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IPR2025-01261

Apple Inc v. Avant Location Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Monitoring the Presence of a Mobile Station in a Special Area
  • Brief Description: The ’910 patent discloses techniques for monitoring when a mobile station is present within a "special area." The special area is defined by the coverage of radio communication devices, such as cellular base stations, that transmit defining signals which the mobile station receives and uses to send an updating signal to the network.

3. Grounds for Unpatentability

Ground 1: Claims 1-2 and 4-8 are obvious over Kraufvelin and Hashimoto

  • Prior Art Relied Upon: Kraufvelin (Application # 2006/0135174) and Hashimoto (Application # 2005/0070283).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kraufvelin taught the core method of monitoring a mobile station's presence. Kraufvelin disclosed defining a geographical "area of interest" by creating a list of Cell IDs corresponding to base stations in that area, sending this list to the mobile station, and having the mobile station compare its current serving Cell ID to the list. If a match occurs, the mobile station sends a location update report to the network. Petitioner contended that Hashimoto supplied the conventional and necessary detail that base stations periodically broadcast their Cell IDs, a feature not explicit in Kraufvelin. Hashimoto also disclosed that a mobile station in an area of overlapping coverage can receive signals and Cell IDs from multiple base stations. The combination thus taught a mobile station receiving periodically broadcast Cell IDs to determine its presence in a special area and reporting this presence to a network server.
    • Motivation to Combine: A POSITA would combine Hashimoto’s teaching of periodically broadcasting Cell IDs with Kraufvelin’s system to ensure reliable operation. This was argued to be a combination of known elements according to known methods (both references relate to 3G cellular standards) to yield the predictable result of a mobile station determining its location. Similarly, a POSITA would incorporate Hashimoto’s teachings on handling overlapping cell coverage to ensure Kraufvelin’s system functioned properly in a real-world network.
    • Expectation of Success: A POSITA would have had a high expectation of success, as both references described standardized cellular network components and signals, making the integration of a conventional feature (periodic Cell ID broadcast) into a location-monitoring system a predictable improvement.

Ground 2: Claim 3 is obvious over Kraufvelin, Hashimoto, and Huomo

  • Prior Art Relied Upon: Kraufvelin (Application # 2006/0135174), Hashimoto (Application # 2005/0070283), and Huomo (Application # 2004/0203863).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 3, which requires that the frequency of the updating signal be different from the frequency of the distinctive defining signal. Petitioner asserted that the combination of Kraufvelin and Hashimoto established the base system for location monitoring using cellular network signals. Huomo was introduced because it taught a system for location-based services that used identifiers from both cellular networks and smaller-scale, short-range wireless services (e.g., WLAN, Bluetooth). Petitioner argued that a mobile station could receive a "defining signal" from a short-range access point (per Huomo) and then send its "updating signal" over the cellular network (per Kraufvelin). It was well-known at the time of the invention that cellular and short-range wireless technologies (like WLAN) operate at different frequencies.
    • Motivation to Combine: A POSITA would combine Huomo's teachings with the Kraufvelin/Hashimoto system to define special areas with greater precision. For example, a short-range network could define a specific retail store within the larger coverage area of a cellular base station. This modification would predictably yield the result of using signals on different frequencies for defining the location versus reporting the location.
    • Expectation of Success: Success was reasonably expected because defining geographical locations using a combination of cellular and short-range wireless technologies was a known technique for improving location accuracy.

Ground 3: Claims 9-14 are obvious over Kraufvelin, Hashimoto, and Andersson

  • 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: This ground targeted claims 9-14, which relate to defining and monitoring a mobile station’s presence in first and second different special areas. While the Kraufvelin/Hashimoto combination taught monitoring a single special area, Andersson taught a system for monitoring a mobile station relative to multiple, distinct areas of interest. Andersson disclosed using multiple "Allowed Cells Lists" to implement different rules or services in different geographical areas (e.g., a "first set of cells" where call origination is allowed and a "second set of cells" where call reception is allowed).
    • Motivation to Combine: A POSITA would have been motivated to incorporate Andersson’s teaching of using multiple cell lists into the Kraufvelin/Hashimoto system to provide greater flexibility. This would allow a client to define and monitor multiple distinct special areas to offer different location-based services depending on the mobile station's location, a simple and predictable extension of the base system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both Kraufvelin and Andersson taught the same fundamental technique of comparing a received Cell ID against a stored list. Applying this known technique to manage multiple lists, as taught by Andersson, was a predictable use of prior art elements according to their established functions.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-14 of Patent 9,042,910 as unpatentable under 35 U.S.C. §103.