PTAB

IPR2025-01179

CentralSquare Technologies LLC v. Carbyne Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Streaming Real-Time Data
  • Brief Description: The ’383 patent relates to systems and methods for streaming real-time data from a user's mobile device to a recipient, such as an emergency call center. The technology involves establishing a first connection (e.g., a voice call), using a unique identifier to send the user an electronic message with a URL link over a second, different connection, and using the link to establish a Web Real-Time Communication (WebRTC) session for transmitting a real-time video stream.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8-13, and 15-19 are Anticipated or Obvious over Ramanujaiaha

  • Prior Art Relied Upon: Ramanujaiaha (Patent 9,762,733).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ramanujaiaha discloses all limitations of independent claims 1, 8, and 15. Ramanujaiaha teaches a contact center system for emergency response services that receives an inbound telephony call from a user’s mobile device (a "first connection"). The system’s call controller extracts the caller’s telephone number. An "orchestration module" then sends an electronic message (an SMS) containing a URL link to the user's device over a separate digital channel (a "second connection"). Petitioner asserted that when the user clicks the link, Ramanujaiaha discloses that a mobile web browser is launched to open a "visual communication channel," establishing a "multimodal session" that runs concurrently with the initial voice call. This session uses WebRTC to transmit real-time video from the mobile device to a live agent at the contact center for display.
    • Motivation to Combine (for §103 grounds): For any limitations the Board might find merely suggested by Ramanujaiaha (such as configuring a server to convert data formats), Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to make such a modification. This would directly support Ramanujaiaha's express goal of facilitating real-time, multimodal interactions. For instance, configuring its multimodal server as a proxy to reformat video streams would be an obvious way to ensure data compatibility between the user device and the contact center.
    • Expectation of Success: A POSITA would have a high expectation of success because Ramanujaiaha expressly contemplates using WebRTC for real-time video and combining distinct voice and visual channels. Implementing these features would involve the straightforward application of known, conventional techniques to achieve the predictable results disclosed in the reference.

Ground 2: Claims 1-20 are Obvious over Ramanujaiaha in view of Krishnan

  • Prior Art Relied Upon: Ramanujaiaha (Patent 9,762,733) and Krishnan (Patent 9,420,099).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this ground as an alternative, asserting that to the extent Ramanujaiaha is found not to teach every element, the combination with Krishnan renders all challenged claims obvious. Ramanujaiaha provides the primary framework of a multimodal contact center that uses a voice call and a subsequent SMS link. Krishnan was cited to supply or reinforce specific teachings for emergency communications. Krishnan explicitly discloses a Public Safety Access Point (PSAP) system where an emergency caller maintains a "voice-only channel" while the PSAP server sends a text message with a link. This link establishes a separate "data channel" (e.g., a WebRTC session) to transmit video, images, and GPS data about an "emergent event" for display to a PSAP agent. Petitioner argued Krishnan explicitly teaches transmitting additional data types like GPS location and photographs (as recited in claims 7, 14, and 20) over the WebRTC session.
    • Motivation to Combine: A POSITA seeking to improve the emergency response system of Ramanujaiaha would have been motivated to incorporate the specific methods taught by Krishnan. Both references address the identical problem of enhancing emergency services by enabling simultaneous voice and video/data streams from a mobile device. A POSITA would logically combine Krishnan's explicit and detailed implementation of a WebRTC data channel for emergency event reporting with Ramanujaiaha's broader multimodal contact center architecture to create a more effective and reliable emergency communication system.
    • Expectation of Success: A POSITA would reasonably expect success in combining the references. Both teach using similar, compatible components (smartphones, cellular networks, SMS, WebRTC) for the common purpose of improving emergency response. Combining their teachings would be a straightforward application of known elements according to their known functions to yield the predictable result of a system capable of concurrent voice and rich data communication during an emergency call.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 11,689,383 as unpatentable.