PTAB

IPR2019-00327

Cisco Systems, Inc. v. Traxcell Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Wireless Network and Method for Providing Location and Performance Data
  • Brief Description: The ’284 patent describes a system for tuning a wireless network by using mobile device location and performance data. The system locates mobile devices, stores their location and signal characteristics, and utilizes a computer to adjust the transmit power of base stations based on the collected information to address network problems.

3. Grounds for Unpatentability

Ground 1: 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 (TS 25.433).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Garceran and Chiang collectively taught the core elements of independent claim 1: a wireless network with mobile devices, radio towers, and a central computer for network optimization. Garceran disclosed a system for downlink power control based on mobile device location and performance data (e.g., signal strength, error rate). Chiang taught an improved method for uplink power control that incorporated mobile device location to solve stability problems inherent in systems relying only on signal strength. The key limitation of claim 1 not explicitly taught by Garceran or Chiang was the generation of an "error code."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Garceran and Chiang to create a comprehensive power control system that optimizes both uplink and downlink, a known objective in cellular network design. Combining Garceran’s downlink control with Chiang’s uplink control would address the well-known "near-far problem" in CDMA networks, which Garceran employs. The combination was said to be predictable as both references were from the same assignee (Lucent) and described similar network architectures. A POSITA would then turn to the 3GPP standard to implement the communication of error conditions (e.g., a "sudden drop in signal strength" from Chiang), as it provided an efficient, standardized method using "error codes" (like SIR_error) instead of less efficient raw numerical data.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination involved applying known solutions (uplink power control, standardized signaling) to address known problems (the near-far problem, efficient data communication) in a predictable manner.

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

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), 3GPP (TS 25.433), and Sheffield (Patent 6,603,966).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1, adding Sheffield to teach limitations in claims 6 and 7 related to presenting network data to a human user. Specifically, Sheffield disclosed a "system evaluator" on a "second computer" (a base PC) that receives and displays network performance and location data in real-time on a GUI for a human user to analyze. This taught the limitations of sending RF signal power parameter data to a user (claim 6) and generating a message identifying location and performance for display (claim 7).
    • Motivation to Combine: Petitioner contended that a POSITA would recognize that even an automated network tuning system like the Garceran/Chiang/3GPP combination would benefit from human oversight and manual tuning. A POSITA would therefore be motivated to integrate Sheffield’s visual display tools to allow a network diagnostician to view the performance data and RF coverage maps generated by the primary system, thereby enabling more effective, human-driven optimization.
    • Expectation of Success: The combination would predictably result in a system that both automatically adjusts parameters and provides a visual interface for human analysis, a common design pattern in complex system management.

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

  • Prior Art Relied Upon: Garceran (Patent 6,522,888), Chiang (Canadian Application # 2,325,644), 3GPP (TS 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 combination to address the privacy-related limitations of claims 9-11, such as generating a "status request" from a second computer and using a "no access flag" to control information release. Johansson taught a method for protecting user privacy by requiring authorization before sharing a mobile device's location. It described a system where a user can set an indicator (a "no access flag") in a home location register (HLR) to permit or deny location-finding requests from third parties.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Johansson’s privacy features because the use of location data for network optimization raises well-known privacy concerns. Integrating Johansson’s user-controlled "no access flag" was a logical step to provide necessary privacy protection for third-party requests, while still allowing the network operator to use the location data for internal optimization. Johansson explicitly stated its solution was designed for easy integration into existing telecommunication systems.
    • Expectation of Success: Combining Johansson's privacy controls with the network optimization and display system would predictably yield a system that balanced functionality with user privacy, a known and desirable goal.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 12, arguing it was a compilation of limitations already taught by the combination of Garceran, Chiang, and Johansson.

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 based on the patent's disclosure of comparing measured metrics (e.g., Ec/Io) to a "minimum value" or "threshold limit" to determine if a corrective action is needed.
  • "means for receiving said performance data and suggest corrective action": Petitioner argued this term in claim 1 should be construed as a means-plus-function limitation under §112, para. 6. The claimed function was identified as "receiving said 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 card. This construction was central to mapping the functions of the prior art's network computers to the claimed "means."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-12 of the ’284 patent as unpatentable under 35 U.S.C. §103.