PTAB

IPR2019-01530

LG Electronics Inc v. Uniloc 2017 LLC

Key Events

Petition

Title: COMMUNICATION SYSTEM
Brief Description: The ’049 patent describes a wireless communication system, such as Bluetooth, for connecting Human/Machine Interface Devices (HIDs) to a network. The invention addresses problems of connection delay and power consumption by proposing that a master station “piggy-back” an additional data field onto its standard inquiry messages to poll specific HIDs at regular intervals.

Prior Art Relied Upon: Larsson (Patent 6,704,293).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Larsson, which discloses a route discovery technique in a Bluetooth ad-hoc network, teaches all limitations of the challenged claims. Larsson’s source node (a primary station) broadcasts “request for route” messages, which Petitioner asserted are equivalent to the claimed "inquiry messages." When the source node expects a reply, it "piggybacks" a broadcast message onto the request for route message; Petitioner contended this teaches the claimed step of "adding to an inquiry message... an additional data field for polling." A destination node (secondary station) that receives this piggybacked data determines it is the intended recipient and generates a response, thereby meeting the claim limitation of a polled station responding when it has data for transmission.
- Motivation to Combine (for §103 grounds): This ground was asserted based on a single reference.
- Expectation of Success (for §103 grounds): This ground was asserted based on a single reference.

Prior Art Relied Upon: Larsson (Patent 6,704,293) and BT Core (Specification of the Bluetooth System: Core, Vol. 1, Dec. 1, 1999).
Core Argument for this Ground:
- Prior Art Mapping: This ground was presented as an additive combination to Ground 1. Petitioner argued that to the extent Larsson is found deficient, BT Core supplies the missing details. BT Core, as the official Bluetooth specification, explicitly describes the standard packet structures, including predetermined data fields (access code, header, payload) that a POSITA would have used to implement Larsson’s system. Furthermore, BT Core describes a specific "POLL packet" used by a master to compel a response from a slave, which Petitioner argued makes the "polling" function of Larsson's piggybacked message explicit.
- Motivation to Combine (for §103 grounds): Petitioner asserted a POSITA implementing the Bluetooth-based ad-hoc network described in Larsson would have been motivated to consult the BT Core specification. This would be a natural step to ensure the system complied with the Bluetooth standard and to use known, standard techniques for functions like polling, thereby yielding predictable results and improving network efficiency.
- Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in combining the teachings, as it involved implementing a system (Larsson) using the foundational technical standard (BT Core) on which it is based.

Prior Art Relied Upon: IrOBEX (IrDA Object Exchange Protocol, a 1999 technical publication).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the IrOBEX protocol, which defines a request-response paradigm for device communication, renders the claims obvious. The "OBEX CONNECT" packet, used to initiate a connection and request capability information, was equated to the claimed "inquiry message." The IrOBEX protocol teaches optionally adding a "target header" to this packet to direct it to a specific device, application, or service; Petitioner mapped this optional header to the "additional data field for polling." A receiving device that matches the information in the target header sends a response, while a non-matching device does not. This was argued to teach the final limitations of a polled station determining it has been polled and responding accordingly. Petitioner also noted that since the target header is optional, not all "inquiry messages" in an IrOBEX system would have the polling field, thus satisfying claim 12.
- Motivation to Combine (for §103 grounds): This ground was asserted based on a single reference.
- Expectation of Success (for §103 grounds): This ground was asserted based on a single reference.

Term: “inquiry message[s]”
Petitioner’s Proposed Construction: “a message seeking information or knowledge.”
Rationale: Petitioner argued this construction aligns with the broadest reasonable interpretation standard. The argument was supported by the ’049 patent’s own description of Bluetooth inquiry procedures, which are used by a device to find a base station and seek information needed to connect. Critically, Petitioner noted that the PTAB had previously adopted this exact construction for the same term during the prosecution of a related patent (’207 patent) from the same family with a common inventor and similar disclosures.

Petitioner requests institution of an inter partes review and cancellation of claims 11 and 12 of Patent 6,993,049 as unpatentable under 35 U.S.C. §103.