PTAB

IPR2025-01257

Apple Inc v. Avant Location Technologies LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Monitoring Presence of Mobile Stations
  • Brief Description: The ’030 patent relates to methods for monitoring the presence of a mobile station within a predefined "special area." Based on the mobile station's presence or non-presence in this area, the system enables or disables associated presence-related services.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 4-11 are obvious over Putkiranta and Kraufvelin.

  • Prior Art Relied Upon: Putkiranta (Patent 8,615,256) and Kraufvelin (Application # 2006/0135174).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Putkiranta disclosed the core method of claim 1. Putkiranta taught a system where a mobile station detects its entry into a "localized service area" (the claimed "special area") defined by cellular base stations. Upon entry, the mobile station sends an updating signal, uncorrelated to a phone call, to a service server. The server then derives the mobile station's presence and instructs an application server to enable or disable location-dependent services. Petitioner asserted this maps to the storing, transmitting, receiving, deriving, and enabling/disabling limitations of claim 1.
    • Motivation to Combine: Kraufvelin addressed a problem in systems like Putkiranta's: network configurations can change, making a mobile station's stored list of service areas outdated. Kraufvelin taught a network-side "sanity check" to verify the cell-ID reported by the mobile station against the network's current configuration. Petitioner contended a POSITA would combine Kraufvelin's sanity check with Putkiranta's system to improve its accuracy and reliability, ensuring that services are based on the mobile station's actual, verified location.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because it involved implementing a known verification technique (Kraufvelin) to improve a similar, known system (Putkiranta) in a predictable manner.

Ground 2: Claims 2-3 are obvious over Putkiranta, Kraufvelin, and Granberg.

  • Prior Art Relied Upon: Putkiranta (Patent 8,615,256), Kraufvelin (Application # 2006/0135174), and Granberg (Patent 6,122,510).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 to address dependent claims 2 and 3, which recite updating an "operating parameter" in a database, such as a "service flag." Petitioner argued that Granberg taught a database for managing subscriber services that used "network-specific indicators" or "flags" as operating parameters. These flags were set or reset to activate or deactivate network-based services for a subscriber.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Granberg’s flag-based database management into the Putkiranta/Kraufvelin system. This would provide a well-known, efficient, and standardized method for updating and tracking the status of services (enabled/disabled) based on the mobile station's presence, thereby facilitating system administration and troubleshooting.

Ground 3: Claims 1 and 4-11 are obvious over Rachabathuni and Huomo.

  • Prior Art Relied Upon: Rachabathuni (Patent 6,628,938) and Huomo (Application # 2004/0203863).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Rachabathuni disclosed an alternative embodiment of the method in claim 1 using short-range wireless beacons. In Rachabathuni, a wireless device receives a beacon signal containing a unique "location identifier" (the claimed "checking data") when it enters the beacon's range (the "special area"). The device then sends this location information as an "updating signal" to a location server, which in turn allows a proximity server to enable or disable services based on the device's location.
    • Motivation to Combine: While Rachabathuni mentioned various wireless technologies, Huomo explicitly taught using cellular technology (e.g., GSM, pico-cells) for location beacons. Petitioner argued a POSITA would combine these teachings to use cellular technology for Rachabathuni's beacons. The motivation was to create a simpler, more integrated system that could leverage a mobile device's existing cellular radio, eliminating the need for a separate technology like Bluetooth and thereby broadening the system's applicability to standard cellular phones.
    • Expectation of Success: Success would be expected because Huomo described a device operating in the proposed manner, demonstrating the feasibility of using cellular technology to transmit beacon signals for location-based services.

Ground 4: Claims 2-3 are obvious over Rachabathuni, Huomo, and Granberg.

  • Prior Art Relied Upon: Rachabathuni (Patent 6,628,938), Huomo (Application # 2004/0203863), and Granberg (Patent 6,122,510).
  • Core Argument for this Ground:
    • Prior Art Mapping: Similar to Ground 2, this ground added Granberg to the primary combination to address the "operating parameter" and "service flag" limitations of claims 2 and 3. Petitioner contended that Granberg's teaching of using settable flags in a database to manage service activation was directly applicable to the location-based service system of Rachabathuni/Huomo.
    • Motivation to Combine: The motivation paralleled that of Ground 2. A POSITA would combine Granberg with the Rachabathuni/Huomo system to implement a known and efficient method for managing service states. This would provide an easily comprehensible summary of service status (via flags) based on location, improving the verifiability and administration of the presence-based system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11 of the ’030 patent as unpatentable.