PTAB

IPR2019-00540

CISCO SYSTEMS, INC. v. Meetrix IP, LLC

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1. Case Identification

2. Patent Overview

  • Title: System for Multi-Participant Audio/Video Conferencing
  • Brief Description: The ’332 patent relates to audio and video telecommunications technology for collaboration over hybrid networks, such as the Internet and the Public Switched Telephone Network (PSTN). The system describes mixing audio data from various participants and transmitting the combined stream to conference participants.

3. Grounds for Unpatentability

Ground 1: Obviousness over Drell, Knappe, Elliott, and VPN Textbook - Claims 8-11 are obvious over Drell in view of Knappe, Elliott, and the VPN Textbook.

  • Prior Art Relied Upon: Drell (Patent 7,089,285), Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), and “MPLS and VPN Architectures” (the VPN Textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of these references taught every element of claims 8-11.
      • Drell was used as the primary reference, disclosing a base system for multi-point videoconferencing between endpoints over a network that can include the Internet and PSTN. Drell’s system includes an audio mixing module at a near-end endpoint to combine audio from remote endpoints.
      • Knappe was argued to supplement Drell by teaching specific improvements for audio mixing and network integration. Knappe discloses using a separate mixer "summer" for each participant to generate a unique audio stream that excludes their own audio, preventing echo and feedback. Knappe also teaches using a moderator with amplified audio for higher prominence and a gateway to convert signals between PSTN and IP-based networks (VoIP).
      • Elliott was introduced to teach the use of additional collaboration data types (e.g., web browsing, application sharing per the T.120 standard) and, critically, the use of a Virtual Private Network (VPN) with IP-tunneling to secure conference communications over a public network like the Internet.
      • The VPN Textbook was cited to teach the specific implementation of the VPN suggested by Elliott. It describes the "hub-and-spoke" topology as a common, cost-effective, and less complex way to connect remote sites to a central hub, which maps directly to the ’332 patent's network architecture.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve predictable and beneficial results.
      • A POSITA would combine Drell with Knappe to improve the conferencing experience by implementing a designated moderator for better control, enhancing moderator intelligibility, and using separate audio summers to eliminate echo, all well-known problems with predictable solutions. Using a gateway, as taught by Knappe, was a standard solution for integrating disparate networks like the PSTN and Internet in Drell's system.
      • A POSITA would add Elliott's teachings to the Drell/Knappe system to enhance functionality and security. Adding collaboration data (web browsing, etc.) was a known way to improve conference effectiveness. Implementing a VPN was an obvious solution to the known security vulnerabilities of transmitting business communications over the public Internet.
      • A POSITA implementing the VPN from Elliott would consult a reference like the VPN Textbook to select a topology. The textbook's disclosure of the hub-and-spoke model as the most common and cost-effective choice would have made it an obvious design choice for the Drell system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because all references operate in the same field of multiparty conferencing. The combination involved applying conventional techniques (VPNs, gateways, audio mixing methods) to a standard conferencing system (Drell) to solve known problems, yielding only predictable results.

Ground 2: Obviousness over Drell, Knappe, Elliott, VPN Textbook, and Hoke - Claim 12 is obvious over Drell in view of Knappe, Elliott, the VPN Textbook, and Hoke.

  • Prior Art Relied Upon: Drell (Patent 7,089,285), Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), the VPN Textbook, and Hoke (Patent 6,701,437).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 to address claim 12, which adds a limitation requiring an encoder to compress the mixed data before transmission. Petitioner argued that Hoke provides the missing element of data compression within a VPN. Hoke explicitly teaches that a VPN unit can process, encrypt, and compress a data packet before transmission over a VPN tunnel. This compression corresponds to the "encoder" recited in claim 12.
    • Motivation to Combine: A POSITA, having already decided to implement a VPN based on the Drell/Knappe/Elliott/VPN Textbook combination, would have been motivated to incorporate Hoke's teachings on compression. It was well-known in the art that compressing data, especially voice data, reduces required bandwidth and improves performance over lower-speed links. Hoke explicitly recognizes this desirability by teaching the compression of data transmitted over VPN tunnels. A POSITA would therefore find it obvious to add a compression feature to the VPN routers of the combined system to gain these known benefits.
    • Expectation of Success: A POSITA would have had a high expectation of success in adding compression. Hoke itself states that many compression algorithms were well-known and that a POSITA could implement them without undue experimentation. Combining encryption (from the base VPN) and compression was a common practice. The result—more efficient data transmission over the secure VPN tunnel—was entirely predictable.

4. Relief Requested

  • Petitioner requested the Board institute an inter partes review and cancel claims 8-12 of the ’332 patent as unpatentable under 35 U.S.C. §103.