PTAB

IPR2019-00458

Samsung Electronics Co., Ltd. v. SEVEN Networks, LLC

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1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Traffic Optimization on an Application-by-Application Basis
  • Brief Description: The ’127 patent discloses systems for conserving mobile device resources (e.g., battery, CPU) by manipulating the timing of triggers used by background applications. The invention focuses on receiving user selections to "optimize background traffic" for specific applications and to enter a "power save mode" that adjusts the timing of application activities to reduce resource consumption.

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 teaches most limitations of the independent claims. Giaretta discloses a system for managing network access requests when a mobile device is in a "background mode" to save battery power. It does this by manipulating the timing of application timers, forcing them to expire together to aggregate and bundle network requests. This aggregation corresponds to the claimed "optimizing background traffic" and "adjusting a timing of activities." Petitioner asserted that Giaretta's background mode is a power save mode that can be triggered when battery power falls below a threshold. However, Giaretta does not explicitly teach receiving a user selection for which applications to optimize.
    • Motivation to Combine: Petitioner contended that Lee addresses the missing user-selection element. Lee teaches a user configuration panel that allows a user to individually set the update frequency for applications, effectively defining their criticality and tolerance for delay. A person of ordinary skill in the art (POSITA) would combine Lee's user-configurable settings with Giaretta's traffic optimization system to allow users to decide which applications are critical and which can have their traffic optimized. This combination would be a predictable improvement, giving users control over resource management.
    • Expectation of Success: A POSITA would have a high expectation of success because combining a user interface for setting application preferences (from Lee) with a background process manager (from Giaretta) involves known software design principles and would not require undue experimentation.

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 argued that Backholm, which is assigned to the Patent Owner, teaches all limitations of the independent claims. Backholm discloses a distributed proxy system that "allows optimization of network usage" through a local proxy on the mobile device. This system includes a "batching module" that accumulates low-priority transactions for batch transfer when an application is in the background, which Petitioner mapped to the claimed "optimizing background traffic." Crucially, Backholm explicitly states that a user can manually configure settings to enable or disable this batching mechanism on an application-by-application basis, satisfying the "receive a selection from a user" limitation. Backholm further teaches that its system can enter a power save mode based on device properties, including battery level, and that this mode can be turned on or off by the user via a user interface.
    • Key Aspects: Petitioner emphasized that Backholm, a single reference from the Patent Owner itself, discloses all the core concepts of the challenged claims, including user-selectable, per-application traffic optimization and a power save mode based on battery level.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for dependent claims 35 and 45. These grounds added Hackborn (Patent 8,280,456) to the primary combinations of Giaretta/Lee and Backholm. Hackborn was cited to teach the limitation of displaying a graphical indication of battery consumption associated with specific applications. A POSITA would have been motivated to add Hackborn’s display to provide users with the necessary data to make informed decisions about which applications to select for traffic optimization.

4. Key Claim Construction Positions

  • Petitioner argued that the term "optimize background traffic," which appears in independent claims 33 and 42, should be construed as "adjust background traffic to conserve network or mobile device resources."
  • This construction was proposed for the inter partes review (IPR) proceeding based on the Patent Owner's own proposed construction and expert declarations in related district court litigation (e.g., SEVEN Networks, LLC v. ZTE (USA) Inc.). Adopting this construction is critical to Petitioner's argument, as it allows prior art that "adjusts" traffic (e.g., by batching or delaying) to meet the "optimize" limitation, even if the prior art does not use the exact word "optimize."

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 33, 35, 38, 41-42, 44-45, and 48 of the ’127 patent as unpatentable under 35 U.S.C. §103.