PTAB

IPR2019-00412

ZTE (USA), Inc. v. SEVEN Networks, LLC

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1. Case Identification

2. Patent Overview

  • Title: Method for Power Saving in Mobile Devices by Optimizing Wakelocks
  • Brief Description: The ’254 patent describes methods for conserving power in a mobile device by managing "wakelocks"—mechanisms that prevent a device from entering a low-power sleep state. The invention involves detecting device activity states and entering a power optimization state where wakelocks from "non-critical" applications are released, while applications on a "whitelist" may be permitted to maintain their wakelocks.

3. Grounds for Unpatentability

Ground 1: Obviousness over WakeScope and Sony - Claims 1, 2, 4, and 9 are obvious over WakeScope in view of Sony.

  • Prior Art Relied Upon: WakeScope (Kim et al., WakeScope: Runtime WakeLock Anomaly Management Scheme for Android Platform) and Sony (Anna Aleryd, How Sony's Battery STAMINA Mode works).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that WakeScope, a technical paper, taught a runtime scheme to detect and manage "wakelock anomalies" to prevent energy waste in Android devices. It disclosed acquiring a system wakelock in response to an application request and detecting an activity state based on the display screen status (e.g., screen turning off). However, Petitioner contended WakeScope did not explicitly teach a user-configurable whitelist. Sony, a blog post describing a power management feature, disclosed the concept of a "Battery STAMINA Mode" that reduces background activity when the screen is off but allows users to "white list" important applications to permit them to continue running. Petitioner asserted the combination taught releasing a system wakelock for a non-whitelisted application upon entering a power optimization state (screen off) and subsequently acquiring a wakelock for a whitelisted application.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings to improve the system in WakeScope with the user-friendly whitelist feature from Sony. This would create a more practical and predictable power management tool, allowing users to customize which applications are critical enough to bypass the power-saving measures, thereby preventing the system from killing applications the user deems important.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it involved implementing a known software feature (a whitelist) into a known power management framework to achieve the predictable result of user-customizable power savings.

Ground 2: Obviousness over WakeScope, Sony, and Marcellino - Claim 5 is obvious over the combination of WakeScope, Sony, and Marcellino.

  • Prior Art Relied Upon: WakeScope, Sony, and Marcellino (Application # 2010/0216434).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the WakeScope and Sony combination from Ground 1 to address dependent claim 5, which added the limitation that the power optimization state is entered in response to whether the device is connected to a power source. Petitioner argued that Marcellino explicitly taught this concept. Marcellino disclosed that, to conserve battery life, mobile devices may enter a reduced power mode specifically "when not connected to a power supply."
    • Motivation to Combine: A POSITA would be motivated to add Marcellino’s teaching to the WakeScope-Sony system for a simple, common-sense reason: power optimization is only necessary when running on limited battery power. Disabling the power-saving features when the device is connected to an external power source, as taught by Marcellino, would avoid the tradeoff of reduced functionality when power is plentiful, thus improving the user experience without any downside.
    • Expectation of Success: The proposed modification was a straightforward and predictable improvement, involving the addition of a simple condition (checking the power source status) to a power management system.

Ground 3: Obviousness over WakeScope, Sony, and Srinivasan - Claims 3, 6-8, 10, 11, 13-15, 28, 29, and 31-33 are obvious over the combination of WakeScope, Sony, and Srinivasan.

  • Prior Art Relied Upon: WakeScope, Sony, and Srinivasan (Application # 2014/0038674).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the device's activity state to be based on sensed motion. Petitioner asserted that Srinivasan taught an "activity recognition system" for mobile devices that used sensors like an accelerometer and gyroscope to determine user activity (e.g., idle, walking, running). Based on this detected activity, Srinivasan’s system would dynamically control power consumption and could transition the device into a sleep mode. This directly taught using motion to determine the activity state, as required by the challenged claims.
    • Motivation to Combine: A POSITA would combine Srinivasan's motion-based activity detection with the WakeScope-Sony system to improve the accuracy of determining when the user is idle. Relying only on screen status can be flawed (e.g., a user might be listening to audio with the screen off). Adding motion detection as taught by Srinivasan would provide a more robust and reliable trigger for entering the power optimization state, preventing unwanted interruptions and improving the overall system intelligence.
    • Expectation of Success: Integrating motion sensor data into a power management system was a known technique, and a POSITA would expect to successfully add this functionality to the base system to yield the predictable benefit of more accurate activity detection.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 12 and 30 based on the combination of all four references: WakeScope, Sony, Marcellino, and Srinivasan. This ground argued that it would have been obvious to create a system incorporating all the features taught by the references, including the power source and motion detection limitations.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial by noting this petition was filed concurrently with a Motion for Joinder with an already-instituted IPR, Google LLC v. Seven Networks, LLC, IPR2018-01117. Petitioner contended that joinder would promote efficiency and avoid inconsistent results.
  • The petition also preemptively distinguished itself from other pending IPRs against the ’254 patent by stating that those proceedings relied on different primary prior art references, making the invalidity arguments in this petition new and distinct.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-15 and 28-33 of the ’254 patent as unpatentable.