PTAB

IPR2019-00324

Cisco Systems Inc v. Traxcell Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Network Tuning using Mobile Device Data
  • Brief Description: The ’024 patent describes a system for optimizing a wireless network by using a computer to collect and analyze mobile device location and performance data. Based on this analysis, the system determines and suggests corrective actions, such as adjusting the transmit power of base station transceivers to remedy network problems.

3. Grounds for Unpatentability

Ground 1: Obviousness over Garceran and Chiang - Claims 11-14 and 17-20 are obvious over Garceran in view of Chiang.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888) and Chiang (Canadian Application # 2,325,644 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Garceran discloses a system for optimizing wireless network coverage based on mobile device location and performance data, specifically for performing downlink power control. Independent claim 11 requires a computer that receives location and performance data, identifies faulty communication, and takes corrective action. Petitioner contended Garceran teaches these elements, such as using a Mobile Switching Center (MSC) to collect location and performance data (e.g., RSSI, BER) to adjust base station transmit power for poor coverage areas. Chiang was argued to supplement Garceran by teaching an improved method for uplink power control using mobile device geolocation data to make an "intelligent decision" about adjusting transmit power, rather than blindly reacting to signal fluctuations.
    • Motivation to Combine: A POSITA would combine these references to create a comprehensive power control system for both uplink and downlink, which was a known objective in cellular network design. Petitioner asserted that Garceran and Chiang are in the same field of endeavor (location-based services for cellular networks) and that adding Chiang's improved uplink control to Garceran's downlink system would be a logical step to solve the well-known "near-far problem" in CDMA networks, which requires robust uplink power management.
    • Expectation of Success: A POSITA would have had a high expectation of success because Garceran and Chiang disclose nearly identical network architectures (an MSC controlling multiple base stations). Garceran’s system already collects the necessary location and performance data that would enable the implementation of Chiang’s "intelligent" uplink power control logic, yielding the predictable result of a system with position-based power control in both directions.

Ground 2: Obviousness over Garceran, Chiang, and 3GPP - Claims 1, 2, 4-10, 15, 16, 21 and 22 are obvious over Garceran in view of Chiang and 3GPP.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644 A1), and 3GPP (3GPP Technical Specification 25.433 version 4.0.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the "error code" limitations present in independent claims 1 and 6 and their dependents. Petitioner argued that while Garceran and Chiang disclose the error conditions (e.g., poor coverage, a sudden drop in signal strength), they do not explicitly teach communicating this information using coded messages. The 3GPP standard, a well-known specification for 3G UMTS networks, was introduced to supply this missing element. 3GPP explicitly defines a system for communicating performance metrics, such as Signal-to-Interference Ratio (SIR) and SIR error, between a base station (Node B) and a network controller (RNC) using specific integer codes. This maps directly to the claim limitations requiring the computer to receive and act upon an "error code."
    • Motivation to Combine: A POSITA, having combined Garceran and Chiang, would need an efficient way to communicate the identified error conditions from the base station to the central computer (MSC/RNC). Petitioner contended it would be obvious to look to a prominent industry standard like 3GPP for a solution. The motivation was particularly strong due to the significant bandwidth efficiency offered by 3GPP's coding scheme (e.g., using 6 bits for a SIR value instead of a 32- or 64-bit floating-point number), which is a critical consideration in wireless systems.
    • Expectation of Success: Combining 3GPP would be straightforward and yield predictable results. A POSITA would simply apply the standardized 3GPP communication protocols to the error conditions (e.g., signal drop) already identified by the Garceran and Chiang systems, thereby creating the complete system claimed.

4. Key Claim Construction Positions

  • "coupled"/"coupling": Petitioner argued this term should be given its ordinary and customary meaning and should not be construed to require a direct physical connection. This construction was asserted as important because components in the prior art systems (e.g., an MSC and a base station) are functionally and communicatively coupled but may not be directly wired together.
  • "referenc[es]/[ing] the performance data": Petitioner proposed construing this phrase to mean comparing performance data to a target or threshold. This construction was central to the argument, as the prior art systems make corrective-action decisions by comparing measured performance data (e.g., signal strength) against predefined minimum values or thresholds to determine if a fault condition exists.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, and 4-22 of Patent 9,642,024 as unpatentable under 35 U.S.C. §103.