PTAB

IPR2019-00476

Unified Patents LLC v. Clean Energy Management Solutions LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Mesh Network Door Lock
  • Brief Description: The ’479 patent discloses an electronic door lock system designed to operate within a wireless mesh network. The system uses a network key to remotely communicate with and control the lock, leveraging the mesh topology for enhanced communication reliability.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sabo, ZigBee, and Elpern - Claims 1, 2, 9, 10, 15, and 16 are obvious over Sabo in view of ZigBee and Elpern.

  • Prior Art Relied Upon: Sabo (Patent 7,520,152), ZigBee (ZigBee Specification, Version 1.0), and Elpern (Patent 5,979,199).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sabo taught the foundational elements of a wireless home system, including a door lock, a base station, and a remote fob for control. However, Sabo did not explicitly detail the structure of a mesh network or a code authentication feature. Petitioner asserted that the ZigBee specification supplied the missing mesh network limitations, teaching a standard protocol with coordinator, router, and end node device types, as well as features for robust data forwarding. Sabo itself suggested its network could be a ZigBee network. To address the limitation of authenticating a code, Petitioner relied on Elpern, which taught an electronic lock system where a remote fob transmits an encrypted code or serial number that is verified at the lock before actuation.
    • Motivation to Combine: A POSITA would combine Sabo with ZigBee because Sabo expressly disclosed that its network could be based on the ZigBee standard. The motivation was to implement Sabo's system using a well-defined protocol to achieve the known benefits of mesh networking, such as extended range and greater reliability. A POSITA would then incorporate the teachings of Elpern to add a conventional security feature (code authentication) to Sabo's remote-control lock system, thereby preventing unauthorized access.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success. Modifying Sabo's network to conform to the ZigBee standard was a predictable implementation of a known protocol. Similarly, integrating Elpern's established code authentication technique into Sabo's wireless lock was a straightforward application of a known security solution to a similar system for the predictable result of enhanced security.

Ground 2: Obviousness over Rodriguez, ZigBee, and Tischendorf - Claims 1, 2, 6, 9, 10, and 15 are obvious over Rodriguez in view of ZigBee and Tischendorf.

  • Prior Art Relied Upon: Rodriguez (Application # 2006/0103503), ZigBee (ZigBee Specification, Version 1.0), and Tischendorf (Patent 6,297,725).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Rodriguez taught a home network system with a door lock, a remote transmitter, and the capability to operate as a "mesh" type network where devices could act as relay points. The specific network architecture details that were added to the ’479 patent claims during prosecution to overcome a rejection based on Rodriguez (e.g., coordinator/router/end nodes, full/reduced function devices) were all standard features of the ZigBee protocol. Therefore, ZigBee was used to supply these well-known mesh network implementation details. Petitioner further argued that Tischendorf, which is explicitly cited in the ’479 patent's specification, disclosed the claimed "electrically actuated arm" by teaching an electromechanical door lock with a rotating locking rod.
    • Motivation to Combine: A POSITA would combine Rodriguez's conceptual mesh network with the ZigBee standard to implement a practical, low-power, and robust network for controlling home appliances, including the door lock. The motivation to incorporate Tischendorf's lock mechanism was that it provided a known, compatible, and effective electromechanical design for the door lock in Rodriguez's system, a fact acknowledged by the patentee's own reference to Tischendorf.
    • Expectation of Success: Success would have been reasonably expected. Modifying Rodriguez’s network to utilize the specific roles and topologies defined by the ZigBee standard was a predictable software and configuration task. Likewise, integrating the known electronic lock mechanism from Tischendorf into the broader home automation system of Rodriguez represented a routine combination of known elements to achieve a predictable function.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 6, 9, 10, 15, and 16 of the ’479 patent as unpatentable.