PTAB

IPR2019-00251

Apple Inc v. Uniloc 2017 LLC

Key Events

Petition

Title: COMMUNICATION SYSTEM
Brief Description: The ’049 patent relates to a wireless communication system, such as Bluetooth, for connecting devices like Human/Machine Interface Devices (HIDs). The invention addresses delays and power inefficiencies in connection procedures by proposing a method to "piggy-back" an additional data field onto standard inquiry messages, enabling a primary station to poll secondary stations at regular intervals.

Prior Art Relied Upon: Larsson (Patent 6,704,293).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Larsson, which discloses route discovery in wireless ad-hoc networks, teaches every element of the challenged claims. Larsson’s method involves a source node (primary station) broadcasting "request for route messages" to neighboring nodes (secondary stations). Petitioner contended these messages are "inquiry messages" as they seek route information. Larsson further discloses "piggybacking" a broadcast message onto this request to solicit a reply from a specific destination node. This piggybacked data, which polls the destination node, was argued to be the claimed "additional data field for polling." The receiving node in Larsson determines if it is the polled destination and responds accordingly, satisfying the final limitations of claim 11. For dependent claim 12, Larsson's disclosure of messages being sent with or without piggybacked data (distinguished by a "piggyback indicator") meets the limitation that not all inquiry messages have the additional data field.
- Key Aspects: This ground relies on interpreting Larsson's route discovery messages and piggybacking technique as analogous to the '049 patent's polling method.

Prior Art Relied Upon: Larsson (Patent 6,704,293) and BT Core (Specification of the Bluetooth System: Core, Vol. 1, Dec. 1, 1999).
Core Argument for this Ground:
- Prior Art Mapping: This ground serves as an alternative to Ground 1, arguing that if Larsson is deemed deficient, its combination with the BT Core specification renders the claims obvious. BT Core explicitly defines the standard Bluetooth packet format, including the specific "plurality of predetermined data fields" (e.g., access code, header, payload) that Larsson’s system would necessarily use. BT Core also describes a "POLL packet" used by a master to obtain a required response from a slave. Petitioner argued this confirms that Larsson's piggybacked message, which expects a reply, functions as a poll, strengthening the mapping of Larsson's teachings to the claim limitations regarding a "data field for polling."
- Motivation to Combine: A POSITA would combine Larsson with BT Core because Larsson explicitly discloses a system for a "Bluetooth scatternet." To implement Larsson's system, a POSITA would have naturally consulted the BT Core specification for standard implementation details, such as packet structure and polling mechanisms.
- Expectation of Success: The combination would yield predictable results, as it involves applying the official Bluetooth standard (BT Core) to a system designed to operate using the Bluetooth protocol (Larsson).

Prior Art Relied Upon: IrOBEX (IrDA Object Exchange Protocol technical publication).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the IrOBEX protocol, which defines a request-response framework for data exchange, discloses all claimed elements. The IrOBEX "CONNECT (request) packet," used by a requesting device (primary station) to initiate a connection and seek capability information from a receiving device (secondary station), was asserted to be an "inquiry message." This packet has a required structure of predetermined data fields. To create a "Directed Connection," IrOBEX teaches adding an optional "target header" to the packet. Petitioner contended this optional header is the "additional data field for polling," as it identifies a specific target device, service, or application and prompts it to respond. The receiving device determines if the packet contains this header, determines if it is the polled target, and responds only if it has relevant data, mapping to the remaining limitations of claim 11. Because the target header is explicitly optional, IrOBEX also meets the limitation of claim 12.
- Key Aspects: This ground proposes a non-Bluetooth-based prior art reference that allegedly contains a direct analog to the claimed polling mechanism.

"inquiry message[s]": Petitioner argued for the construction "a message seeking information or knowledge." This construction is central to all grounds, as it allows prior art messages that are not explicitly labeled "inquiry messages"—such as Larsson's "request for route message" and IrOBEX's "CONNECT (request) packet"—to be mapped to the claim term. Petitioner supported this construction by citing the '049 patent's specification, principles of claim differentiation, and a prior construction adopted by the Board for the same term in a related patent.

Petitioner requests institution of an inter partes review and cancellation of claims 11 and 12 of the ’049 patent as unpatentable.