PTAB

IPR2020-01057

Klas Telecom Inc v. Arnouse Digital Devices Corp

Title: MOBILE DATA CENTER
Brief Description: The ’769 patent describes a portable and mobile deployable data center (DDC). The system features a three-level nested architecture comprising a plurality of computing assemblies removably disposed within a rack, which is in turn removably disposed within an interconnection mechanism, all housed within a rugged carrying case.

Prior Art Relied Upon: Everhart (Patent 7,843,692).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Everhart disclosed most elements of the challenged claims, including a mobile modular communications device housed in a rugged transit case. Everhart’s system included multi-slot chassis units (the claimed "interconnection mechanism"), a DC power backplane, and individual, removable "personality modules" (the claimed "computing assemblies"). However, Petitioner contended Everhart did not explicitly disclose a "rack" structure separate from its chassis for the collective removal of the modules.
- Motivation to Combine: This ground asserted an obvious modification rather than a combination. A person of ordinary skill in the art (POSITA) would have been motivated to modify Everhart’s system by adding a separate rack structure. The motivation was to improve serviceability and ease of use by enabling the collective removal of all computing modules at once, a known and predictable design choice for modular systems.
- Expectation of Success: A POSITA would have a reasonable expectation of success in incorporating a rack, as it represented a simple and well-understood mechanical modification to group existing modules within a chassis, a common practice in the field of modular electronics.

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 the overall portable system (case, interconnection mechanism, modules) and supplemented it with Frink to explicitly teach the "rack" limitation missing from Everhart. Petitioner asserted that Frink disclosed a modular data storage system that expressly taught using a "rack" to contain computing components within a larger chassis, including its definition as a "structural frame that can contain or physically support one or more computer systems."
- Motivation to Combine: A POSITA would combine Everhart's mobile system with Frink's rack concept to achieve the known benefit of improved modularity and serviceability. The combination would allow for the convenient, collective removal of the computing assemblies from the chassis, an advantage inherent in the rack-based design taught by Frink.
- Expectation of Success: A POSITA would have expected success in combining the references because both relate to modular computer systems. Integrating a known rack structure (from Frink) into a modular chassis (from Everhart) was a predictable and straightforward design choice to enhance functionality.

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 built upon the combination of Everhart and Frink from Ground 2 to establish the base mobile data center recited in claim 1. It then added Bang-Olsen to teach the additional limitation of claim 11: a carrying case that "further comprises wheels." Petitioner argued that Bang-Olsen, which disclosed a rugged, mobile media server in a "carry-on portable, rugged, protective and mobile case," explicitly taught providing the case with rollers (wheels).
- Motivation to Combine: The motivation was to address the common-sense problem of transporting a potentially heavy portable electronics case. A POSITA would have been motivated to add the wheels taught by Bang-Olsen to the portable case of the Everhart/Frink system to make it more easily transportable, a simple and predictable improvement.
- Expectation of Success: There would have been a high expectation of success, as adding wheels to a portable case is a simple, common, and well-understood mechanical modification that does not affect the electronic functionality of the system.

"Deployable Data Center": Petitioner argued this preamble term was not limiting. However, if construction were required, it should mean "a portable case including one or more removable computing devices," based on the understanding of a POSITA.
"Rack": Petitioner contended that for the challenged claims, this term should be construed as "a structural frame that can contain or physically support one or more computer systems." This construction, based in part on the disclosure of Frink, was crucial to distinguish the claimed invention from Everhart’s integrated chassis and to support the obviousness arguments.
"Reader Functionality": Petitioner proposed this term should be understood broadly as "the function of obtaining data for the computing assembly," arguing it was not explicitly defined but could be interpreted from the patent's context.

Priority Date Challenge: A central argument of the petition was that the ’769 patent was not entitled to its claimed priority date of April 10, 2012. Petitioner asserted that the earlier-filed applications failed to provide written description support for the claimed three-level nested structure including a separate "rack." It was argued that this structure was first disclosed in the application filed on March 13, 2015. This later effective filing date was critical for establishing Bang-Olsen (filed in 2014) as prior art against the ’769 patent under 35 U.S.C. §102.

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