PTAB

IPR2025-01262

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
  • Brief Description: The ’621 patent discloses methods for monitoring the presence of a mobile station within a predefined "special area." The system relies on a provider of presence-related services, distinct from the mobile telephone network, using servers to enable or disable services based on updating signals received from the mobile station that indicate its presence within the special area.

3. Grounds for Unpatentability

Ground 1: Obviousness over Putkiranta and Kraufvelin - Claims 1, 4-10, and 13-18 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 that Putkiranta disclosed the core elements of the challenged claims. Putkiranta taught a system where a mobile station, upon entering a "localized service area" defined by a set of base station cells, sends a notification message to a service server. This server then enables or disables location-dependent services (e.g., call pricing, email routing) for that mobile station. Petitioner asserted that this system taught a method involving a provider of presence services (the service/application servers), a special area defined by radio signals (the localized service area), storing linking data (mobile station IDs with cell IDs), and receiving an updating signal from the mobile station to enable/disable a service. However, Putkiranta’s system relied on the mobile station's determination of its location. Kraufvelin was introduced to address deriving the mobile station's presence on the network side.
    • Motivation to Combine: Petitioner contended that Kraufvelin addressed a known problem in systems like Putkiranta’s: the potential for inaccurate location data because network configurations (e.g., cell IDs for a given area) change frequently. Kraufvelin taught performing a network-side "sanity check" by comparing the cell-ID reported by the mobile station with the network's current list of cell-IDs for the intended geographical area. A person of ordinary skill in the art (POSITA) would combine Kraufvelin's verification feature with Putkiranta’s system to improve its accuracy and reliability, ensuring that services were provided based on the mobile station's actual, verified location rather than a potentially outdated, mobile-reported one. This combination would yield the predictable result of a more robust location-based service.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Putkiranta and Kraufvelin described analogous systems addressing the same technical field of location-based services in cellular networks. The proposed combination involved implementing a known verification technique (Kraufvelin's sanity check) to improve a known system (Putkiranta's), which was a predictable use of prior art elements.

Ground 2: Obviousness over Rachabathuni - Claims 1, 4-10, and 13-18 are obvious over Rachabathuni.

  • Prior Art Relied Upon: Rachabathuni (Patent 6,628,938).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Rachabathuni, standing alone, rendered the claims obvious. Rachabathuni disclosed a location-based service system using short-range wireless beacons (e.g., Bluetooth) instead of cellular base stations. In this system, a mobile device received a beacon signal containing a unique location identifier when it entered the beacon's range (the "special area"). The mobile device then relayed this location information as an "updating signal" to a "location identification server" via a cellular network. This server, along with a "proximity server," constituted a provider of presence-related services separate from the mobile network. The servers processed this information to determine the mobile device's presence and, in response, enabled or disabled applications or services on the device. Petitioner mapped Rachabathuni's wireless beacon to the claimed "radio communication defining device," its coverage area to the "special area," and its location ID to the "checking data." The transmission of the beacon information from the mobile device to the server was argued to be the claimed "updating signal."
    • Key Aspects: This ground asserted that all limitations of the independent claims were met by a single reference. Rachabathuni's disclosure of servers (location and proximity servers) connected to the cellular network but distinct from it was argued to meet the limitation that the service provider is "different than the mobile telephone network." The enabling/disabling of services was controlled by the proximity server, which modified system behavior based on the mobile station's presence in the beacon's range.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 2-3 and 11-12 over Putkiranta, Kraufvelin, and Granberg (Patent 6,122,510), and also over Rachabathuni and Granberg. Granberg was introduced for its teaching of using a database with network-specific flags (e.g., tariff or service flags) to efficiently manage and update services for subscribers based on their location. This was argued to make it obvious to modify the primary combinations to include updating an "operating parameter" in a database, as required by the dependent claims.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-18 of the ’621 patent as unpatentable under 35 U.S.C. §103.