PTAB

IPR2019-00542

Cisco Systems, Inc. v. Meetrix IP, LLC

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1. Case Identification

2. Patent Overview

  • Title: Audio and Video Telecommunications for Collaboration Over Hybrid Networks
  • Brief Description: The ’525 patent describes conferencing technology for collaboration over hybrid networks. The system mixes audio and video data from multiple participants, including those on the Internet and the Public Switched Telephone Network (PSTN), and transmits the mixed data to conference participants.

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 discloses a base multi-party videoconferencing system where a software-based "near conference endpoint" connects participants over hybrid networks (e.g., Internet and PSTN). This endpoint receives, processes, and mixes audio and video streams from multiple remote endpoints. Knappe was asserted to teach key features missing from Drell, including: (1) designating a participant as a "moderator" with control over the conference; (2) using a gateway to connect standard analog telephones from the PSTN; and (3) a more advanced audio mixing technique where each participant receives a mixed stream that excludes their own audio, a common method to prevent echo and feedback.
    • Motivation to Combine: A POSITA would combine Knappe's features into Drell's system to achieve predictable improvements. Adding a moderator role from Knappe would provide better conference organization and control. Implementing Knappe’s audio mixing method would solve the well-known problem of audio feedback in conferencing systems. Incorporating Knappe's gateway and associated protocols (like RTP) would expand Drell's system to more robustly and effectively integrate PSTN users, thereby enhancing its hybrid-network capabilities.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination. Both references address the same technical field of multiparty conferencing, and the proposed integrations involve applying known solutions (moderator control, echo cancellation, gateway integration) to achieve well-understood and predictable benefits in performance and usability.

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 adds the teachings of Elliott to the Drell/Knappe combination. Elliott discloses advanced conferencing features, including the use of a Virtual Private Network (VPN) with "IP-tunneling" for secure transmission and the sharing of more varied "collaboration data," such as collaborative web browsing and application sharing. Petitioner asserted that Elliott’s teachings supply elements of the challenged claims in a different manner than Ground 1. For example, Elliott’s teaching of VPN-based encryption provides an alternative basis for the "encoding" limitations in claims 15-16, while its teaching of app/web sharing provides a more robust basis for the "collaboration data" limitation in claim 9 than Drell's disclosure of "still images."
    • Motivation to Combine: A POSITA would be motivated to integrate Elliott's teachings to enhance the security and functionality of the Drell/Knappe system. Implementing a VPN as taught by Elliott was a conventional method to secure business communications over the public Internet, which Drell's system utilizes. This would protect conference data from eavesdropping and reduce the costs associated with private data lines. Adding Elliott's broader types of collaboration data would allow conference participants to share information more effectively, improving the overall collaborative experience.
    • Expectation of Success: The combination was predictable and would have been successful. Using VPNs to secure Internet traffic and adding various data sharing tools were conventional, widely adopted practices in network communications and conferencing systems at the time.
    • Key Aspects: Petitioner contended this ground is not redundant because it offers alternative invalidity theories. It relies on different prior art teachings for key limitations like "collaboration data" (Elliott's app sharing vs. Drell's still images) and "encoding" (Elliott's VPN encryption vs. Knappe's packet encapsulation), providing a distinct basis for unpatentability.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because the two grounds presented are not redundant. It asserted that Ground 2 provides distinct prior art teachings for key claim limitations, thereby justifying the presentation of multiple challenges to address potential arguments from the Patent Owner concerning the scope of the claims or the teachings of the prior art in Ground 1.

5. 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.