PTAB

IPR2018-01823

ipDataTel, LLC v. ICN Acquisition, LLC

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1. Case Identification

2. Patent Overview

  • Title: Gateway Registry Methods and Systems
  • Brief Description: The ’871 patent discloses systems and methods for remotely managing local network devices. The technology centers on a two-step process where a gateway device first communicates with a remote "gateway registry" to obtain the network address of a "gateway server," and then communicates with that gateway server to download user-specific account information and configuration settings needed to manage the local devices.

3. Grounds for Unpatentability

Ground 1: Claims 1, 6, 15, 17, and 31 are obvious over Vasisht in view of Evans and Donahue.

  • Prior Art Relied Upon: Vasisht (Application # 2004/0133689), Evans (Application # 2005/0055575), and Donahue (Application # 2003/0101243).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of these three references renders the challenged claims obvious. Vasisht was asserted to disclose the foundational system: a gateway device that manages a local network of devices (e.g., security sensors, controllers) by retrieving configuration settings from a remote server (an ISP). However, Petitioner contended Vasisht uses a single-step process where the gateway sends its MAC address directly to the ISP's DHCP server and receives configuration settings in return. Petitioner argued Vasisht lacks the claimed two-step process involving a "gateway registry."

      To supply this missing element, Petitioner relied on Evans. Evans was argued to teach a two-step configuration method using standard DHCP protocols. In Evans, a network device (a DHCP client) sends a request with its identifier to a first server (a DHCP server). This first server, which Petitioner equated to the claimed "gateway registry," responds not with the full configuration, but with the network address of a second server (a TFTP server). The device then contacts this second server, which Petitioner equated to the claimed "gateway server," to download the detailed configuration file.

      Finally, Petitioner asserted that Donahue teaches associating the configuration data with a specific user "account." Donahue describes a system where a DSL gateway's unique serial number is linked to a specific user's order. The gateway sends its serial number in a DHCP request to a remote server, which then uses the number to look up and return the "user's unique configuration details." This supplies the claimed concept of an "account" and "account information" tied to the gateway device. For dependent claims, Petitioner argued that the use of a MAC address as the serial number (claim 6) is explicitly taught by both Vasisht and Evans as a standard device identifier in DHCP requests.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Vasisht with Evans to improve the scalability and manageability of the network configuration process, an advantage expressly stated in Evans. A POSITA would be further motivated to incorporate Donahue's teachings to enable user-specific customization of configuration settings, which is a logical and predictable improvement for managing numerous distinct networks (e.g., multiple home security systems). The combination represents a predictable use of known technologies to solve a known problem.

    • Expectation of Success: A POSITA would have a high expectation of success in combining these references. The proposed modification involved integrating well-understood networking standards (DHCP, TFTP) and applying them in their conventional manner. The combination was presented as an assembly of prior art elements according to known methods to yield predictable results.

4. Key Claim Construction Positions

  • "Account": Petitioner argued that, based on the specification of the ’871 patent, the term "account" should be construed to mean a "user's record." This construction was asserted to be critical to the obviousness argument, as it provides the necessary link between the generic "configuration file" taught in Evans and the user-specific "account information" taught in Donahue. By construing "account" as a user-specific record, Petitioner could map Donahue's disclosure of retrieving "user's unique configuration details" onto the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 6, 15, 17, and 31 of Patent 8,478,871 as unpatentable.