PTAB

IPR2025-01259

Apple Inc v. Avant Location Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Location-Based Tariffs and Services for Mobile Devices
  • Brief Description: The ’720 patent relates to systems and methods for providing location-dependent services or tariffs to mobile stations. The technology uses a "radio communication defining device" to transmit a "distinctive defining signal," which defines a "special area" wherein a mobile station’s presence triggers adjustments to its services or billing rates.

3. Grounds for Unpatentability

Ground 1: Obviousness over Vendetti and Granberg - Claims 1-2, 5, 7, 9-10, 12, and 15 are obvious over Vendetti in view of Granberg.

  • Prior Art Relied Upon: Vendetti (Patent 5,295,180) and Granberg (Patent 6,122,510).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Vendetti disclosed the core method of using "marker transmitters" (radio communication defining devices) to transmit "marker signals" (distinctive defining signals) that define specific geographic "zones" (special areas). Within these zones, a mobile unit could be billed at different rates. Petitioner asserted that Granberg supplemented Vendetti by teaching the specific implementation of adjusting services through a database containing subscriber records with "network-specific indicators" or "flags" (a service flag) that could be set or reset to activate or deactivate services. The combination, therefore, taught a mobile station sending an update signal to a server which, in turn, adjusted an operating parameter comprising a tariff (from Vendetti) and a service flag (from Granberg).
    • Motivation to Combine (for §103 grounds): Petitioner contended that Vendetti described a system for location-based billing but left the specific implementation details to a POSITA. A POSITA would combine Vendetti’s system with Granberg’s well-known flag-setting database techniques to efficiently implement, manage, and scale the location-based tariff changes for a large number of subscribers.
    • Expectation of Success (for §103 grounds): A POSITA would have an expectation of success because both references operate in cellular networks, describe managing subscriber profiles, and are therefore compatible. Applying Granberg's standardized database management to Vendetti's location-based system was argued to be a predictable and conventional design choice.

Ground 2: Obviousness over Vendetti, Granberg, and Kraufvelin - Claim 2 is obvious over Vendetti and Granberg in view of Kraufvelin.

  • Prior Art Relied Upon: Vendetti (Patent 5,295,180), Granberg (Patent 6,122,510), and Kraufvelin (Application # 2006/0135174).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Vendetti-Granberg combination to address claim 2, which requires the updating signal to be sent at specific times: periodically, upon entry/exit of the special area, or while remaining in the area. While Vendetti taught periodic monitoring, Petitioner argued Kraufvelin explicitly disclosed a system for sending location-based notifications upon "ENTERing the area" or "LEAVEing the area," as well as periodically.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Kraufvelin's more comprehensive timing triggers with the base Vendetti-Granberg system to improve the accuracy of location detection. This would allow the system to provide more accurate and timely tariffs and services, which is particularly useful for mobile devices that are, by nature, constantly moving.

Ground 3: Obviousness over Vendetti, Granberg, and Huomo - Claims 4, 6, 11, and 16 are obvious over Vendetti and Granberg in view of Huomo.

  • Prior Art Relied Upon: Vendetti (Patent 5,295,180), Granberg (Patent 6,122,510), and Huomo (Application # 2004/0203863).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Huomo to address claims related to signal frequencies. Claims 4 and 6 require the distinctive defining signal to have a frequency different from the updating signal and/or outside the frequency range allocated for the mobile telephone network. Petitioner asserted Huomo taught a location-based system using both cellular network identifiers and short-range wireless services (e.g., WLAN, Bluetooth). It was well-known that these two communication types operate at different, non-interfering frequencies.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Huomo's teachings to create more granular and precise "special areas" (e.g., a specific store within a mall) than possible with cellular signals alone. Using short-range wireless technology for the "distinctive defining signal" to define these precise zones would predictably result in that signal having a different frequency from the cellular network-based "updating signal," thus rendering the claims obvious.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 5, 10, 14, and 15 based on Vendetti, Granberg, and Vimpari (WO 00/27152). This ground primarily relied on Vimpari's teachings for storing authentication parameters in a device's memory to verify its validity within a fixed network.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-2, 4-7, 9-12, and 14-16 as unpatentable.