PTAB

IPR2018-01727

Cisco Systems Inc v. TracBeam LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Gateway And Hybrid Solutions For Wireless Location
  • Brief Description: The ’327 patent discloses methods for locating communication devices within a wireless network. The system utilizes a plurality of "location determiners," which employ different underlying technologies to generate independent geographic location estimates, and then processes these estimates to provide a final, resulting location for the device.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, and 6 are obvious over [Sheffer](https://ai-lab.exparte.com/case/ptab/IPR2018-01727/doc/1005) in view of [Cisneros](https://ai-lab.exparte.com/case/ptab/IPR2018-01727/doc/1006) and [Sanderford](https://ai-lab.exparte.com/case/ptab/IPR2018-01727/doc/1007).

  • Prior Art Relied Upon: Sheffer (Patent 5,844,522), Cisneros (Patent 5,774,829), and Sanderford (Patent 5,717,406).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the prior art combination discloses all limitations of the challenged claims. Sheffer was presented as the primary reference, disclosing a base system for locating a mobile phone using multiple independent techniques, satisfying the requirement for a "plurality of location determiners." Specifically, Sheffer teaches using an azimuth triangulation technique, an RSSI-based technique, and a cell-site data technique, and then comparing the results to determine a final location with an associated "confidence level," which Petitioner mapped to the patent's reliability limitations.

    • To meet limitations in dependent claim 6 requiring a "predetermined pattern detection process," Petitioner introduced Sanderford. Sanderford teaches using a neural network—which is trained beforehand and thus predetermined—to analyze signal timing patterns (Time-of-Arrival/Relative Time-of-Arrival) to determine location. Petitioner asserted a POSITA would have viewed Sanderford's neural network as a second, distinct type of location determiner that relies on pattern detection to improve accuracy, especially in environments with signal multipath distortion.

    • To address limitations regarding the combination of outputs from different determiners, Petitioner relied on Cisneros. Cisneros teaches combining position estimates from different sources by weighting each solution "in accordance with its estimated quality." Petitioner argued this renders obvious the claimed step of combining or resolving differences between geographic identifications to produce a resulting location dependent on both.

    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine these references to create a more robust and accurate location system. A POSITA would recognize the limitations of Sheffer's azimuth-based system, which is susceptible to multipath errors in urban environments. They would be motivated to supplement Sheffer's system with Sanderford's neural network technology, as it is specifically designed to mitigate such multipath effects and improve accuracy. Furthermore, a POSITA would incorporate the weighting and averaging techniques from Cisneros as a known and logical method for intelligently combining the outputs from the different location techniques (Sheffer's and Sanderford's) to yield a more reliable final position estimate than simply selecting one over the others.

    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in combining the references. All three patents operate in the same technical field of wireless device location, use compatible technologies, and address the common and well-understood goal of improving location accuracy. The proposed combination involved applying known techniques to improve a base system in a predictable manner.

4. Key Claim Construction Positions

  • "location determiners": Petitioner argued this term should be construed as a means-plus-function term under 35 U.S.C. §112, ¶ 6. The proposed function was "determining communication device location," and the corresponding structure identified in the specification was a "location hypothesizing model (FOM) implemented on or by a location center or mobile base station."
  • "at least one of: a potential geographic location and a potential geographic extent": Petitioner argued that, based on the context and alternative phrasing used throughout the claims, this phrase should be construed disjunctively to mean "at least one of a potential geographic location or at least one of a potential geographic extent." This construction opposes an interpretation that would require both a location and an extent.
  • "at least one of the first and second location determiners": Similarly, for claim 6, Petitioner argued this phrase means "at least one of the first location determiners or at least one of the second location determiners," based on the singular verb "is" that follows the phrase in the claim.

5. Relief Requested

  • Petitioner requests institution of an inter partes review of claims 1, 2, and 6 of the ’327 patent and cancellation of these claims as unpatentable.