PTAB

IPR2019-00539

Cisco Systems Inc v. Meetrix IP LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Participant Conferencing Over Hybrid Networks
  • Brief Description: The ’332 patent describes a teleconferencing method for supporting multi-participant collaboration across hybrid networks, specifically combining a packet-switched network (Internet) and a circuit-switched network (Public Switched Telephone Network or PSTN). The system utilizes a central bridge to receive and mix audio data from various clients (e.g., VoIP clients, PSTN clients) and transmits the mixed audio back to the participants.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Conferencing and VPN References - Claims 1, 2, 4, 5, and 7 are obvious over Knappe in view of Elliott and the VPN Textbook.

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), and the VPN Textbook (“MPLS and VPN Architectures,” 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Knappe, discloses the core elements of claim 1, including a multi-participant conference system with a conference bridge that receives audio from both PSTN and IP-based clients (including a moderator). Knappe’s bridge mixes audio from various participants and transmits a custom mixed stream back to each participant (e.g., mixing moderator and PSTN audio for a remote client). Petitioner contended that Elliott, which is in the same field, supplies the missing limitations by teaching the use of a Virtual Private Network (VPN) with IP-tunneling for secure conferencing and the transmission of collaboration data (e.g., application sharing, web browsing) in addition to audio/video. The VPN Textbook was cited to teach that a "hub-and-spoke" topology is the most common, cost-effective, and least complex way to implement the VPN taught by Elliott, thereby disclosing the claimed VPN tunnel structure.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Knappe and Elliott to achieve predictable benefits. Adding Elliott's VPN technology to Knappe's internet-based system was argued to be a straightforward solution to the well-known problem of insecurity on public networks. Incorporating Elliott's teachings on collaboration data would enhance Knappe's system by providing more effective ways for participants to share information. A POSITA implementing the resulting system would then consult a reference like the VPN Textbook and select the conventional hub-and-spoke topology for its known cost and simplicity benefits.
    • Expectation of Success: Petitioner argued success would have been reasonably expected because the combination involved applying conventional technologies (VPN tunneling, hub-and-spoke architecture) to a known system (Knappe's conferencing bridge) to achieve predictable results (enhanced security and functionality).

Ground 2: Obviousness with Added Software and Compression Features - Claims 3 and 6 are obvious over Knappe in view of Elliott, the VPN Textbook, and Drell.

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), the VPN Textbook (“MPLS and VPN Architectures,” 2001), and Drell (Patent 7,089,285).
  • Core Argument for this Ground: This ground builds upon the combination in Ground 1 and adds the teachings of Drell to address limitations in dependent claims 3 and 6.
    • Prior Art Mapping: Petitioner alleged that Drell provides teachings for limitations not explicitly met by the primary combination. Specifically, claim 3 requires receiving and decoding IP packets from the PSTN client at a moderator computer system, and claim 6 requires encoding mixed audio into compressed audio data. Drell teaches a low-cost conferencing system where the functions of a traditional, expensive, centralized hardware bridge are implemented as software on a participant's endpoint computer (a "near conference endpoint"). This software-based approach, located at the moderator's system, would perform the receiving and decoding functions. Drell also explicitly teaches using an audio codec to encode audio streams with a standard or proprietary compression algorithm (e.g., H.323) to reduce the amount of data transmitted over the network.
    • Motivation to Combine: The primary motivation to add Drell's teachings to the Knappe/Elliott combination was cost and efficiency. A POSITA would combine Drell's software-based bridge concept with Knappe's system to replace the costly dedicated hardware bridge with a more economical software solution running on an existing participant's computer, such as the moderator's. A POSITA would also have been motivated to incorporate Drell's audio compression techniques to reduce bandwidth usage, a common and well-understood optimization for network communications that provides a predictable benefit.
    • Expectation of Success: Petitioner asserted a high expectation of success because implementing conferencing functions in software and using audio compression were conventional techniques in the art. Drell itself demonstrated the success of this approach, and modifying Knappe’s system with these known software-based improvements would have been a predictable endeavor for a POSITA.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of Patent 9,253,332 as unpatentable.