PTAB

IPR2019-00327

Cisco Systems Inc v. Traxcell Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Network Tuning System
  • Brief Description: The ’284 patent describes a system and method for tuning a wireless network by using a computer to collect and store mobile device location and performance data, and then adjusting network parameters, such as base station transmit power, based on that data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Garceran, Chiang, and 3GPP - Claims 1-5 and 8 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), and 3GPP (Technical Specification 25.433).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Garceran and Chiang disclosed all elements of independent claim 1 except for the "error code" limitation. Garceran taught a system for optimizing downlink power control using mobile device location and performance data (e.g., signal strength, error rate). Chiang taught using mobile device location to improve uplink power control. Together, they disclosed a network with wireless devices, radio towers (base stations), and a computer (MSC) that locates devices, stores performance data, and suggests corrective actions (power adjustments). Petitioner contended that the 3GPP standard, a well-known document in the field, disclosed the use of standardized, efficient codes for communicating network performance information, such as signal-to-interference ratio (SIR) and SIR error, which satisfied the "error code" limitation.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Garceran's downlink optimization with Chiang's uplink optimization to create a more robust and comprehensive power control system, as both address the same fundamental problem in cellular networks. Because Garceran and Chiang did not specify how error conditions (e.g., a sudden signal drop) were communicated, a POSITA would naturally turn to an industry standard like 3GPP to implement a known, efficient method for this communication. Using codes, as taught by 3GPP, was argued to be an obvious choice to reduce signaling overhead on bandwidth-limited wireless networks.
    • Expectation of Success: The combination involved applying a standard communication protocol (3GPP) to a known type of network optimization system (Garceran/Chiang), which would have yielded predictable results.

Ground 2: Obviousness over Garceran, Chiang, 3GPP, and Sheffield - Claims 6 and 7 are obvious over Garceran in view of Chiang, 3GPP, and Sheffield.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), 3GPP (Technical Specification 25.433), and Sheffield (Patent 6,603,966).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Sheffield to the base combination from Ground 1 to address limitations in claims 6 and 7 related to presenting data to a human user. Sheffield disclosed a "system evaluator" on a second computer (a base PC) that receives network performance data (including power levels) and location data, and visually displays this information in real-time to a user for network analysis and diagnostics. This was alleged to teach the limitations of sending power parameter data to a user of a second computer and generating a message identifying location and performance data for display.
    • Motivation to Combine: Petitioner argued that a POSITA would have recognized that wireless networks require human-driven tuning and management. Therefore, it would have been obvious to add Sheffield’s user interface and data visualization features to the automated system of Garceran/Chiang. This would allow a network diagnostician to see the performance data and coverage maps generated by the system, providing a useful tool for optimization and troubleshooting.

Ground 3: Obviousness over Garceran, Chiang, 3GPP, Sheffield, and Johansson - Claims 9-11 are obvious over Garceran in view of Chiang, 3GPP, Sheffield, and Johansson.

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), 3GPP (Technical Specification 25.433), Sheffield (Patent 6,603,966), and Johansson (Patent 6,442,391).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Johansson to the prior ground's combination to address limitations in claims 9-11 concerning user privacy and access control. Johansson taught a system for protecting user privacy by allowing a user to set a "no access flag" (an indicator in the Home Location Register) to permit or deny requests for their location data from a third party (a "second computer"). Johansson disclosed the second computer generating a "status request" for location, the network checking the user's flag, and denying the request if permission was not granted.
    • Motivation to Combine: Petitioner asserted that a POSITA building a system that collects and uses sensitive location data would have been motivated to address well-known user privacy concerns. Johansson provided an obvious solution by teaching a mechanism to give users control over their location data. A POSITA would have integrated Johansson’s privacy features into the combined system to provide a necessary data protection function.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 12 (Ground 4) based on the combination of Garceran, Chiang, and Johansson, arguing claim 12 is largely a compilation of limitations found in claims 1, 7, and 9.

4. Key Claim Construction Positions

  • "referencing performance": Petitioner argued this term should be construed to mean "comparing performance data to a target or threshold." This construction was asserted to be supported by the specification's examples, where measured data (like Ec/Io) is compared to a "minimum value" to determine if corrective action is needed.
  • "means for receiving said performance data and suggest corrective action" (Claim 1): Petitioner contended this is a means-plus-function limitation under 35 U.S.C. §112, para. 6. The functions were identified as "receiving performance data" and "suggesting corrective action." The corresponding structure disclosed in the specification was argued to be a computer with a processor, memory, and a network interface, running specific software modules like the "Monitoring Software 2802" and "Fault Diagnosis and Correction Software 2806."

7. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-12 of the ’284 patent as unpatentable.