PTAB

IPR2019-00043

Panasonic Avionics Corp v. LinkSmart Wireless Technology LLC

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Petition
petition

1. Case Identification

2. Patent Overview

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

3. Grounds for Unpatentability

Ground 1: Obviousness over Abraham, Malkin, and Telia - Claims 91-99, 108-120, and 122-125 are obvious 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 Abraham, Malkin, and Telia rendered all challenged claims obvious under 35 U.S.C. §103. The primary reference, Abraham, was asserted to disclose the core architecture of the claimed system, while Malkin and Telia were used to supply missing features related to packet redirection and rule modification based on user data, respectively.

      • Abraham taught a network server for managing IP packet communication between a Local Area Network (LAN) and the internet. This server used a filter engine programmed with user-specific rule sets stored in a database. Critically, Abraham disclosed correlating these rule sets to a temporarily assigned network (IP) address for each user, which changes as users log in and out. Abraham's system could automatically modify portions of a rule set based on time (using "timer rules") and on the locations a user accesses (through a DNS verification process that updates rules based on visited websites). However, Abraham's server functions primarily to "allow" or "deny" packets, not "redirect" them.
      • Malkin was introduced to supply the "redirection" functionality required by the claims. Malkin described a system where a Network Access Server (NAS), upon denying a service request based on filtering rules, redirects the disallowed packet to a different server. This second server then sends an informative message back to the user explaining why the request was denied. Petitioner contended that augmenting Abraham's network server with Malkin's packet redirection technique would result in a "redirection server" that can allow, block, and redirect traffic, thus meeting the claim term's construction.
      • Telia was used to teach modifying a rule set as a function of data transmitted to or from a user. Telia described a system where a user is initially granted access only to an authorization server. To gain full network access, the user might be required to view an "advertisement message" (data to the user) and answer questions about it (data from the user). Upon successful interaction, the authorization server sends a message to the network filter to open access for that user's IP address. Petitioner argued this directly taught modifying a user's rule set from a restrictive state to a permissive state based on a data exchange with the user.

    • Motivation to Combine: Petitioner asserted several motivations for a person of ordinary skill in the art (POSITA) to combine the references.

      • A POSITA would combine Malkin with Abraham to provide a more beneficial and user-friendly system. Abraham's system contemplated sending "violation message[s]" but lacked a detailed mechanism for doing so. Malkin offered a known, predictable, and improved method for delivering informative denial-of-service messages by redirecting packets. This combination would predictably enhance Abraham's system without altering its fundamental filtering operation.
      • A POSITA would combine Telia with the Abraham/Malkin system to implement known and desirable network access controls, particularly in a corporate environment like that described in Abraham. Telia’s system of presenting a message and requiring a response before granting full access provided a clear blueprint for implementing an "Acceptable Use Policy" screen. An employee would be required to view and acknowledge corporate policy (an adaptation of Telia's "advertisement") before being allowed access to the internet, a common and beneficial security practice.

    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in making these combinations. The proposed modifications involved integrating known techniques (packet redirection, pre-access authentication) into a conventional network filtering architecture. The combination of these distinct but complementary technologies used known methods to yield the predictable result of a more robust and user-friendly network access control system.

4. Key Claim Construction Positions

  • "redirection server": Petitioner proposed this term be construed as "a server operable to control network access by applying the following actions: block, allow, and redirect." This construction was central to the argument, as Abraham's server primarily blocked and allowed traffic, making the addition of Malkin's redirection teaching necessary to meet the claim limitation.
  • "one or more of the user side... and the network side...": For claims 99 and 120, which require the server to modify a rule set based on instructions from one of these sides, Petitioner argued for a construction of "the user side or the network side." This interpretation, as opposed to requiring instructions from both, allowed Abraham's disclosure of receiving administrative instructions from a computer on the LAN (the "user side") to satisfy the claim limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) trial and the cancellation of claims 91-99, 108-120, and 122-125 of the ’459 patent as unpatentable.