PTAB

IPR2019-00326

Cisco Systems Inc v. Traxcell Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Managing a Wireless Radio-Frequency Network
  • Brief Description: The ’320 patent discloses a system for tuning a wireless network by using a mobile device's location and performance data. The system collects this data, compares it to expected performance, determines corrective actions like adjusting base station power, and includes a privacy feature to control access to the device's location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Garceran, Chiang, and Johansson - Claims 1 and 4 are obvious over Garceran in view of Chiang and Johansson.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), and Johansson (WO 1998/52379).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches all limitations of independent claims 1 and 4. Garceran disclosed a base system for optimizing wireless network coverage by collecting mobile device location and performance data (e.g., signal strength) in a central database to adjust base station transmit power (downlink power control). Chiang taught enhancing this concept by using geolocation data to make more intelligent decisions about uplink power control, avoiding wild fluctuations caused by temporary signal fading. Johansson addressed the privacy concerns inherent in location-based services by disclosing a user-settable indicator, or "no access flag," that permits or denies a second party's request for the mobile device's location.
    • Motivation to Combine: A POSITA would combine Garceran and Chiang to create a more robust network optimization system that managed both downlink and uplink power control based on location data. This combination would solve the well-known "near-far" problem in CDMA networks, which Garceran’s system used, making uplink control a necessary addition. A POSITA would further integrate Johansson’s privacy feature because location-tracking for network tuning also enables other location-based services, raising predictable privacy issues. Johansson offered a known, simple, and easily integrated solution to this problem, allowing users to control the dissemination of their location data.
    • Expectation of Success: The combination was argued to be a predictable integration of known elements. Garceran and Chiang disclosed similar network architectures, making the addition of Chiang’s uplink control to Garceran’s system straightforward. Johansson’s privacy flag was described as a minor modification applicable to any telecommunications system, ensuring it could be successfully implemented in the combined Garceran/Chiang system to yield predictable results.

Ground 2: Obviousness over Garceran, Chiang, Johansson, and 3GPP - Claims 2, 3, 5, and 6 are obvious over the combination of Garceran, Chiang, and Johansson in view of 3GPP.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), Johansson (WO 1998/52379), and 3GPP (Technical Specification 25.433 v4.0.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the dependent claims, which required receiving an "error code" and determining a corrective action based on its "value." Petitioner argued that while Garceran and Chiang taught detecting and communicating error conditions (e.g., poor service locations, sudden signal drops), they did not specify the use of a coded message. The 3GPP standard, a well-known specification for 3G cellular networks, disclosed a standardized and efficient method for communicating such information. 3GPP defined specific codes for reporting signal quality metrics like Signal-to-Interference Ratio (SIR) and SIR error, which a base station would send to a network controller.
    • Motivation to Combine: A POSITA implementing the Garceran/Chiang system would have been motivated to use a standardized and efficient communication protocol for reporting performance data. The 3GPP specification provided a natural and obvious choice for this purpose. Using 3GPP's compact codes (e.g., 6-7 bits) instead of full numerical data types (32 or 64 bits) would significantly reduce signaling overhead, a critical concern in bandwidth-limited wireless networks of the time. This standard directly addressed how to communicate the very type of performance data and error conditions disclosed in Garceran and Chiang.
    • Expectation of Success: A POSITA would have had a high expectation of success in using 3GPP's standardized codes to report the error conditions from Garceran and Chiang. The 3GPP specification was designed for this exact purpose in cellular networks, making its application to the combined system a predictable implementation of a known industry standard.

4. Key Claim Construction Positions

  • “referenc[es]/[ing] the performance data”: Petitioner argued this term should be construed to mean "comparing performance data to a target or threshold." This construction was asserted to be critical because both Garceran and Chiang disclose comparing measured signal quality data against a threshold or stored statistical data (expected performance) to determine if a corrective action, such as a power adjustment, is necessary.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 of the ’320 patent as unpatentable.