PTAB

IPR2019-00544

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 ’612 patent describes a system for conducting multi-participant audio and video conference calls over a hybrid network architecture. The system integrates participants connected via the public Internet, often through a Virtual Private Network (VPN), with participants connected via the Public Switched Telephone Network (PSTN).

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 19-21 and 25-27 over Knappe, Elliott, VPN Textbook, and Hendricks

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), VPN Textbook (“MPLS and VPN Architectures”), and Hendricks (WO 2001/18665A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references taught all elements of independent claim 19 and its dependents.
      • Knappe was asserted to disclose the foundational system: a multiparty conferencing architecture with a central conference bridge and call manager connecting both computer-based participants over a network (like the Internet) and telephone-based participants over the PSTN. Knappe’s system receives and mixes audio and video from various participants.
      • Elliott was introduced to supply missing features. Petitioner contended Elliott taught using a VPN with IP-tunneling to secure conference communications over a public network. Elliott also explicitly taught transmitting collaboration data (e.g., application sharing, web browsing, data compliant with the T.120 standard) to enhance conferencing.
      • The VPN Textbook was used to elaborate on the VPN technology from Elliott. It described the hub-and-spoke (or star) topology as the most common, cost-effective, and least complex method for implementing a VPN, mapping to the patent’s centralized server architecture.
      • Hendricks was cited to teach full-duplex audio in a multiparty call, allowing for more natural, simultaneous, two-way conversation. Petitioner argued this rendered the “full duplex audio” limitation of claim 19 obvious.
    • Motivation to Combine: A POSITA would combine these references for predictable benefits. A POSITA would combine Knappe and Elliott to add security (VPN) and enhanced features (collaboration data) to a known conferencing system. Upon deciding to use a VPN, a POSITA would consult a source like the VPN Textbook and select the common hub-and-spoke topology for its cost and simplicity benefits. Finally, a POSITA would incorporate full-duplex audio from Hendricks into Knappe’s system to improve the user experience by eliminating voice clipping and enabling more natural conversation, a well-known objective in telephony.
    • Expectation of Success: Petitioner asserted a high expectation of success. The combination involved applying conventional technologies (VPNs, data collaboration, full-duplex audio) to a standard conferencing framework (Knappe) to achieve their well-known and predictable functions. The use of established standards like T.120 further supported this.

Ground 2: Obviousness of Claims 22-24 and 28-29 over Knappe, Elliott, VPN Textbook, Hendricks, and Drell

  • Prior Art Relied Upon: Knappe (Patent 7,180,997), Elliott (Patent 6,690,654), VPN Textbook (“MPLS and VPN Architectures”), Hendricks (WO 2001/18665A1), and Drell (Patent 7,089,285).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 and adds Drell to address the additional limitations in claims 22-24, which relate to data compression.
      • Drell was asserted to teach a videoconferencing system that uses a standard or proprietary audio compression algorithm (e.g., H.323 codecs like G.711) to compress mixed audio data before transmission. This was argued to directly teach the limitation of “compressing the second mixed audio data” recited in claim 22. Drell also taught the corresponding decompression of the data at the receiving endpoint, mapping to the limitation in claim 23.
    • Motivation to Combine: The motivation to add Drell to the combination of the other references was to achieve a known benefit: reducing the amount of data transmitted over the network. A POSITA would recognize that compressing audio data in the Knappe system would conserve bandwidth, allowing for more efficient operation or more simultaneous calls on a given network link. Using a standard codec, as taught by Drell, would also ensure interoperability and avoid the cost of developing a proprietary solution.
    • Expectation of Success: Success would be reasonably expected because Knappe already disclosed the use of a codec (coder/decoder), and Drell demonstrated the successful application of compression algorithms in the analogous field of videoconferencing. Implementing a standard compression algorithm like H.323 into Knappe's codec was presented as a routine modification for a POSITA.

4. Relief Requested

  • Petitioner requested 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.