PTAB

IPR2025-01327

Reolink Innovation Inc v. Hsin Tai Wu

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Searching System, Method, and P2P Device for P2P Device Community
  • Brief Description: The ’655 patent describes a peer-to-peer (P2P) system for managing content downloads from a community of P2P devices. The system architecture includes an online server that maintains a topology data table of device connections and a separate content management server that uses an index database to handle search requests from a user's device.

3. Grounds for Unpatentability

Ground 1A: Anticipation by Schwan - Claims 1-4, 7-9, 11-13, 16, 18, and 19 are anticipated by Schwan.

  • Prior Art Relied Upon: Schwan (EP Publication No. 2,086,206).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schwan discloses a P2P system that tracks and facilitates content downloads between peer nodes. Schwan’s “tracker node” functions as the claimed content management server, storing a content index (table 32) that maps to the claimed index database. Schwan’s “peer-to-peer manager” functions as the claimed online server, storing network topology information (table 34) including latency and ISP data, which maps to the claimed topology data table and link data. A user device (peer node A) sends a search request to the tracker, which searches its index and uses topology data from the manager to return a ranked list of peers, fulfilling all limitations of independent claims 1 and 11.

Ground 1B: Obviousness over Schwan and Lee - Claims 1-4, 7-13, 16-19 are obvious over Schwan in view of Lee.

  • Prior Art Relied Upon: Schwan (EP Publication No. 2,086,206) and Lee (Application # 2011/0087775).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent Schwan does not explicitly teach a user's device obtaining link data based on both a search result and a topology data table to establish a connection, Lee supplies this teaching. Lee describes a P2P control device that receives a search request, returns a content identifier (the search result), and then, upon request, generates a P2P overlay connection for content delivery using network topology information.
    • Motivation to Combine: A POSITA would combine Schwan with Lee to solve the problem of inefficient P2P connections that Schwan acknowledges can occur. Lee’s method of generating an optimized P2P overlay based on network topology and providing link data to establish that overlay would have been a predictable solution to improve the efficiency and reliability of content delivery in Schwan's system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success as both references operate in the P2P networking domain and address the common problem of efficiently connecting peers for content sharing.

Ground 1C: Obviousness over Schwan, Lee, and Strickland - Claims 5, 6, 14, and 15 are obvious over Schwan in view of Lee, and further in view of Strickland.

  • Prior Art Relied Upon: Schwan (EP Publication No. 2,086,206), Lee (Application # 2011/0087775), and Strickland (Application # 2007/0226368).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued the Schwan-Lee combination provides the base P2P searching system, while Strickland teaches the charging-related limitations of claims 5, 6, 14, and 15. Strickland discloses a P2P server that facilitates monetary transactions for file sharing, including a "user-charge module" that confirms a user has been charged (either via direct payment or pre-purchased credits) before authorizing a download. Strickland’s server receives user identity, charging, and payment confirmation data from the user’s device.
    • Motivation to Combine: A POSITA would be motivated to add Strickland’s charging functionality to the Schwan-Lee system to create a commercial P2P content delivery network. This would provide a convenient and flexible way to charge users for downloads and reward content providers, which was a well-known business model and design choice in the field.
    • Expectation of Success: Integrating a known transactional model like Strickland’s into a P2P download system was a predictable implementation with a high expectation of success.

Ground 2A: Anticipation by Li - Claims 1, 7-9, 11, 16, 18, and 19 are anticipated by Li.

  • Prior Art Relied Upon: Li (CN Publication No. 101018172).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Li discloses a P2P system in a metropolitan area network that anticipates the challenged claims. Li’s system includes P2P node computers (the P2P devices), a “P2P index server” (the content management server with an index database and search engine), and a “topology server” (the online server). The topology server stores a topology data table with location vectors (subnet IP addresses and switch connections) for each P2P node, which constitutes the claimed link data. A requesting P2P node queries the index server, which returns a list of resource nodes; this list is then used with the topology server to identify the nearest neighbor node for download, thereby anticipating the claimed system and method.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1, 7-11, and 16-19 are obvious over Li in view of Rose (Application # 2005/0050028), which allegedly provides teachings on generating a comprehensive, periodically updated index database. Further grounds build on the Li-Rose combination by adding Schwan for search result sorting or Strickland for charging functionalities.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’655 patent as unpatentable.