PTAB

IPR2024-00857

VusIONGroup SA v. Hanshow Technology Co Ltd

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1. Case Identification

2. Patent Overview

  • Title: Interactive Electronic Tag Device Communication System and Method
  • Brief Description: The ’216 patent discloses an interactive communication system for electronic tag devices designed to conserve battery power. The system achieves this by switching tags between a "normal" (less frequent) and a "fast" (more frequent) monitoring mode, coordinated with a base station's corresponding normal and fast wake-up modes.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 5-8, 11-15, 18, and 19 are obvious over Nagata

  • Prior Art Relied Upon: Nagata (Japanese Published Unexamined Patent Application 2017-126872).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nagata, which discloses a wireless display system with electronic rack labels, teaches all elements of the challenged claims. Nagata’s system comprises a server ("background server"), access points ("base stations"), labels ("electronic tag devices"), and a remote control or smartphone ("external device"). Petitioner asserted that Nagata's labels feature two communication parts—one using NFC with the external device ("second communication path") and another using RF with the access points ("first communication path"). The labels switch between "sleep" and "awake" states to conserve power, which Petitioner mapped to the claimed "normal monitoring mode" and "fast monitoring mode," respectively.
    • Motivation to Combine: This ground relied on a single reference plus the general knowledge of a person of ordinary skill in the art (POSITA). Petitioner contended a POSITA would have understood that Nagata’s access points must operate in modes coordinated with the labels' modes to enable communication, thereby teaching the claimed "normal" and "fast" wake-up modes for the base station.
    • Expectation of Success: Petitioner asserted that implementing Nagata's system using well-known network standards (e.g., IEEE 802.15.4/ZigBee) to realize the claimed functionality would have been obvious with a high expectation of success.

Ground 2: Claims 1, 2, 5-8, 11-15, 18, and 19 are obvious over Nagata in view of Hashiguchi

  • Prior Art Relied Upon: Nagata and Hashiguchi (Japanese Published Unexamined Patent Application 2016-140368).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this combination as an alternative, arguing that to the extent Nagata does not explicitly teach certain "fast" mode limitations, Hashiguchi provides the missing disclosure. Hashiguchi teaches an electronic label system with an "energy-saving mode" where labels wake every 20 seconds and an "active mode" where they wake every 4 seconds. This approach varies the rate of waking, complementing Nagata's disclosure of varying the duration of the awake state.
    • Motivation to Combine: A POSITA would combine Nagata and Hashiguchi to create a more power-efficient system with improved responsiveness. Hashiguchi's more frequent but shorter wake cycles would be seen as an advantageous modification to Nagata's longer awake durations, reducing overall power consumption. The fact that the references share inventors, applicants, and address the same technical problem provided a strong motivation for combination.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in integrating Hashiguchi's wake-up timing into Nagata's system. This would involve the straightforward application of known power management techniques to yield the predictable result of improved battery life and system responsiveness.

Ground 3A: Claims 3, 4, 9, 10, 16, and 17 are obvious over Nagata in view of Thubert

  • Prior Art Relied Upon: Nagata and Thubert (Application # 2018/0123887).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring the selection of an optimal base station based on signal quality. Petitioner argued that while Nagata discloses a system with a plurality of base stations, Thubert teaches the optimal selection process. Thubert discloses a wireless network where a supervisory device receives signal quality metrics (e.g., RSSI) from multiple access points that detect a node and then selects a primary access point with the best signal for communication.
    • Motivation to Combine: A POSITA would combine Thubert's optimal base station selection logic with Nagata's system to improve communication reliability and throughput. Improving signal quality would reduce retransmissions and decrease the time that labels must remain in the power-intensive fast monitoring mode, directly furthering the goal of battery conservation.
    • Expectation of Success: Applying signal strength reporting to select an optimal communication path was a well-known technique in wireless networking. A POSITA would expect success in applying this conventional method to Nagata's system to achieve the predictable benefits of enhanced reliability and efficiency.
  • Additional Grounds: Petitioner asserted that claims 3, 4, 9, 10, 16, and 17 are also obvious over the combination of Nagata, Hashiguchi, and Thubert, relying on similar arguments for combining the references.

4. Arguments Regarding Discretionary Denial

  • Petitioner stipulated that if the Board institutes this inter partes review, Petitioner will not pursue the specific grounds asserted in this petition, or any other grounds based on patents or printed publications that could have been reasonably raised, in the parallel district court litigation. Petitioner argued this stipulation mitigates concerns regarding conflicting decisions and duplicative efforts, making a discretionary denial under Fintiv improper.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of Patent 11,540,216 as unpatentable.