PTAB

IPR2022-00586

Qualcomm Inc v. FedEx Corporate Services Inc

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1. Case Identification

2. Patent Overview

  • Title: Hierarchical Sensor Network for a Grouped Set of Packages Being Shipped Using Elements of a Wireless Node Network
  • Brief Description: The ’231 patent discloses a system for monitoring a group of packages using a hierarchical sensor network. The network comprises a server, a mobile master node, and one or more ID nodes, which are placed within the packages. The server creates the network hierarchy by recording association data linking the master node to one package, ID nodes to other packages, and the master node to the ID nodes.

3. Grounds for Unpatentability

Ground 1: Claims 1-27, 29, and 30 are obvious over Lau in view of Benson.

  • Prior Art Relied Upon: Lau (Patent 7,212,829) and Benson (Application # 2007/0002139).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lau discloses a general "article shipment notification system" with a tracking server and tracking devices attached to packages, where the server stores information associating the device with the package. Benson discloses a specific hierarchical monitoring system comprising a "master data collection unit" (the claimed master node), multiple "remote sensor units" (the claimed ID nodes), and a "central data collection server." Critically, Benson's remote sensor units act as slave devices that communicate with the master unit but are not configured to communicate directly with the central server. Petitioner contended that implementing Lau’s system with Benson’s hierarchical architecture meets the limitations of independent claims 1, 10, 16, and 26, including the creation of the hierarchy by the server and the distinct communication paths for the master and ID nodes.
    • Motivation to Combine: A POSITA would combine Lau and Benson for several reasons. First, Lau explicitly states its system "supports many different tracking devices," and Benson discloses just such a hierarchical tracking device system. Second, a POSITA would seek to obtain the well-known benefits of a hierarchical network, which both Lau's provisional application and Benson recognize, such as reduced cost for numerous lower-tier sensors, decreased communication volume by aggregating data at the master node, and lower overall power consumption.
    • Expectation of Success: The combination represented the predictable application of a known hierarchical sensor network architecture (Benson) to a known problem domain (Lau's package tracking), providing a POSITA with a reasonable expectation of success.

Ground 2: Claim 28 is obvious over Lau in view of Benson and Harring.

  • Prior Art Relied Upon: Lau (Patent 7,212,829), Benson (Application # 2007/0002139), and Harring (Patent 9,501,920).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Lau-Benson combination to address the limitations of claim 28, which adds the requirement that the group of packages is "identified by shipping information to be related and shipped together, the shipping information maintained on the server and defined by a shipping customer." Petitioner argued that Harring teaches a cargo tracking system that discloses this functionality. Harring describes a "large customer Web site" that provides customer-specific data, including a "customer shipment summary page" displaying a summary of all shipments associated with that customer. This mapping provides the claimed shipping information that is maintained on a server (Harring's web server) and defined by a shipping customer.
    • Motivation to Combine: A POSITA would be motivated to integrate Harring's teachings into the Lau-Benson system based on Lau’s own disclosure that "interested parties can gain access to status information pertaining to the articles being shipped via a website." Harring provides a specific, known implementation of such a customer-facing website for tracking shipments. A POSITA would therefore incorporate Harring's customer web portal to provide the website functionality expressly contemplated by Lau.
    • Expectation of Success: Integrating a known web-based customer interface for displaying shipment data (Harring) with a back-end hierarchical tracking system (Lau-Benson) was argued to be a straightforward and predictable design choice with a high expectation of success.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate because the asserted grounds are not cumulative to the prosecution history. The primary reference, Lau, was cited in an Information Disclosure Statement (IDS) that included 50 other references but was never substantively discussed or used as the basis for a rejection by the examiner. The other key references, Benson and Harring, were never presented to the examiner at all. Petitioner asserted that its arguments are therefore substantively different from those considered during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’231 patent as unpatentable under 35 U.S.C. §103.