PTAB

IPR2019-00541

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 ’525 patent describes conferencing technology for collaboration over hybrid networks, such as the Internet and a Public Switched Telephone Network (PSTN). The system involves mixing audio and video data from multiple participants and transmitting the mixed streams back to the conference participants.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 are obvious over Drell, Knappe, and Voois.

  • Prior Art Relied Upon: Drell (Patent 7,089,285), Knappe (Patent 7,180,997), and Voois (Patent 6,215,515).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Drell disclosed the foundational multi-participant videoconferencing system operating over hybrid networks (Internet and PSTN), including an audio/video mixing module. Knappe was argued to supplement Drell by teaching key features for managing such a conference, including designating a "moderator" for control, using a "gateway" for protocol conversion between the PSTN and Internet, and employing individualized audio mixers ("summers") for each participant to prevent echo and enhance moderator intelligibility. Finally, Petitioner asserted that Voois taught a PSTN-based "videophone," making it obvious to upgrade Drell's PSTN endpoint to a device capable of both sending and receiving video, not just audio.
    • Motivation to Combine: A POSITA would combine Drell and Knappe to improve the functionality and quality of Drell's conferencing system by adding well-known conference control features (moderator), solving common technical problems (echo), and enabling seamless operation across different network types (gateway). A POSITA would then incorporate Voois's teachings to provide a richer, more effective collaborative experience for PSTN participants by enabling them to engage with video, which was a known benefit of videoconferencing.
    • Expectation of Success: Petitioner contended there was a high expectation of success because all references pertained to the same field of multiparty conferencing. The proposed modifications involved applying conventional techniques (e.g., gateways, individual audio mixing) to a known system architecture to achieve predictable improvements.

Ground 2: Claims 5-8 are obvious over Drell, Knappe, Voois, Elliott, and the VPN Textbook.

  • Prior Art Relied Upon: Drell (Patent 7,089,285), Knappe (Patent 7,180,997), Voois (Patent 6,215,515), Elliott (Patent 6,690,654), and the VPN Textbook ("MPLS and VPN Architectures," Guichard et al., 2001).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the limitations of claims 5-8, which explicitly recite transporting data streams across a "virtual private network tunnel." Petitioner argued that Elliott taught the use of a virtual private network (VPN) with "IP-tunneling" to securely transmit multimedia collaboration data (voice, video, etc.) over the Internet. The VPN Textbook was cited for teaching that the most common, cost-effective, and least complex VPN topology was a "hub-and-spoke" configuration, which is analogous to the "star" topology described in the ’525 patent.
    • Motivation to Combine: A POSITA implementing the conferencing system of Drell/Knappe/Voois over a public network like the Internet would have been motivated to add security, a known concern. Elliott provided the solution by teaching the use of VPN tunneling for this exact purpose. The POSITA would have then consulted a standard reference like the VPN Textbook to implement this solution using the most conventional and practical topology (hub-and-spoke) to constrain cost and complexity.
    • Expectation of Success: Petitioner argued success would be expected because securing communications over public networks was a common problem with a well-known solution (VPNs). Combining conferencing systems with VPN technology was conventional at the time, and the components for implementing a hub-and-spoke VPN were commercially available and widely understood.

  • Additional Grounds: Petitioner asserted alternative obviousness challenges in Grounds 3 (over Drell and Knappe) and 4 (over Drell, Knappe, Elliott, and the VPN Textbook). These grounds were contingent on the Patent Owner arguing that the term "second mixed data stream" requires only audio, not audio and video, and relied on the same combinations as Grounds 1 and 2 but for an audio-only PSTN client.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the term "mixed data stream" as "a data stream including at least audio data and video data." This construction was asserted to be critical because it is supported by the claim language, which distinguishes between a "mixed data stream" and a "mixed audio data stream" or "mixed voice data." Petitioner contended this interpretation was necessary to give separate meaning to different terms and was consistent with the patent's specification, which describes mixing both audio and video. The contingent nature of Grounds 3 and 4 was based on a potential rejection of this construction.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-8 of the ’525 patent as unpatentable under 35 U.S.C. §103.