PTAB

IPR2021-00964

Sonos Inc v. Google LLC

Title: Relaying Communications in a Wireless Sensor System
Brief Description: The ’586 patent specification discloses a wireless residential fire and security alarm system comprising sensors, repeaters, and a central base station. However, the challenged claims are directed more broadly to "audio-enabled wireless devices" configured for bidirectional communication in a "wireless mesh network," which relay communication packets to one another based on address information.

Prior Art Relied Upon: Baker (Application # 2006/0120433) and Bruckert (EP 0 416 732 B1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Baker disclosed all elements of the independent claims except for an explicit "reset element." Baker taught a wireless mesh network of audio-enabled consumer electronic devices (e.g., TVs, audio systems) that use transceivers and controllers to relay data packets between nodes using local routing tables. To supply the missing element, Petitioner asserted that Bruckert taught that a reset capability is a necessary and standard feature for "all data processing systems" to handle initialization, power-up, and error recovery.
- Motivation to Combine: A POSITA would combine Bruckert’s standard reset functionality with Baker’s network devices to ensure reliable operation. Because Baker's devices are data processing systems, incorporating a standard reset function to handle errors or power cycling would have been an obvious and beneficial modification to improve system robustness.
- Expectation of Success: A POSITA would have a high expectation of success, as incorporating a well-known reset function (e.g., via a switch or software command) into a consumer electronic device was a routine and predictable engineering task.

Prior Art Relied Upon: Baker (Application # 2006/0120433), Bruckert (EP 0 416 732 B1), and McMillin (Patent 7,027,773).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the combination in Ground 1. Petitioner argued that McMillin taught the collision avoidance techniques recited in the dependent claims. Specifically, McMillin disclosed a wireless network where nodes "listen" to a frequency to check if it is in use before transmitting. If a collision is detected, transmission is delayed by a "randomly selected amount of time." McMillin also taught using a "gateway device" to connect the network to the Internet, as required by claims 7 and 16.
- Motivation to Combine: The network in Baker, having multiple independent transmitters, is inherently susceptible to message collisions—a problem McMillin was explicitly designed to solve. A POSITA would combine McMillin's collision avoidance techniques with Baker's network to reduce data corruption and improve overall network efficiency and reliability. The motivation to add Internet connectivity is to expand the system's functionality, a common design goal.
- Expectation of Success: Success would be expected because applying standard collision avoidance protocols like "listen-before-talk" and random backoff delays to a packet-based wireless network was a conventional and well-understood practice.

Prior Art Relied Upon: Marman (WO 00/21053A1) and Shoemake (Application # 2002/0122413).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Marman, like the ’586 patent’s specification, taught a wireless fire/security system with audio-enabled sensors (containing "sounders") that function as nodes in an "interactive multi-path loop system" (i.e., a mesh network). These sensors used routing tables to relay messages. Petitioner argued Marman taught every claim limitation except for the specific packet structure. Shoemake was introduced to teach a standard wireless packet structure (based on IEEE 802.11) that included a preamble, header (with source/destination addresses), payload, and checksum, aligning with the claimed packet portions.
- Motivation to Combine: A POSITA implementing Marman's packet-based communication system would be motivated to use a standard, off-the-shelf packet format like that described in Shoemake. Using a standard format would ensure interoperability, reduce development time, and leverage known, reliable technology, making it an obvious design choice over creating a proprietary format.
- Expectation of Success: There would be a high expectation of success in using a standard packet structure from Shoemake to implement the packet communications in Marman's network, as this was a routine and fundamental aspect of wireless network design.

"wireless mesh network" (preamble term): Petitioner argued the preamble term is non-limiting because the claim body defines a structurally complete invention without it. Alternatively, if deemed limiting, Petitioner contended the prior art discloses networks meeting both its own proposed construction and the Patent Owner's construction from a related district court case.
"reset element": Petitioner proposed a broad construction: "an element that functions to place the controller in a prescribed state." It argued this covers hardware (a switch) or software-initiated resets, both of which are taught by the prior art. This contrasted with the Patent Owner's allegedly narrower construction requiring a hardware element that resets the device's configuration.
"preamble portion": Petitioner contended this term had a well-understood meaning to a POSITA as a sequence of bits used to initiate and synchronize a receiving device, as taught by the prior art.

§314(a) (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court proceeding was in its early stages, with no trial date set and minimal investment by the court and parties. Petitioner emphasized that the IPR would be more efficient, as a final written decision (FWD) would likely issue before any potential trial.
§325(d): Petitioner argued denial under §325(d) would be inappropriate because the petition raised new arguments with prior art not considered during prosecution. The primary references (Baker, Bruckert, Shoemake) were never before the Examiner. Furthermore, while Marman was related to a reference of record, it was never substantively applied, which Petitioner characterized as an Examiner error, especially since the same Examiner had previously used the reference to reject similar claims in a related application.

Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-5, 7-12, 14-16, 18, and 20 of the ’586 patent as unpatentable.