PTAB

IPR2026-00008

Cisco Systems Inc v. Dynamic Mesh Networks Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Mesh Network
  • Brief Description: The ’691 patent discloses a structured wireless mesh network where nodes form a hierarchical, tree-like topology. The system is designed to maintain internal connectivity and transition smoothly between a configuration connected to an external network and an isolated configuration where the external connection is lost.

3. Grounds for Unpatentability

Ground 1: Claims 1, 18, and 35 are obvious over Castagnoli, Bauer, and Gil.

  • Prior Art Relied Upon: Castagnoli (Application # 2006/0215581), Bauer (Application # 2007/0140239), and Gil (Patent 7,852,819).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Castagnoli taught the foundational system: a hierarchical, tree-like wireless mesh network with routing nodes, including multi-radio nodes that use different channels for upstream and downstream data transfer. To address the claimed "isolated operation," Petitioner asserted that Bauer taught how a mesh network maintains functionality when disconnected from an external network by providing IP services (like DHCP) locally among the mesh nodes. The combination allegedly met the core limitations of a structured mesh network capable of operating in both connected and isolated modes. Gil was added to teach that the backhaul connection from a root node to an external network could be wireless, a known alternative to the wired connection mentioned in Castagnoli.
    • Motivation to Combine: A POSITA would combine these references to create a more robust and fault-tolerant mesh network. Castagnoli provided the basic hierarchical structure, Bauer solved the known problem of losing external connectivity, and Gil provided a known and flexible implementation detail for that external connection. Combining them addressed different, complementary failure scenarios to yield predictable improvements in network reliability.
    • Expectation of Success: Petitioner asserted a high expectation of success because the references addressed distinct but related aspects of mesh networking. Combining Castagnoli's structure with Bauer's isolated operation logic was presented as a straightforward application of known techniques to improve a known system, with Gil merely suggesting an obvious design choice for the backhaul link.

Ground 2: Claims 9-11 and 15-16 are obvious over Castagnoli, Bauer, Gil, and Zeng.

  • Prior Art Relied Upon: Castagnoli (Application # 2006/0215581), Bauer (Application # 2007/0140239), Gil (Patent 7,852,819), and Zeng (Application # 2009/0213730).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims requiring the network to detect the loss of an external connection and then re-establish a new connection. Petitioner argued that while the base combination taught a network that could function in isolation, Zeng specifically taught the claimed recovery mechanism. Zeng described a system where an access point, upon detecting the failure of its primary (wired) backhaul link, reconfigures a radio to actively search for, and connect to, a neighboring access point to re-establish a path to the external network.
    • Motivation to Combine: A POSITA, having already designed a network capable of isolated operation per Castagnoli and Bauer, would be motivated to add Zeng’s teachings to provide an automated recovery mechanism. This would move the system beyond simple fault tolerance (surviving isolation) to active fault recovery (restoring connection), which was a known goal in network design. It was argued to be an obvious improvement to make the network self-healing.

Ground 3: Claim 19 is obvious over Castagnoli, Bauer, Gil, and Papadoglou.

  • Prior Art Relied Upon: Castagnoli (Application # 2006/0215581), Bauer (Application # 2007/0140239), Gil (Patent 7,852,819), and Papadoglou (Application # 2008/0214175).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claim 19, which depended from claim 18 (adding a DHCP server to each node, taught by Bauer) and further required the DHCP server to assign IP addresses containing random numbers. Petitioner contended that the base combination of Castagnoli, Bauer, and Gil already established a mesh network with local DHCP services. Papadoglou was cited as evidence that assigning a random IP address via a DHCP server was a conventional, well-known technique at the time.
    • Motivation to Combine: The motivation was simply to implement a known, common feature into the DHCP server taught by Bauer. A POSITA implementing a DHCP server would have been aware of various IP address assignment strategies, including random assignment, and would have found it obvious to apply this conventional technique. Papadoglou merely confirmed that this was a standard practice, making its application in Bauer's system a predictable design choice.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1, 9-11, 15-16, 18-19, and 35 of the ’691 patent as unpatentable.