PTAB

IPR2019-00544

Cisco Systems Inc v. Meetrix IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Audio and Video Telecommunications for Collaboration Over Hybrid Networks
  • Brief Description: The ’612 patent discloses technology for voice and video conferencing over hybrid networks that include both packet-switched networks like the Internet and circuit-switched networks like the Public Switched Telephone Network (PSTN). The system uses a central server or bridge to manage communications between various clients.

3. Grounds for Unpatentability

Ground 1: Obviousness over Knappe, Elliott, VPN Textbook, and Hendricks - Claims 19-21 and 25-27 are obvious over Knappe in view of Elliott, the VPN Textbook, and Hendricks.

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), "MPLS and VPN Architectures" (the "VPN Textbook"), and Hendricks (WO 01/18665A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the primary reference, Knappe, disclosed the foundational system for multiparty conferencing with a central conference bridge connecting participants over both the Internet and the PSTN. This conference bridge functions as the claimed "server."
      • Elliott was argued to supplement Knappe by teaching the use of multi-media collaboration services (including sharing web browsing and application data per the T.120 standard) and securing these communications over the public Internet using a "virtual private network (VPN)... IP-tunneling."
      • The VPN Textbook was cited to teach that a "hub-and-spoke" topology is the most common and cost-effective implementation for a VPN, which corresponds to the claimed "VPN tunnel" connecting remote clients to a central server.
      • Hendricks was introduced to teach providing "full duplex calls" and "full duplex interconnectivity" in a multimedia conference, satisfying the "full duplex audio" limitation.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references to achieve predictable and beneficial results. A POSITA would add Elliott's security and collaboration features to Knappe's base system to enhance its functionality and security, which were known issues with Internet communications. When implementing the VPN taught by Elliott, a POSITA would consult a standard reference like the VPN Textbook and select the common, cost-effective hub-and-spoke topology. Finally, a POSITA would incorporate Hendricks' teaching of full-duplex audio to improve Knappe's system, as full-duplex communication was known to provide a more natural and desirable user experience.
    • Expectation of Success: Petitioner contended that a POSITA would have a high expectation of success because the combination involved applying conventional technologies (VPNs, T.120 data, full-duplex audio) to a known conferencing framework (Knappe). The technologies were from analogous fields, and their integration was a matter of routine engineering using known techniques to achieve predictable improvements in security, functionality, and audio quality.

Ground 2: Obviousness over Knappe, Elliott, VPN Textbook, Hendricks, and Drell - Claims 22-24 and 28-29 are obvious over Knappe in view of Elliott, the VPN Textbook, Hendricks, and Drell.

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), the VPN Textbook, Hendricks (WO 01/18665A1), and Drell (Patent 7,089,285).
  • Core Argument for this Ground: This ground builds upon the combination asserted in Ground 1 and adds the teachings of Drell to address limitations in the remaining challenged claims related to audio compression and decompression.
    • Prior Art Mapping: Drell was argued to teach a videoconferencing system that uses an audio codec to compress mixed audio data before transmission and decompress it upon receipt at a remote endpoint. Drell specifically disclosed using a "standard or proprietary audio compression algorithm" as part of a packet-based process (e.g., H.323), which corresponds to the claimed steps of "compressing the... mixed audio data" using a "standard audio codec" and "decompressing the compressed digital audio data."
    • Motivation to Combine (for §103 grounds): Petitioner argued a POSITA would have been motivated to incorporate Drell's teachings of audio compression into the system of Knappe (as modified by the other references). The motivation was to gain the well-known and significant benefit of reducing the amount of data transmitted over the network. This reduction in bandwidth usage was a known objective in the art, as it allows for more efficient use of network resources and supports more concurrent calls on links with limited capacity.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in this combination. Knappe already disclosed the use of a codec, and Drell demonstrated the successful application of compression algorithms in the analogous context of conferencing systems. Implementing a standard compression codec (such as G.711 or G.729 from the H.323 standard, as taught by Drell) would be a straightforward and predictable modification for a skilled artisan.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 19-29 of Patent 9,843,612 as unpatentable under 35 U.S.C. §103.