "a device with storage." This construction was based on the claim's requirement that the register is "configured to store" data and enabled mapping the term to Obhan's "Admission Control Block (ACB)," a memory-resident component that could be located in various network devices.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 31, 33, and 35 of the ’667 patent as unpatentable under 35 U.S.C. §103.