PTAB

IPR2019-00542

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 for collaboration
  • 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 each participant with data from other participants and transmitting the combined stream back to the conference members.

3. Grounds for Unpatentability

Ground 1: Obviousness over Drell and Knappe - Claims 9-12 and 15-16 are obvious over Drell in view of Knappe.

  • Prior Art Relied Upon: Drell (Patent 7,089,285) and Knappe (Patent 7,180,997).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Drell taught the core of the claimed invention: a multi-party videoconferencing system operating over hybrid networks where a software-based application at one endpoint mixes audio and video streams from remote endpoints. This local mixing avoids the expense of a traditional multi-point control unit (MCU). Knappe was argued to supply the remaining limitations, teaching a multiparty conferencing system that includes a designated "moderator" to control the conference, a gateway to convert between PSTN signals and VoIP packets for participants on standard telephones, and an audio mixing technique where each participant receives audio from others but not their own to prevent echo.
    • Motivation to Combine: A POSITA would combine Drell and Knappe because they address the same field of multiparty conferencing. The specific motivations included: (1) adding Knappe's moderator functionality to Drell’s system to provide desirable conference control; (2) incorporating Knappe’s gateway to allow standard telephone users to join Drell's internet-based conference; (3) using Knappe’s audio mixing technique to prevent echo and feedback in Drell’s system; and (4) encapsulating audio in VoIP and Real-time Transport Protocol (RTP) packets as taught by Knappe, which was a standard method for real-time applications compatible with Drell’s disclosed H.323 protocol.
    • Expectation of Success: Petitioner asserted a high expectation of success because the references describe analogous conferencing systems and the proposed modifications involved combining conventional and well-understood technologies (e.g., moderators, gateways, VoIP) to achieve predictable improvements in functionality and quality.

Ground 2: Obviousness over Drell, Knappe, and Elliott - Claims 9-16 are obvious over Drell in view of Knappe and Elliott.

  • Prior Art Relied Upon: Drell (Patent 7,089,285), Knappe (Patent 7,180,997), and Elliott (Patent 6,690,654).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Drell and Knappe by adding the teachings of Elliott. Petitioner argued that Elliott disclosed key features missing from the primary combination, namely the use of a Virtual Private Network (VPN) with IP-tunneling for secure transmissions and the sharing of richer forms of "collaboration data," such as collaborative web browsing and application sharing, consistent with the T.120 standard. For claims requiring transmission through a VPN (claims 13-14) or an "encoding" step (claims 15-16), Elliott’s disclosure of encryption via VPN tunneling was argued to render these limitations obvious. For claims requiring transmission of "collaboration data" (claim 9), Elliott’s teaching of sharing web browsing and application data was presented as a more robust teaching than Drell's disclosure of "still images" relied upon in Ground 1.
    • Motivation to Combine: A POSITA would combine Elliott’s teachings with the Drell/Knappe system to solve known problems and enhance functionality. The primary motivations were to (1) add security to communications over the public internet, a known vulnerability of systems like Drell's, by implementing the well-known solution of a VPN as taught by Elliott; and (2) improve the conferencing experience by incorporating Elliott's advanced collaboration tools, allowing participants to share more than just audio and video.
    • Expectation of Success: Petitioner contended the combination would have yielded predictable results. Using a VPN to secure internet traffic was a conventional and widely adopted practice. Similarly, adding more data sharing capabilities was a known method for improving the effectiveness of collaboration systems.
    • Key Aspects: Petitioner explicitly argued this ground was not redundant to Ground 1 because it provided alternative and distinct prior art teachings for key claim limitations. Specifically, it relied on Elliott for VPN encryption as the "encoding" step and for multi-media services as the "collaboration data," in contrast to Ground 1's reliance on IP/RTP encapsulation and still images for the same respective limitations.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 9-16 of the ’525 patent as unpatentable under 35 U.S.C. §103.