PTAB

IPR2019-00315

ecobee Inc v. Lime Green Lighting LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: System, Method, and Apparatus for Self-Adaptive Scheduled Lighting Control
  • Brief Description: The ’874 patent describes a lighting control device that obtains environmental data from sensors and input data from a user. The device transmits this data to an external server, which in turn generates and provides a lighting operating schedule back to the device for controlling one or more lights.

3. Grounds for Unpatentability

Ground 1: Obviousness over Abraham and Barrilleaux - Claims 1-5, 9-10, 15, 17-18, and 20 are obvious over Abraham in view of Barrilleaux.

  • Prior Art Relied Upon: Abraham (Application # 2012/0095601) and Barrilleaux (Application # 2011/0307112).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Abraham disclosed the core architecture of the claimed invention, including a lighting control device with environmental sensors (occupancy, daylight) and user input devices (buttons) that communicates with an external "controller 150." Petitioner contended that this external controller met the "external server" limitation of the claims, as it received sensor and input data to facilitate control of the lighting devices. However, Abraham did not explicitly teach generating lighting schedules. Petitioner asserted that Barrilleaux remedied this deficiency by disclosing a goal-based lighting control system where an external server generates predictive lighting operating schedules as a function of time based on sensor data and user-defined management goals. The combination of Abraham's hardware system with Barrilleaux's scheduling intelligence allegedly rendered the independent claims (1, 15, and 20) obvious. For dependent claims, Abraham was argued to teach specific environmental data types (claim 2), input device types (claim 3), and dimmer technology using semiconductor devices via incorporated references (claim 5).
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Abraham and Barrilleaux because they address similar problems in the analogous field of lighting control. A POSITA would have been motivated to incorporate Barrilleaux’s advanced, predictive scheduling techniques into Abraham's system to achieve improved performance and energy savings, a key goal mentioned in both references.
    • Expectation of Success: Petitioner argued that combining the known elements of Abraham's control architecture with Barrilleaux's scheduling logic would have been a straightforward integration of complementary technologies, yielding predictable results.

Ground 2: Obviousness over Abraham, Barrilleaux, and Callahan - Claim 6 is obvious over the combination of Ground 1 in view of Callahan.

  • Prior Art Relied Upon: Abraham (Application # 2012/0095601), Barrilleaux (Application # 2011/0307112), and Callahan (Patent 4,633,161).
  • Core Argument for this Ground:
    • Prior Art Mapping: Claim 6 depends from claim 5 and requires the dimmer's semiconductor devices to control electrical current by either "adjusting the closing angle of an alternating-current waveform" or "pulse width modulation." Petitioner argued that a reference incorporated by Abraham (Gehman) already taught phase-control dimming, which corresponds to adjusting the closing angle. Callahan was introduced to explicitly teach an "electronic dimming apparatus" that uses a "pulse width modulating" dimmer. Petitioner argued that Callahan disclosed the advantages of pulse width modulation (PWM) were well-known, making it an obvious alternative control method for the dimmer in the Abraham/Barrilleaux system.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Callahan's teachings to implement a well-understood and effective dimming technique (PWM) as a design choice for the dimmer in the primary system. This would have been seen as the simple substitution of one known dimming method for another to achieve a predictable result.

Ground 3: Obviousness over Abraham, Barrilleaux, and Challapali - Claim 7 is obvious over the combination of Ground 1 in view of Challapali.

  • Prior Art Relied Upon: Abraham (Application # 2012/0095601), Barrilleaux (Application # 2011/0307112), and Challapali (Application # 2013/0285556).

  • Core Argument for this Ground:

    • Prior Art Mapping: Claim 7 adds the method steps of comparing a newly obtained lighting schedule to a currently-executing one and modifying the current schedule if the two are different. While the base combination taught obtaining a schedule, it did not explicitly describe this comparison and modification logic. Petitioner asserted that Challapali, which discloses a policy-based light management system, taught this exact functionality. Challapali’s central control apparatus was described as checking new policies for consistency against existing policies and suggesting modifications to resolve conflicts, directly mapping to the limitations of claim 7.
    • Motivation to Combine: A POSITA would have been motivated to integrate Challapali’s conflict-resolution procedures into the Abraham/Barrilleaux system to enhance its robustness. This would allow the lighting controller to intelligently manage and avoid potential conflicts between different lighting schedules, improving overall system reliability.

  • Additional Grounds: Petitioner asserted that claims 8 and 16 are obvious over Abraham and Barrilleaux in view of Cloutier (Patent 7,019,276). Cloutier was cited for its teaching of determining if environmental data conforms to a control limit (e.g., a setpoint) and executing commands to bring the environmental conditions into conformance.

4. Key Claim Construction Positions

  • "server": Petitioner proposed the construction "a system on a network that provides a service to other systems connected to the network." This construction was central to arguing that Abraham’s external "controller 150," which facilitates control of multiple lighting devices, qualified as the claimed "external server."
  • "influence value": Petitioner proposed the construction "a value corresponding to the degree to which a light bulb influence the light level." This term, relevant to claim 10, was argued to be taught by a reference incorporated into Abraham (Steiner) that described a calibration routine determining the effect of an electric light on a sensor's readings.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-10, 15-18, and 20 of the ’874 patent as unpatentable.