PTAB

IPR2022-00001

Gen Digital Inc v. Kajeet Inc

Title: Feature Management of a Communication Device
Brief Description: The ’559 patent discloses systems and methods for real-time management of a communication device, such as a mobile phone, by establishing and enforcing policies stored on a server. The system uses a distributed architecture where a device sends a request to a server, the server makes a decision based on stored policies, and the device enforces that decision.

Prior Art Relied Upon: Putzolu (Patent 6,578,076).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Putzolu teaches a policy-based network management system that is directly analogous to the architecture of the ’559 patent. Putzolu’s “policy server” stores policies and makes access decisions, while its “policy clients” (e.g., routers, firewalls) enforce these decisions. Petitioner contended this maps directly to independent claims 1 and 27, which require a computing device to send a request to a server, receive a decision based on policies stored at the server, and enforce that decision without locally accessing the policies. The policy client in Putzolu offloads policy interpretation to the server, mirroring the claimed invention’s core functionality.
- Motivation to Combine: Not applicable (single reference).
- Expectation of Success: Not applicable (single reference).
- Key Aspects: Petitioner emphasized that Putzolu’s disclosure of a distributed architecture where a client "outsources" decisions to a server renders the central concept of the challenged independent claims obvious.

Prior Art Relied Upon: Putzolu (Patent 6,578,076) and Rothman (Patent 7,826,835).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that while Putzolu provides the foundational client-server policy architecture, Rothman provides the specific context missing for certain dependent claims. Rothman explicitly discloses applying policy management to a "mobile telephone" to control features like picture-taking or text messaging, directly teaching the limitation of claim 2. Rothman also teaches managing a plurality of mobile phones under a plan set by an administrator (e.g., an employer), with customizable policies for different groups, which Petitioner argued meets the limitations of claims 7 and 8.
- Motivation to Combine: A POSITA would combine the references to apply the known, general-purpose policy management system of Putzolu to the specific, known application of controlling mobile phone features described in Rothman. This combination would be a predictable solution to the well-known problem of managing mobile device usage for purposes like corporate control or parental supervision.
- Expectation of Success: Petitioner argued success would be expected because the combination involves applying a known technique (Putzolu's system) to a device ready for such improvement (Rothman's mobile phone) to achieve a predictable result.

Prior Art Relied Upon: Bhat (Application # 2005/0021978).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Bhat teaches the key limitations of independent claim 13 concerning local caching and updating of policy decisions. Bhat discloses a system where a policy enforcement point (a web server) receives an initial policy decision from a policy engine (a server) and stores it in a local cache. For subsequent requests, the web server uses the stored decision instead of contacting the server again. Critically, Bhat also teaches that the enforcement point can receive an "updated policy decision" from the engine if the underlying policy changes, and then determines whether to grant a request based on both the original stored decision and the update.
- Motivation to Combine: Not applicable (single reference).
- Expectation of Success: Not applicable (single reference).
- Key Aspects: This ground focused on the efficiency aspect of the invention, which Petitioner contended was fully disclosed by Bhat’s teaching of caching policy decisions locally to reduce network traffic and server load.

"the decision being based on one or more policies that are stored at the server" (Claims 1, 13, 27): Petitioner argued this phrase should be construed to mean the decision "results from the server applying the policy... to the request sent by the computing device." Citing the prosecution history, Petitioner asserted that the Applicants distinguished prior art by emphasizing that policy decisions are "performed at the server level" in a "distributed architecture," not on the device. This construction is central to the obviousness arguments, as it requires the decision-making logic to reside on the server, a key feature taught by the prior art references.

Petitioner argued that discretionary denial under Fintiv would be inappropriate. The petition asserted that the parallel district court litigation was in its very early stages, with a trial date of August 28, 2023, well after the projected Final Written Decision date in Q1 2023. Petitioner also noted that investment by the court and parties had been minimal, with fact discovery still open and no depositions taken. Finally, Petitioner stated it would cease asserting in the litigation any combination of references on which trial is instituted, thereby narrowing the issues and avoiding significant overlap.

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 5-15, 18-21, and 27-29 of the ’559 patent as unpatentable.