ipDataTel LLC v. ICN Acquisition LLC

1. Case Identification

• Case #: IPR2018-01822
• Patent #: 9,141,276
• Filed: September 28, 2018
• Petitioner(s): ipDataTel, LLC; Alula Holdings, LLC; Resolution Products, LLC
• Patent Owner(s): ICN Acquisition, LLC
• Challenged Claims: 1, 2, 5, 7, 8, 11, 13, 14, 17

2. Patent Overview

• Title: INTEGRATED INTERFACE FOR MOBILE DEVICE
• Brief Description: The ’276 patent discloses an integrated security system that enables users to remotely monitor and control a premise-based security system using a mobile device. The system architecture involves a local gateway communicating with sensors, a remote server infrastructure, and user applications on mobile devices that connect to the system over a network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Johnson and BeAtHome - Claims 1, 7, and 13 are obvious over Johnson in view of BeAtHome.

• Prior Art Relied Upon: Johnson (Patent 6,580,950) and BeAtHome (a user guide published in 2000).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Johnson and BeAtHome collectively disclose all elements of the independent claims. Johnson teaches an internet-based home communication system where a user can remotely monitor and control home devices, including a security system, via a web browser on devices like wireless web-connected phones. BeAtHome similarly discloses a security system with a "Home Appliance" that communicates with a secure website, accessible via mobile devices, to provide remote control and monitoring. Petitioner contended these references teach a monitoring system with sensors, a mobile device provided separately, and applications (e.g., a web browser) running on the device. The login procedures described in both references were argued to meet the "synchronization" limitation, establishing a two-way communication link between the mobile device and the monitoring system's data center to exchange status information and user commands.
  • Motivation to Combine: A POSITA would combine Johnson and BeAtHome because they describe substantially the same commercially available system and address the same problem of remote home monitoring. Both references even use the term "BeAtHome" in their URLs or product descriptions, suggesting they describe different aspects of the same system. The combination would have been a predictable implementation of known technologies for a known purpose.
  • Expectation of Success: A POSITA would have a high expectation of success as the combination involved applying the web-based remote access of Johnson to the specific security system components of BeAtHome, which was a routine and predictable integration.

Ground 2: Obviousness over Johnson/BeAtHome and Additional Art for Custom Applications - Claims 2, 8, and 14 are obvious over Johnson and BeAtHome, optionally in view of Dykes, and further in view of Granade and Artz.

• Prior Art Relied Upon: Johnson (Patent 6,580,950), BeAtHome (a user guide), Granade (Application # 2002/0103881), and Artz (Patent 7,461,120).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the base combination of Johnson and BeAtHome to address the dependent claims' limitation of a "custom-built" application. Petitioner asserted that Granade teaches that applications for mobile devices must often accommodate browsers and presentation methods tailored to different devices, particularly noting the need for customized WAP browsers. Artz further teaches that different computer systems use distinct, non-interchangeable operating systems and browsers (e.g., Safari for MacOS vs. Internet Explorer for Windows). These references establish that custom-building applications for specific hardware and software platforms was a well-known practice at the time.
  • Motivation to Combine: A POSITA would be motivated to modify the Johnson/BeAtHome system by incorporating custom-built applications as taught by Granade and Artz for predictable reasons. To ensure a consistent and reliable user experience across the diverse landscape of mobile devices, it would have been obvious to create applications (such as browsers or dedicated apps) tailored to the specific display requirements, input modes, and operating systems of those devices.
  • Expectation of Success: Applying known application programming techniques to accommodate known mobile device features would have been a routine task for a POSITA with a high expectation of success.

Ground 3: Obviousness over Johnson/BeAtHome and Additional Art for Alarm Overrides - Claims 5, 11, and 17 are obvious over Johnson and BeAtHome, optionally in view of Dykes, and further in view of Monnes and Donner.

• Prior Art Relied Upon: Johnson (Patent 6,580,950), BeAtHome (a user guide), Monnes (Patent 6,459,440), and Donner (Patent 7,392,306).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed the dependent claims' limitations related to receiving an "alarm event" and "overriding a first application" with a higher-priority alarm notification. Petitioner argued that while Johnson/BeAtHome teach sending alerts, Monnes and Donner explicitly teach the claimed override functionality. Monnes discloses using pop-up windows for alarm notifications on mobile devices, which can cover a full or partial screen. Donner teaches creating user profiles to set alert priorities, allowing a high-priority event to generate a pop-up window or other notification that overrides a lower-priority application currently in use.
  • Motivation to Combine: A POSITA would combine the alarm override and pop-up notification features of Monnes and Donner with the Johnson/BeAtHome security system to enhance its functionality. Providing a prominent, overriding alert for a critical alarm event is a more effective notification method than a simple email or status update. This combination of known elements would yield the predictable result of a more robust and user-friendly alarm system.
  • Expectation of Success: Integrating a known pop-up alert mechanism into a web-based monitoring system was a straightforward implementation for a POSITA.

• Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 1, 7, and 13 over Johnson and BeAtHome in view of Dykes (Patent 5,872,915), which was argued to provide additional detail on using username/password authentication to establish a secure, two-way communication link (i.e., "synchronization") with a web server.

4. Key Claim Construction Positions

• For the purposes of the IPR, Petitioner proposed adopting the Patent Owner's proposed construction of "synchronization" from the related district court litigation.
• Proposed Construction: "two-way exchange of information over an electronic network to establish a communication link between the mobile device and the monitoring system."
• Petitioner noted that this was the broadest reasonable construction, while reserving the right to argue in the parallel litigation that the term is indefinite. This construction was central to mapping the login procedures described in the prior art to the "synchronization" limitation of the claims.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 5, 7, 8, 11, 13, 14, and 17 of Patent 9,141,276 as unpatentable.