PTAB

IPR2026-00103

Samsung Electronics America Inc v. Massively Broadband LLC

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1. Case Identification

2. Patent Overview

  • Title: Clearinghouse System for Communications Networks
  • Brief Description: The ’794 patent discloses a clearinghouse system that functions as a marketplace to connect telecommunications carriers having infrastructure needs with end-users or property owners having available telecommunications or property assets. The system uses a database to store carrier needs and end-user assets to facilitate matching and notification.

3. Grounds for Unpatentability

Ground 1: Claims 1-10, 12-13, and 17-19 are obvious over Dawson in view of Geranio.

  • Prior Art Relied Upon: Dawson (Application # 2003/0216953) and Geranio (Application # 2004/0002871).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dawson disclosed the core "clearinghouse for communication networks" recited in independent claim 1. Dawson taught a system with a database for managing information related to deploying wireless infrastructure, including records of carrier needs (e.g., "roof rights") and end-user assets (e.g., properties with site addresses). Petitioner asserted that Geranio, which taught a real estate clearinghouse, supplied the missing transactional features, such as generating and transmitting proposed business terms and providing notifications when a suitable match between a buyer and seller is identified.
    • Motivation to Combine: A POSITA would combine Geranio's transactional features with Dawson's telecommunications-focused clearinghouse to create a more comprehensive and efficient system. This integration would streamline the process from assessing potential infrastructure sites (taught by Dawson) to procuring the legal rights for those sites through automated negotiation and contract features (taught by Geranio).
    • Expectation of Success: Petitioner contended that success was expected because Dawson’s system already included search, update, and communication interfaces. Adding Geranio's transactional functionalities would only require standard database extensions and interface modifications, which were well-established techniques at the time.

Ground 2: Claims 20-26 are obvious over Daley, Aaron, and Scherzer, optionally in view of Dawson.

  • Prior Art Relied Upon: Daley (Application # 2007/0207800), Aaron (Application # 2008/0305747), and Scherzer (Application # 2008/0186882), with Dawson (Application # 2003/0216953) optionally included.
  • Core Argument for this Ground:
    • Prior Art Mapping: This combination targeted claims related to collecting performance and quality of service (QoS) data. Petitioner argued Daley disclosed a diagnostic system for monitoring mobile devices, which meets the basic elements of the clearinghouse of independent claim 20. Aaron and Scherzer were argued to teach the collection of performance, QoS, and geographic location information from mobile devices to create and update service quality maps. This combination allegedly disclosed a database including performance/QoS information, records of carriers and end-users, and electronic interfaces for automatically and manually updating the database with information from mobile devices.
    • Motivation to Combine: A POSITA would have been motivated to integrate the teachings of Aaron and Scherzer into Daley's diagnostic system. Adding geographic location and real-time QoS data would significantly improve the ability to diagnose and remediate network performance issues, as it allows correlation of problems with specific locations or infrastructure components. The optional inclusion of Dawson was argued to satisfy the "clearinghouse" term if construed to require infrastructure procurement features.
    • Expectation of Success: Success was expected because the references addressed the same problem (improving wireless network experience) with compatible technologies. Modifying Daley's system to collect additional data points (location and QoS) would involve straightforward enhancements to data transmission protocols and database schemas.

Ground 3: Claims 20-25 are obvious over Scherzer, optionally in view of Dawson.

  • Prior Art Relied Upon: Scherzer (Application # 2008/0186882), with Dawson (Application # 2003/0216953) optionally included.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Scherzer alone disclosed the clearinghouse system of independent claim 20. Scherzer taught a system with a server and database for evaluating the connection quality of mobile devices to wireless access points. This system collected performance and QoS information from mobile devices, stored it in a database associated with specific locations, and used it to provide geographic maps of access points to users. This allegedly met the limitations requiring a database with QoS information, records identifying infrastructure (access points) and end-users (device owners), and public records (geographic maps).
    • Motivation to Combine: The optional combination with Dawson was proposed in the alternative. The motivation was to add Dawson's infrastructure procurement functionalities to a system like Scherzer's, which already managed network performance data. This would allow a carrier to use the performance data to identify areas needing network expansion and then use the procurement tools to facilitate that expansion, creating a unified system for network management and growth.
    • Expectation of Success: Petitioner argued success was expected because the systems were complementary. Integrating Dawson's sales and property management database into Scherzer's performance-monitoring system would involve known database integration techniques.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations adding Aaron to the Dawson/Geranio base to teach mobile updates and adding Chmaytelli to teach location-based advertising.

4. Key Claim Construction Positions

  • Petitioner argued that several terms in the challenged claims should be construed as means-plus-function limitations under pre-AIA 35 U.S.C. §112, ¶6. These constructions were presented as central to the invalidity analysis.
  • "means for sending instructions..." (Claim 23): Petitioner proposed the function is "sending instructions...for configuring or reconfiguring...wireless devices based on a ranking of performance or specific requests of an end user." The corresponding structure was identified as "a computer configured to send information to a wireless device."
  • "means for identifying..." (Claim 30): Petitioner proposed the function is "identifying a geographic location of a mobile or fixed device." The corresponding structure was identified as a "processor or circuitry configured to identify the geographic location of a device via communication with a device's GPS or via derivation from other data."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-32 of the ’794 patent as unpatentable.