PTAB

IPR2019-00541

Cisco Systems, Inc. v. Meetrix IP, LLC

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1. Case Identification

2. Patent Overview

  • Title: Conferencing Over Hybrid Networks
  • Brief Description: The ’525 patent relates to technology for multi-participant teleconferencing over hybrid networks, such as the Internet and a Public Switched Telephone Network (PSTN). The invention describes a system that receives audio and video data from participants, mixes the data into customized streams for each participant, and transmits the mixed streams back to the respective 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 asserted that Drell taught a base multiparty videoconferencing system connecting endpoints over hybrid networks (Internet and PSTN) and included modules for mixing audio and video. Knappe was argued to supply key missing features, including assigning a "moderator" role for conference control, using individualized audio "summers" to combine streams while excluding a participant's own audio to prevent echo, and employing a gateway for protocol conversion between PSTN and IP networks. Finally, Voois was argued to teach a PSTN-based videophone, making it obvious to implement the PSTN client in the combined Drell/Knappe system as a device capable of both audio and video communication, as required by the claims.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Drell with Knappe to improve the base system with desirable features like moderator control, enhanced audio quality (by avoiding echo), and seamless integration of PSTN and Internet users. A POSITA would further incorporate Voois's videophone into the combined Drell/Knappe system to allow PSTN users to participate fully with both audio and video, thereby enhancing collaboration and providing a consistent user experience across different network types.
    • Expectation of Success: Petitioner argued success was highly predictable because the references all operate in the same field of conferencing technology. The proposed modifications involved combining known elements for their established functions (e.g., using a gateway for protocol conversion, using a videophone for video calls over a phone network) to achieve predictable improvements in a conferencing system.

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,” 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address limitations in dependent claims 5-8 related to secure transport. Petitioner argued that Elliott taught the use of a virtual private network (VPN) with IP-tunneling to provide secure multi-media collaboration. The VPN Textbook was argued to disclose various VPN topologies, noting that the "hub-and-spoke" topology was the most common, cost-effective, and analogous to the ’525 patent’s claimed "star" topology. Together, these references were argued to teach transporting the conference data streams across a secure VPN tunnel, as claimed.
    • Motivation to Combine: A POSITA implementing the conferencing system of Drell/Knappe/Voois would recognize the security vulnerabilities of transmitting business communications over the public Internet. This would provide a strong motivation to incorporate the VPN and IP-tunneling techniques taught by Elliott to secure the data. The POSITA would then consult a resource like the VPN Textbook to select a standard, cost-effective implementation, making the hub-and-spoke topology an obvious choice.
    • Expectation of Success: Petitioner contended that success was expected because combining conferencing systems with VPNs was a conventional practice to enhance security. Implementing a standard hub-and-spoke VPN topology using commercially available hardware and software would have been a straightforward task for a POSITA, leading to the predictable result of secure conference communications.
  • Additional Grounds: Petitioner asserted alternative obviousness challenges for claims 1-4 over Drell and Knappe, and for claims 5-8 over Drell, Knappe, Elliott, and the VPN Textbook. These grounds were presented as contingent on a potential claim construction of "second mixed data stream" that does not require the inclusion of video data.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the term "mixed data stream," proposing it means "a data stream including at least audio data and video data." This construction was asserted to be critical to the primary invalidity arguments. Petitioner contended this meaning is required by the plain language of claim 1, which separately recites a "mixed audio data stream," implying that a "mixed data stream" must be different and therefore contain more than just audio. This interpretation was also argued to be consistent with the ’525 patent's specification, which describes mixing both audio and video data.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review of claims 1-8 of Patent 9,094,525 and the cancellation of those claims as unpatentable under 35 U.S.C. §103.