STAyLinked Corp v. Ivanti Inc

1. Case Identification

• Case #: IPR2021-01366
• Patent #: 9,648,083
• Filed: August 10, 2021
• Petitioner(s): StayLinked Corporation
• Patent Owner(s): Ivanti, Inc.
• Challenged Claims: 1-13 and 15-16

2. Patent Overview

• Title: Data Entry on a Terminal-Emulation Device
• Brief Description: The ’083 patent describes a method for data entry on a terminal-emulation client communicating with a host application. The method uses one or more scripts running on the client to associate data identifiers with specific input fields, allowing for processed input data (e.g., from a barcode scanner) to be automatically inserted into the correct field.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 8-13 are obvious over Wavelink Scripting Guide in view of Teklogix.

• Prior Art Relied Upon: Wavelink Scripting Guide (a client scripting reference guide) and Teklogix (a wireless gateway user manual).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wavelink Scripting Guide taught all elements of the independent claims except for associating data identifiers with specific input fields to auto-populate data. Wavelink disclosed a Telnet client that runs scripts to automate processes, receive data from a host, and detect input fields. Teklogix, however, explicitly taught an "auto-locate and fill" feature for barcode data. This feature used an "AIAG" parameter, which served as a data identifier (e.g., a prefix or tag) associated with a particular input field. When barcode data was entered, the terminal would search for an input field with a matching AIAG identifier and automatically populate the data.
  • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine the teachings to improve the functionality of the Wavelink Telnet client. Teklogix's auto-locate-and-fill feature was a known solution to the common problems of slow manual data entry and input errors. A POSITA would have been motivated to implement this known feature on the similar Wavelink client using Wavelink’s own disclosed scripting capabilities to achieve the predictable benefits of faster and more accurate data entry.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying a known technique (scripting, as taught by Wavelink) to implement a known feature (auto-locate-and-fill, as taught by Teklogix) on a similar terminal emulation device to achieve a predictable result.

Ground 3: Claims 1-3 and 8-13 are obvious over Wavelink Scripting Guide in view of Field Data ID.

• Prior Art Relied Upon: Wavelink Scripting Guide (a client scripting reference guide) and Field Data ID (a Wavelink white paper).

• Core Argument for this Ground:

  • Prior Art Mapping: As in Ground 1, Petitioner asserted that Wavelink Scripting Guide served as the base reference. The missing element—associating a data identifier with an input field for automatic data population—was allegedly supplied by Field Data ID. This white paper, also from Wavelink, described a feature that used scripting to "assign a unique ID, such as a letter, to each field on the screen." When a barcode beginning with that specific ID was scanned, the system automatically populated the information into the corresponding field. Petitioner argued this directly taught the client-side association of a data identifier with an input field as claimed.
  • Motivation to Combine: The motivation was particularly strong as both references were from the same entity (Wavelink) and related to the same product (the Wavelink Telnet Client). Field Data ID described a feature for a later version of the software. A POSITA would have been motivated to use scripting, as taught in both references, to implement the Field Data ID feature to improve the client’s functionality, making data entry easier and reducing errors by ensuring scanned data went to the correct field without manual cursor placement.
  • Expectation of Success: Success would have been predictable because the combination merely involved implementing an improved feature from the same product family using the established scripting methods taught by the primary reference.

• Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 2 and 4) that added McNair (Application # 2005/0010418) to the combinations of Ground 1 and Ground 3, respectively. McNair was used to teach the limitations of dependent claims related to voice commands, converting speech to text, and generating speech, arguing it would have been obvious to add these known voice-enablement features to the terminal client.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) or §325(d). It contended that a prior petition (IPR2021-00022) was dismissed at Petitioner's request before the Board considered its merits, and that this petition contained substantial new evidence regarding the public accessibility of the prior art. Petitioner also argued that the co-pending district court litigation was in its early stages, with no trial date set, such that an inter partes review (IPR) would be more efficient than duplicative efforts in court.

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-13 and 15-16 of Patent 9,648,083 as unpatentable.