PTAB

IPR2019-00458

Samsung Electronics Co Ltd v. Seven Networks LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Resource Conservation by Manipulating Application Triggers
  • Brief Description: The ’127 patent relates to conserving mobile device resources, such as battery power and CPU usage, by manipulating the timing of triggers (e.g., alarms, timers) used by applications. The system can optimize background traffic and adjust application activity timing based on user selections and power-saving modes.

3. Grounds for Unpatentability

Ground 1: Obviousness over Giaretta and Lee - Claims 33, 38, 41-42, 44, and 48 are obvious over Giaretta in view of Lee.

  • Prior Art Relied Upon: Giaretta (Patent 9,264,868) and Lee (Application # 2012/0272230).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Giaretta taught the core limitations of independent claims 33 and 42 by disclosing a system that optimizes background traffic to conserve battery power. Giaretta’s system aggregates and delays network requests from multiple applications executing in a background mode, effectively batching data transfers. While Giaretta distinguished between "critical" and "non-critical" applications, Petitioner asserted it did not explicitly teach receiving a user selection for this purpose. Lee was argued to supply this missing element, as it disclosed a user configuration panel allowing a user to individually set application preferences (e.g., update frequency) and enable/disable a power-saving mode. Lee also taught that a power save mode could be exited based on a user directive.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Lee's user-selectable controls with Giaretta's traffic optimization system. Since Giaretta already differentiated applications based on delay tolerance, it would have been a predictable and obvious improvement to allow the user—who best knows which applications are critical—to make that selection via a user interface as taught by Lee.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as both systems operate on similar mobile device hardware and the integration would require only minimal, routine modifications.

Ground 2: Obviousness over Backholm - Claims 33, 38, 41-42, 44, and 48 are obvious over Backholm.

  • Prior Art Relied Upon: Backholm (Application # 2012/0023190).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Backholm, by itself, rendered the claims obvious. Backholm disclosed a distributed proxy system on a mobile device that "allows optimization of network usage" for background applications by using a "traffic shaping engine" with a "batching module." This system aligns and delays data requests from different applications to reduce radio use. Critically, Backholm was argued to explicitly teach receiving user selections for this optimization, stating that the batching capability can be "disabled or enabled at the application level... based on... user configuration" and that "the user can manually configure a setting." Backholm also disclosed that its power save mode monitors battery level as a condition for activation and can be "turned on and off, for example, by the user via a user interface."
    • Motivation to Combine (for §103 grounds): Not applicable for a single reference ground.
    • Expectation of Success (for §103 grounds): Not applicable for a single reference ground.

  • Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 2 and 4) against claims 35 and 45 by adding Hackborn (Patent 8,280,456) to the primary combinations of Giaretta/Lee and Backholm, respectively. Hackborn was cited for its teaching of a graphical user interface that displays per-application battery consumption percentages, allegedly rendering obvious the dependent claim limitation to "display an indication of battery consumption associated with the first application."

4. Key Claim Construction Positions

  • "optimize background traffic" (claims 33 and 42): Petitioner proposed construing this term as "adjust background traffic to conserve network or mobile device resources." This construction was based on the Patent Owner's own proposed construction in related district court litigation. Petitioner adopted this construction for the purpose of the IPR to argue that the claims were obvious even under the Patent Owner's interpretation, which encompassed actions like batching data, pipelining traffic, and delaying data transmission to conserve resources.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 33, 35, 38, 41-42, 44-45, and 48 of the ’127 patent as unpatentable.