PTAB

IPR2025-01256

Apple Inc v. Avant Location Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Monitoring the Presence of a Mobile Station
  • Brief Description: The ’040 patent describes a method for monitoring a mobile device's presence within predefined "special areas." The system uses defining signals from network base stations, which the mobile device receives and processes to determine its location, subsequently sending an updating signal to the network to trigger location-based parameter adjustments.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 5-8, and 10-14 are obvious over [Kraufvelin](https://ai-lab.exparte.com/case/ptab/IPR2025-01256/doc/1006), [Hashimoto](https://ai-lab.exparte.com/case/ptab/IPR2025-01256/doc/1008), and [Andersson](https://ai-lab.exparte.com/case/ptab/IPR2025-01256/doc/1007)

  • Prior Art Relied Upon: Kraufvelin (Application # 2006/0135174), Hashimoto (Application # 2005/0070283), and Andersson (Patent 6,230,017).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Kraufvelin, discloses the core method of monitoring a mobile station in a defined "area of interest" by having the mobile station compare a received cell ID against a pre-stored list of IDs defining that area. When a match occurs, the mobile station sends a location report to the network. Petitioner contended that Hashimoto supplies a conventional implementation detail missing from Kraufvelin: that base stations "periodically transmit" their cell IDs over a broadcast channel (BCCH), which is how a mobile device would receive the defining signal. Finally, Andersson was argued to teach the network-side implementation, describing databases that link a mobile station's location to a set of operating parameters (e.g., special tariffs) and adapting those parameters based on location updates.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references to achieve a predictable result. A POSITA would implement Kraufvelin’s location monitoring system using Hashimoto’s well-known method of broadcasting cell IDs, as it was a standard feature of 3G cellular networks. Furthermore, a POSITA would integrate Andersson’s database system for managing the location data from Kraufvelin’s system. Storing parameters in a database, as taught by Andersson, provided known advantages such as centralized management, data standardization, and the ability to offer location-based services like variable tariffs, which Kraufvelin suggests but does not detail.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because all three references operate within the same field of cellular communication, describe standardized network components and protocols, and address the common problem of providing location-based services. The combination involved applying known techniques to yield a predictable improvement.

Ground 2: Claims 3-4 are obvious over Kraufvelin, Hashimoto, Andersson, and [Sundar](https://ai-lab.exparte.com/case/ptab/IPR2025-01256/doc/1017)

  • Prior Art Relied Upon: Kraufvelin (Application # 2006/0135174), Hashimoto (Application # 2005/0070283), Andersson (Patent 6,230,017), and Sundar (Application # 2003/0134636).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Sundar to the primary combination to address limitations in claims 3 and 4. Petitioner argued Sundar teaches applying location-monitoring techniques to both cellular (WWAN) and Wi-Fi (WLAN) networks. For claim 4, which requires a defining signal from a wireless device transmitted "outside the frequency range" of the cellular network, Sundar’s disclosure of using Wi-Fi access points and their SSIDs meets this limitation. For claim 3, which requires acknowledging receipt of the update signal, Petitioner argued Sundar explicitly discloses a "registration ACK" message sent to the mobile device after it sends a location update, a conventional feature for ensuring data integrity.
    • Motivation to Combine: A POSITA would combine Sundar with the base combination to extend location-monitoring capabilities to Wi-Fi networks. This would predictably improve location accuracy due to the smaller coverage areas of Wi-Fi access points and allow services to be offered in locations without cellular coverage. Adding an acknowledgment step as taught by Sundar was presented as a simple, well-known method to improve system reliability.

Ground 3: Claim 9 is obvious over Kraufvelin, Hashimoto, Andersson, and [McNutt](https://ai-lab.exparte.com/case/ptab/IPR2025-01256/doc/1014)

  • Prior Art Relied Upon: Kraufvelin (Application # 2006/0135174), Hashimoto (Application # 2005/0070283), Andersson (Patent 6,230,017), and McNutt (Application # 2001/0037211).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds McNutt to address claim 9, which recites that the updating signal includes a "request to access a service" and that the network includes means to "allow or forbid the provision of this service" based on location. Petitioner argued that McNutt discloses precisely this: an interactive wagering application that verifies a user's location and, based on that location, either permits or restricts access to the wagering service.
    • Motivation to Combine: Kraufvelin teaches providing various location-based services but is not specific. McNutt provides a concrete example of a location-dependent service (wagering) and the logic for gating access. A POSITA would have been motivated to incorporate McNutt’s service-access control into the Kraufvelin/Andersson framework to expand the types of services offered, particularly for services regulated by location. This combination would predictably result in a more robust location-based service platform.

4. Key Claim Construction Positions

  • "special operating means" ([1.7], [11.2]): Petitioner argued this is a means-plus-function term.
    • Function: Adapting the value of at least one operating parameter taking into account the presence of the mobile station in each of the special areas.
    • Structure: At least one server storing a database that links a special area, a mobile station, and one or more parameters. This construction was central to Petitioner’s argument that Andersson’s database, which links cell lists to tariffs for a specific mobile station, provides the structure for the claimed function.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-14 of the ’040 patent as unpatentable.