PTAB

IPR2025-01260

Apple Inc v. Avant Location Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Monitoring Presence of Mobile Devices in Special Areas
  • Brief Description: The ’922 patent discloses methods for providing presence-related services by monitoring a mobile station's location relative to special areas defined by radio communication devices. The system enables or disables services based on updating signals received from the mobile station indicating its presence or non-presence in these areas.

3. Grounds for Unpatentability

Ground 1: Obviousness over Putkiranta and Kraufvelin - Claims 1-3, 6, and 9-16 are obvious over Putkiranta in view of 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 Putkiranta discloses a location-based service system where a mobile station sends a notification to a service server upon entering a "localized service area" defined by cellular base stations (radio communication defining devices). This server then enables or disables services based on the mobile station's location. Petitioner contended that Putkiranta teaches the core limitations of independent claim 1, including defining special areas with distinctive signals, storing data linking the mobile station to these areas, and receiving updating signals from the mobile station to trigger services.
    • Motivation to Combine: Petitioner asserted that Kraufvelin teaches a similar system but adds a "sanity check" feature, where the network verifies a mobile station's reported cell-ID against its own stored definition of the service area to confirm the location. A POSITA would combine Kraufvelin's sanity check with Putkiranta's system to improve accuracy and reliability. This verification ensures that services are delivered only when the mobile station is confirmed to be in the correct location, which is a known problem as network operators frequently reconfigure the cells that define a service area.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination because Kraufvelin teaches a system already operating in the proposed manner. Implementing its verification feature into the analogous Putkiranta system would be a predictable improvement.

Ground 2: Obviousness over Putkiranta, Kraufvelin, and Granberg - Claims 4-5 and 7-8 are obvious over Putkiranta and Kraufvelin in view of 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 upon the combination in Ground 1. Petitioner argued that the additional limitations of claims 4, 5, 7, and 8—which require updating an "operating parameter" like a tariff or service flag in a database—are taught by Granberg. Granberg discloses using a database, such as a Home Location Register (HLR), to manage subscriber services by setting or resetting "network-specific indicators" or flags depending on the subscriber's current network.
    • Motivation to Combine: A POSITA would combine Granberg's database flag management with the Putkiranta/Kraufvelin system to provide an easily comprehensible status summary for network administrators. This would allow them to efficiently verify and troubleshoot which services are enabled or disabled for a mobile station in a particular location, a known benefit of using status tables in network management.
    • Expectation of Success: The combination was presented as the predictable use of a standard network database management technique (from Granberg) to add a beneficial administrative feature to a known type of location-based service system (Putkiranta/Kraufvelin).

Ground 3: Obviousness over Rachabathuni and Huomo - Claims 1-3, 6, and 9-16 are obvious over Rachabathuni in view of Huomo.

  • Prior Art Relied Upon: Rachabathuni (Patent 6,628,938) and Huomo (Application # 2004/0203863).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Rachabathuni discloses an alternative location-based service system where a wireless device receives beacon signals from short-range wireless beacons, each broadcasting a unique "location identifier." The device then relays this location information to a server system (a location identification server and proximity server) that determines the device's proximity to locations and modifies services on the device accordingly. Rachabathuni was thus alleged to teach the key claim limitations using a beacon-based architecture.
    • Motivation to Combine: Rachabathuni suggests that its beacons can use various "packet transmission systems." Huomo explicitly teaches using cellular technology (e.g., GSM, CDMA) for transmitting beacon signals, including representing beacons as "picocells" for greater location accuracy. Petitioner argued a POSITA would combine Huomo's use of cellular technology with Rachabathuni's beacon system to allow a wider range of standard mobile devices (e.g., cell phones) to receive beacon signals without requiring separate hardware (like Bluetooth). This modification would simplify the overall system and expand its applicability.
    • Expectation of Success: A POSITA would have an expectation of success because Huomo already described a system operating in the proposed manner (using cellular technology for location-based beaconing), making its application to Rachabathuni's analogous system a straightforward and predictable modification.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 4-5 and 7-8 over Rachabathuni and Huomo in view of Granberg, relying on a similar database modification theory as in Ground 2.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of the ’922 patent as unpatentable.