PTAB

IPR2019-00540

Cisco Systems Inc v. Meetrix IP LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Audio and Video Telecommunications
  • Brief Description: The ’332 patent relates to conferencing technology for collaboration over hybrid networks, such as the Internet and the Public Switched Telephone Network (PSTN). The system processes audio and video data from multiple participants, including mixing audio streams and transmitting them over a network.

3. Grounds for Unpatentability

Ground 1: Claims 8-11 are obvious over Drell, 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 the VPN Textbook (“MPLS and VPN Architectures,” 2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Drell, the primary reference, disclosed a base multi-participant audio/video conferencing system with a central endpoint processing data from remote endpoints over hybrid networks. To this base system, Knappe was alleged to add key features for claim 8, including a moderator, a gateway to connect PSTN clients to an IP network, and a specific audio mixing method using a plurality of summers (one per participant) to generate unique output streams and prevent a participant from hearing their own echo. Elliott was argued to add the use of a Virtual Private Network (VPN) for secure IP tunneling and the transmission of other collaboration data (e.g., web browsing, application sharing) beyond just audio and video. Finally, the VPN Textbook was asserted to teach the implementation of the VPN using a common, cost-effective hub-and-spoke topology, which corresponds to the claimed "VPN tunnel."
    • Motivation to Combine: A POSITA would combine Drell with Knappe to add desirable features like moderator control, enable hybrid PSTN/Internet conferences, and improve audio quality by using separate mixers to eliminate echo. A POSITA would further incorporate Elliott to secure the business communications in Drell's system via a VPN and to enhance the conference's utility by allowing participants to share collaboration data. Finally, when implementing the VPN taught by Elliott, a POSITA would consult a reference like the VPN Textbook and choose the common, cost-effective, and less complex hub-and-spoke topology to connect the various conference endpoints.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success, as the combination involved applying conventional and well-understood technologies (moderator functions, audio mixing techniques, PSTN gateways, VPNs) to a standard conferencing system to achieve predictable improvements in functionality, security, and usability.

Ground 2: Claim 12 is obvious over Drell, 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 (“MPLS and VPN Architectures,” 2000), and Hoke (Patent 6,701,437).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claim 12, which added the limitation of an "encoder configured to encode the mixed data into a compressed data." Petitioner argued the base combination already rendered this limitation obvious, as Drell's "audio codec" inherently performed compression. However, Petitioner additionally introduced Hoke, which explicitly taught computer systems for processing communications within a VPN. Hoke disclosed that a VPN unit serving a source end-station processes, encrypts, and compresses a data packet before transmitting it over the VPN tunnel.
    • Motivation to Combine: A POSITA implementing the secure VPN-enabled conferencing system from the primary combination would be motivated to add the compression taught by Hoke. The motivation was to achieve the well-known benefits of data compression: minimizing bandwidth utilization and improving the performance of the communication links, especially lower-speed ones. Hoke's teaching of compressing data as part of the VPN process directly addressed this known engineering challenge.
    • Expectation of Success: Petitioner argued success would be predictable. Compression algorithms were well-known at the time, and Hoke itself taught that its methods could be implemented using well-known structures without undue experimentation. Applying a known compression technique to data before transmitting it over a VPN tunnel was a conventional method for improving network efficiency.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 8-12 of the ’332 patent as unpatentable.