PTAB

IPR2018-01820

ipDataTel LLC v. ICN Acquisition LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method And System For Communicating With And Controlling An Alarm System From A Remote Server
  • Brief Description: The ’736 patent describes a communication system for transmitting status and alarm condition information from a local alarm system over a network to a remote server. The remote server then performs pre-determined responses based on the received information.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 4 are anticipated by or obvious over Simon

  • Prior Art Relied Upon: Simon (Patent 6,928,148).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Simon disclosed all limitations of claims 1 and 4. Simon’s “central communications station” was identified as the claimed “network node,” which receives data (e.g., passcodes, alarm conditions) from a local premises security system’s “communications unit” over the Internet. This received data was asserted to be “keypad bus information,” as it originates from user keypad entries or from the alarm controller, both of which communicate via Simon's internal bus. Petitioner contended that Simon’s remote station performed pre-determined responses, such as retrieving personalized content based on a received passcode or executing actions from a database in response to an alarm condition. For claim 4, Simon was said to teach storing these sets of responses, such as user content preferences or a database of actions.

Ground 2: Claims 1 and 4-10 are obvious over Simon in view of Heaton

  • Prior Art Relied Upon: Simon (Patent 6,928,148) and Heaton (Application # 2004/0189460).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Simon provided the base system, and Heaton supplied additional features to render the claims obvious. Specifically, Heaton taught an Automatic Monitoring Station (AMS) that performs a wide range of pre-determined responses to alarm events, such as notifying users via email or SMS. For claim 7, Heaton disclosed its AMS instructing a local alarm control unit (ACU) to perform actions, such as activating a camera and transmitting video, which constituted transmitting control information as a pre-determined response. For claim 6, Heaton disclosed a user interface for entering and storing response data.
    • Motivation to Combine: A POSITA would combine Simon and Heaton to enhance Simon’s basic remote monitoring system with the more robust, user-configurable response capabilities taught by Heaton. This would create a more flexible and powerful security platform, which was a predictable improvement.
    • Expectation of Success: Combining Heaton’s software-based response logic with Simon’s known network-connected hardware architecture would have involved routine engineering and yielded predictable results.

Ground 3: Claims 1 and 4-10 are obvious over Palka in view of Simon and/or Heaton

  • Prior Art Relied Upon: Palka (Patent 6,741,171), Simon (Patent 6,928,148), and Heaton (Application # 2004/0189460).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Palka disclosed the core system of a “central monitoring station host” (network node) communicating with an “alarm panel” over a TCP/IP network. Palka’s alarm panel included communication modules (Modem, Ethernet I/O) and a data bus connecting a CPU and keypad input, which taught the claimed communications unit and keypad bus. Petitioner asserted that combining Simon was necessary to explicitly add a keypad processor to Palka's keypad input, which a POSITA would find obvious to enable more advanced functions. Heaton was added to provide the broad, user-defined response functionalities and the transmission of control information back to the local unit.
    • Motivation to Combine: A POSITA would combine Palka’s alarm system with Simon’s keypad processor to improve the functionality and user interface of the local system. A POSITA would further incorporate Heaton's advanced, customizable remote response features into Palka's system to create a more competitive and user-friendly security product, a well-known goal in the art.
    • Expectation of Success: Integrating Simon's known component (keypad processor) and Heaton's response logic into Palka's network-based alarm architecture was presented as a straightforward application of known design principles.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Simon and Heaton with Saylor CIP (Patent 7,113,090) to teach arm/disarm commands (claim 11), and combining Simon and Heaton with Patrick/Tyroler (Application # 2005/0146430 and Application # 10/364,909) to address specific data formatting arguments.

4. Key Technical Contentions (Beyond Claim Construction)

  • Scope of "Keypad Bus Information": Petitioner preemptively argued against a narrow interpretation of "keypad bus information." Petitioner contended that even if the term requires information to be formatted according to a specific keypad bus protocol when received by the network node, the claims would still be obvious. The combination of Patrick and Tyroler was cited to show the common practice of transmitting industry-standard alarm data formats (like ContactID) over a network (like the Internet) using a different protocol (e.g., TCP/IP) than the one used on the local keypad bus. A POSITA would have found it obvious to adapt Simon's system to use such a standard format to leverage its advantages, thus rendering the claims obvious even under a narrower construction.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1 and 4-11 of the ’736 patent as unpatentable.