PTAB

IPR2025-01258

Apple Inc v. Avant Location Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Monitoring a Mobile Station Presence in a Special Area
  • Brief Description: The ’032 patent relates to methods for providing location-based services or tariffs to a mobile station within a special geographic area. The system uses "checking data" stored on the mobile device to determine its presence in the area based on "defining signals" received from network base stations.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 are obvious over Putkiranta, Granberg, and Kraufvelin.

  • Prior Art Relied Upon: Putkiranta (Patent 8,615,256), Granberg (Patent 6,122,510), and Kraufvelin (Application # 2006/0135174).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Putkiranta taught the core method of the challenged claims. In Putkiranta, a mobile station stores a list of base station identifiers ("first checking data") and compares it to received signals to determine its presence in a "localized service area." Upon entering the area, the mobile station sends an "updating signal" to a service provider that is separate from the mobile network operator. Petitioner contended that Granberg taught the claimed "parameters database having an operating parameter" by disclosing a database that uses "network-specific indicators" (e.g., flags) to activate or deactivate network-based services for subscribers. Finally, Kraufvelin was cited as teaching the limitation of "sending...second checking data different from the first checking data to modify the special area" by disclosing a method to provide mobile terminals with updated cell-ID information to account for network changes.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Putkiranta’s system with Granberg’s database management as a predictable and conventional way to implement the service profiles required by Putkiranta. Granberg provided well-known database structures that were a routine implementation detail. A POSITA would also have been motivated to incorporate Kraufvelin’s teachings to improve the reliability and accuracy of Putkiranta’s system. Kraufvelin addressed the known problem of network changes making a stored list of cell identifiers obsolete by teaching a method to send updated lists to the mobile station.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success because all three references operate in the same field of location-based services in cellular networks. The proposed combination involved integrating known, compatible components to improve system functionality in a predictable manner.
    • Key Aspects: This ground was structured to directly rebut the Examiner's reasons for allowance by showing that a service provider separate from the network (Putkiranta) and sending updated checking data (Kraufvelin) were both known in the art.

Ground 4: Claims 1-3 and 5 are obvious over Nam and Noldus.

  • Prior Art Relied Upon: Nam (Application # 2006/0014531) and Noldus (Application # 2010/0167725).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Nam disclosed a location-based service system where a central location server sends a list of Cell-IDs ("first checking data") to a mobile station, defining a "pre-specified area." The mobile station then monitors for these Cell-IDs and transmits a "trigger event" ("updating signal") to the server upon entering the area. Noldus was argued to supplement Nam by teaching a "zone server" with a "zone database" that maintains detailed records for each service zone, including the list of cells defining the zone and the presence status of mobile stations. Crucially, Noldus taught that when a zone definition is modified on the server, an updated list of cell identifiers ("second checking data") is sent to the mobile station to ensure synchronization. For claim 5, Noldus taught tracking a mobile station's "switched off" status in its database and setting a status field to a default value.
    • Motivation to Combine: A POSITA would combine Noldus's database management and dynamic update mechanisms with Nam's location-trigger system as a practical and beneficial implementation. Nam described a system but left management details open; Noldus provided a well-known database approach to manage the zone definitions and ensure their continued accuracy as the network evolved. For handling a switched-off device (claim 5), Noldus provided a logical method for tracking device status to simplify service management, a known problem in the field.
    • Expectation of Success: Petitioner contended the combination would yield predictable results. Both Nam and Noldus described compatible systems for location-based services that rely on transmitting Cell-ID lists to mobile devices over standard network infrastructure. Integrating Noldus's advanced database and synchronization features was presented as a straightforward enhancement to Nam's core system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining the Putkiranta/Granberg/Kraufvelin art with Duan (for claims 4 and 6, teaching acknowledgment and retransmission protocols) and Vimpari (for claim 5, teaching resetting tariffs to a default value when a mobile is switched off). An additional ground also combined Nam, Noldus, and Duan.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 of the ’032 patent as unpatentable.