PTAB

IPR2020-01057

Klas Telecom Inc v. Arnouse Digital Devices Corp

Key Events

Petition

petition

Title: Mobile Data Center
Brief Description: The ’769 patent discloses a portable and mobile system described as a "deployable data center" (DDC). The system features a three-level nested structure within a rugged carrying case: multiple computing assemblies are housed in a removable rack, which is itself removably disposed within an interconnection mechanism that provides power and connectivity.

Prior Art Relied Upon: Everhart (Patent 7,843,692).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Everhart, which discloses a mobile, modular communications device in a rugged transit case, teaches most of the key elements of the challenged claims. Everhart’s system includes a carrying case, modular computing units ("personality modules"), and a chassis with a backplane that functions as the claimed "interconnection mechanism." However, Petitioner contended that Everhart does not explicitly disclose a separate "rack" that is removably disposed within the chassis and allows for the collective removal of all computing modules at once.
- Motivation to Combine (Implicit - Modification of a single reference): Petitioner asserted that a person of ordinary skill in the art (POSITA) would have found it obvious to modify Everhart’s device by incorporating a rack structure. Adding a rack to hold the personality modules would provide the known and predictable benefit of easier maintenance and collective removal of the modules, representing a simple design choice to improve functionality.
- Expectation of Success: A POSITA would have a high expectation of success in integrating a standard rack into Everhart’s chassis, as it involves combining known components for their intended purposes.

Prior Art Relied Upon: Everhart (Patent 7,843,692) and Frink (Patent 8,743,549).
Core Argument for this Ground:
- Prior Art Mapping: This ground used Everhart as the primary reference for its disclosure of a portable, modular computing system in a case. To address the "rack" limitation missing from Everhart, Petitioner cited Frink. Frink discloses a modular mass storage system and explicitly teaches using a rack, which it defines as a "frame or other element... that can contain or physically support one or more computer systems." Frink’s rack is used in conjunction with a backplane and chassis, similar to the structure of the ’769 patent.
- Motivation to Combine: Petitioner argued a POSITA seeking to improve the serviceability of Everhart's system would be motivated to look for solutions in the analogous field of modular computer systems. Frink provides a direct teaching of using a rack to organize and support computing modules for easy removal. A POSITA would combine Frink's rack with Everhart's portable system to achieve the benefit of collective module removability.
- Expectation of Success: The combination was presented as predictable, involving the application of a known technique (using a rack for modular components) to a similar system to obtain an expected result.

Prior Art Relied Upon: Everhart (Patent 7,843,692), Frink (Patent 8,743,549), and Bang-Olsen (Patent 9,609,061).
Core Argument for this Ground:
- Prior Art Mapping: This ground targets claim 11, which adds the limitation that the "carrying case further comprises wheels." Petitioner relied on the combination of Everhart and Frink to teach all other elements of claim 1, as established in Ground 2. Bang-Olsen, which discloses a rugged, "carry-on portable, rugged, protective and mobile case" for a media server, was cited for its express teaching that the case is "provided with rollers" to enhance portability.
- Motivation to Combine: A POSITA would combine the teachings of Bang-Olsen with the portable data center of Everhart and Frink for the simple and common-sense reason of making a heavy, portable electronic device easier to transport. Adding wheels to a ruggedized case is a well-known and obvious design choice to improve mobility.
- Expectation of Success: There would be a clear expectation of success in attaching wheels to a carrying case, a simple mechanical modification.

"Rack": Petitioner proposed construing "rack" as "a structural frame that can contain or physically support one or more computer systems." This construction was central to its argument, as it distinguished the claimed "rack" as a separate component from the chassis/interconnection mechanism taught by Everhart, thereby creating the key structural difference that Frink was cited to resolve.
"Deployable Data Center": While arguing the term is a non-limiting preamble, Petitioner proposed that if construction were required, it should mean "a portable case including one or more removable computing devices."

Priority Date Challenge: Petitioner dedicated significant argument to establishing that the challenged claims were not entitled to the priority date of the parent applications. It contended that the key "three-level nesting structure," specifically the inclusion of a rack removably disposed within an interconnection mechanism, was new matter added in the application filed on March 13, 2015. This argument was critical to establishing Bang-Olsen, filed in 2014, as valid prior art against the claims under 35 U.S.C. §102(a)(2).

Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 5-8, 11, 15, 16, 31, 33, 34, and 36 of the ’769 patent as unpatentable.