PTAB

IPR2019-00043

Panasonic Avionics Corp v. Linksmart Wireless Technology LLC

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1. Case Identification

2. Patent Overview

  • Title: User Specific Automatic Data Redirection System
  • Brief Description: The ’459 patent relates to a data redirection system for dynamically filtering and redirecting internet traffic. The system uses dynamically changing rule sets specific to individual users, based on database entries and user activity, to control network access.

3. Grounds for Unpatentability

Ground 1: Obviousness over Abraham, Malkin, and Telia - Claims 91-99, 108-120, and 122-125 are obvious under 35 U.S.C. §103 over Abraham in view of Malkin and Telia.

  • Prior Art Relied Upon: Abraham (Patent 5,983,270), Malkin (Patent 6,247,054), and Telia (European Patent No. EP0762707A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references teaches every element of the challenged claims, including all limitations of independent claim 91. Abraham was asserted to teach the foundational system: a network server that filters data packets between a local area network (LAN) and the internet using user-specific rule sets. Abraham's system correlates these rules to a user's temporarily assigned IP address and automatically modifies the rule set based on triggers, such as user logins or timed updates. To meet the "redirection server" limitation, Petitioner argued that a POSITA would modify Abraham's server, which primarily teaches blocking or allowing packets, with Malkin's teaching of redirecting denied packets to a different server to provide an informative denial message. The combination of Abraham’s allow/deny functions with Malkin’s redirect function was argued to meet the claimed "plurality of functions used to control data." For limitations requiring rule modification based on user activity, Petitioner asserted that Abraham discloses modifying rules as a function of time (via periodic timer rules) and location the user accesses (via a DNS verification process for visited websites). Petitioner supplemented this with Telia, which was argued to teach modifying access rules based on data transmitted to or from the user (e.g., a user's answers to questions about a policy) and the location of the access-check server itself. Petitioner argued that the combination of these teachings renders obvious the claims requiring rule modification as a function of time, data, or location.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Abraham with Malkin to predictably improve Abraham’s basic filtering with a more user-friendly denial-of-service notification, which was a known technique for enhancing network systems. A POSITA would have been further motivated to incorporate Telia’s teachings as a known and beneficial method for implementing pre-access authorization, such as requiring users in a corporate environment to view and accept a usage policy before being granted full internet access. This combination was presented as a straightforward application of known solutions to solve known problems.
    • Expectation of Success: Petitioner contended that combining these known elements for their recognized purposes—filtering, redirection for notifications, and pre-access checks—would have yielded only predictable results. It was argued that the modifications required programming skills that were well within the ordinary skill in the art at the time, ensuring a high expectation of success.

4. Key Claim Construction Positions

  • "redirection server": Petitioner argued that this term should be construed under the Phillips standard to mean a server that is operable to control network access by performing the functions of blocking, allowing, and redirecting packets. This construction was central to the obviousness argument, as Petitioner used the primary reference (Abraham) to teach blocking and allowing, and the secondary reference (Malkin) to supply the explicit teaching of redirection.
  • "one or more of the user side... and the network side...": For claims 99 and 120, Petitioner argued this phrase means that instructions to modify the rule set can be received from either the user side or the network side, not that they must be received from both. Petitioner contended this construction is supported by the specification and allows Abraham's disclosure—where an administrator on the LAN (the user side) provides instructions—to satisfy the claim limitation without requiring a teaching of instructions originating from the network side as well.

5. Relief Requested

  • Petitioner requests institution of an inter partes review for claims 91-99, 108-120, and 122-125 of the ’459 patent and cancellation of these claims as unpatentable.