PTAB

IPR2026-00032

Samsung Electronics America Inc v. Massively Broadband LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Clearinghouse for Communications Networks
  • Brief Description: The ’925 patent relates to a "clearinghouse" system for telecommunication networks. The system involves a database that collects and stores performance, quality of service (QoS), and infrastructure information, which can be used for network monitoring, providing configuration instructions to devices, and delivering localized content.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 12-18, and 22-25 are obvious over Daley, Aaron, and Scherzer (optionally in view of Dawson).

  • Prior Art Relied Upon: Daley (Application # 2007/0207800), Aaron (Application # 2008/0305747), Scherzer (Application # 2008/0186882), and optionally Dawson (Application # 2003/0216953).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Daley disclosed the core "clearinghouse" concept: a system for monitoring and diagnosing mobile devices that collects performance data into a central server and database. The combination with Aaron and Scherzer adds the claimed features of collecting and using geographic location information alongside more detailed QoS data (e.g., signal strength, dropped calls). Petitioner asserted that if "clearinghouse" is interpreted to require a marketplace for telecommunications infrastructure, the optional combination with Dawson, which disclosed a database for managing and procuring wireless infrastructure sites, would render the claims obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Aaron's and Scherzer's teachings of using location data with Daley's diagnostic system to improve problem assessment and remediation. Knowing a device’s location when a performance issue occurs is a common-sense diagnostic step. A POSITA would further combine these teachings to provide enhanced features like base station recommendations or rankings, improving user experience and gaining a competitive advantage. The optional inclusion of Dawson was motivated by the efficiency of using a single, unified data platform for both network performance monitoring and longer-term network expansion planning.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success. The proposed modifications involved known techniques, such as adding data fields to transmission protocols and adding columns or tables to a relational database to store the new location and QoS data. These tasks were considered straightforward and well within the skill set of a POSITA at the time.

Ground 2: Claims 1-7, 12-18, and 22-25 are anticipated by Scherzer (or obvious over Scherzer in view of Dawson).

  • Prior Art Relied Upon: Scherzer (Application # 2008/0186882) and optionally Dawson (Application # 2003/0216953).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Scherzer alone disclosed every element of these claims. Scherzer taught a client-server system where mobile devices collect and report QoS data for various wireless access points (APs) to a central "radio resource database." This system functioned as a "clearinghouse" by aggregating performance data (e.g., bandwidth, success rate), storing it with geographic location information, and using it to provide users with ranked lists and maps of nearby APs to improve connectivity. Petitioner asserted Scherzer taught both automatic and manual database updates, as well as applications on the mobile devices for obtaining and providing this performance data.
    • Motivation to Combine (for §103 alternative): The motivation to optionally combine Scherzer with Dawson was the same as in Ground 1. This combination was presented to address an alternative interpretation of "clearinghouse" as a system for procuring telecommunications infrastructure, which Dawson explicitly disclosed.
    • Expectation of Success (for §103 alternative): The expectation of success for combining Scherzer with Dawson was based on the same reasoning as in Ground 1, citing the technical feasibility of integrating data from different but related systems.

Ground 3: Claims 8-11 and 19-21 are obvious over Daley, Aaron, Scherzer, and Chmaytelli (optionally in view of Dawson).

  • Prior Art Relied Upon: Daley (Application # 2007/0207800), Aaron (Application # 2008/0305747), Scherzer (Application # 2008/0186882), Chmaytelli (Application # 2006/0253453), and optionally Dawson (Application # 2003/0216953).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims directed to providing localized content and advertising. Petitioner argued that the base combination of Daley, Aaron, and Scherzer already established a system that collected device location information. Chmaytelli was added because it explicitly taught a system for delivering location-specific advertisements to mobile devices using a local ad server, determining device location via GPS or cell tower data, and tracking ad-usage statistics.
    • Motivation to Combine: A POSITA would have been motivated to add the location-based advertising features of Chmaytelli to the network monitoring system of Ground 1. This would leverage the already-collected location data to create a new revenue stream or offer services at a lower cost, which was a well-known business strategy. Since the base system already handled location data, adding another location-based service like advertising was a predictable and logical extension.
    • Expectation of Success: Petitioner argued there was a reasonable expectation of success because the underlying combination already provided location-specific information to mobile devices. Implementing Chmaytelli's teachings would simply involve serving a different type of content (advertisements) based on the same location data, which was a straightforward technical task.

4. Key Claim Construction Positions

  • Petitioner argued that several "means for..." limitations in claims 14, 15, and 22 should be construed as means-plus-function limitations under pre-AIA 35 U.S.C. §112, ¶6.
  • "means for sending instructions..." (Claim 14) and "means for sending a rank ordering..." (Claim 15): Petitioner proposed the function is sending configuration or ranking information from an electronic interface to a wireless device. The corresponding structure was identified as "a computer configured to send information to a wireless device, and equivalents thereof," based on the specification's disclosure of a clearinghouse computer with various interfaces (web, phone, email).
  • "means for determining..." (Claim 22): Petitioner proposed the function is determining the towers or frequencies being used by a device. The corresponding structure was identified as "a computer configured to analyze received and stored information to determine the frequency or tower being used by a device, and equivalents thereof," based on disclosures of a server analyzing device-reported data and comparing it with a tower location database.

5. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-25 of the ’925 patent as unpatentable.