Amazon.com Inc v. Kaifi LLC

1. Case Identification

• Case #: IPR2025-00626
• Patent #: 11,082,518
• Filed: February 26, 2025
• Petitioner(s): Amazon.com, Inc.
• Patent Owner(s): Kaifi LLC
• Challenged Claims: 1-20

2. Patent Overview

• Title: System and Method for Controlling Machine
• Brief Description: The ’518 patent discloses a multi-device home automation system managed by a central "relation server." The server receives a command from a user, identifies the required machines and their capabilities to perform the task, and controls the selected machines to execute the command.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Ermis

• Prior Art Relied Upon: Ermis (Application # 2012/0079091).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Ermis, which predates the ’518 patent by over two years, discloses all limitations of the challenged claims. Ermis describes a "system 12" that functions as a server to manage "networked objects 10" in a home automation environment. Petitioner asserted this server-based "system 12," with its "relation management function 22," is the claimed "relation server." Ermis's concept of forming "relationships" between devices to perform tasks (e.g., turning off lights, starting a washing machine) and its use of "data flows" to define the sequence of operations correspond directly to the ’518 patent's "relation profile" containing a "task processing schedule parameter."
  • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner argued that all claimed features are present in Ermis, which provides express motivation to combine features from its different embodiments to achieve the advantages of streamlined user-device interactions.
  • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground. Petitioner contended that Ermis alone renders the claims obvious.
  • Key Aspects: Petitioner emphasized that key limitations identified by the Examiner during prosecution—such as storing a relation profile with a task processing schedule, and generating a new profile based on user intervention—are explicitly taught by Ermis. For example, Ermis shows a user approving the creation of new relationships between a rental car and other devices, which constitutes a user intervention that generates a new relation profile.

Ground 2: Claims 1-20 are obvious over Ermis in view of Nakano

• Prior Art Relied Upon: Ermis (Application # 2012/0079091) and Nakano (Patent 9,720,391).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Ermis provides the foundational home automation system, and Nakano provides specific, well-known implementation details that a person of ordinary skill in the art (POSITA) would have used to implement Ermis's system. Specifically, Nakano teaches organizing multi-device operations into a "cooperative process composition table," which links device IDs to specific operation IDs. Petitioner asserted this structured table is a direct and obvious implementation of Ermis's "data flows" and the ’518 patent's "task processing schedule parameter." Furthermore, Nakano teaches using a "product code" and "software version" to identify a device's operating system, which corresponds to the "operating system parameter" claimed in the machine profiles of the ’518 patent.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Nakano’s teachings with Ermis's system to achieve predictable results and known benefits. Implementing Nakano's structured data tables would improve the efficiency, scalability, and interoperability of Ermis's system by allowing for efficient database querying and management of complex tasks. Incorporating Nakano's method of identifying operating systems would help achieve Ermis's stated goal of ensuring compatible communication between disparate devices.
  • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in this combination. Both references address the analogous field of home automation using servers to control standard interconnected devices. The combination involves applying a known data structuring technique (Nakano) to a known system architecture (Ermis), which would have been a routine design choice.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under Fintiv, asserting that the co-pending litigation is in its early stages. Key events like claim construction and the close of discovery are scheduled for late 2025, and the March 2026 trial date is speculative and not substantially earlier than the projected Final Written Decision (FWD) date.
• Petitioner also contended that denial under 35 U.S.C. §325(d) is inappropriate because the primary references asserted in the petition, Ermis and Nakano, are highly material and were never considered by the Examiner during the prosecution of the ’518 patent.

5. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-20 of Patent 11,082,518 as unpatentable.