PTAB

IPR2026-00120

NRG Energy Inc v. Malikie Innovations Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Controlling Updates to Internet-Things Devices
  • Brief Description: The ’756 patent discloses systems and methods for remotely managing software updates for Internet of Things (IoT) devices, such as smart appliances. The invention uses a controlling device with a user interface, like a smartphone, to communicate with a server that coordinates the update process for a target IoT device that may lack a sophisticated user interface.

3. Grounds for Unpatentability

Ground 1: Obviousness over Storto - Claims 1-4, 6-10, 12-17, 19-20 are obvious over Storto.

  • Prior Art Relied Upon: Storto (Application # 2017/0351503).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Storto discloses every limitation of the independent claims. Storto describes a remote management system where a smartphone controls firmware updates for network-connected appliances with limited user interfaces. The core four-step process of the ’756 patent’s independent claims was allegedly mapped directly to Storto’s disclosed process. Specifically, Storto’s cloud system (1) receives state information from the controlled appliance, such as connection status and download completion messages; (2) determines the appliance is ready for an update based on this information; (3) receives an "opt-in API call" from the smartphone, which serves as the user's indication to proceed with the update; and (4) sends an "apply update" command to the appliance after receiving the user's approval.
    • Key Aspects: Petitioner contended that Storto addresses the same problem as the ’756 patent—managing updates for IoT devices without user interfaces—using a nearly identical system architecture and process flow. The petition included figures comparing the flowcharts of the ’756 patent and Storto to illustrate the alleged correspondence of each claimed step. Arguments for dependent claims asserted that Storto teaches features like the controlling device being a smartphone, the target device being an IoT device, and checking if the device is idle before applying the update.

Ground 2: Obviousness over Storto and Won - Claims 5, 11, and 18 are obvious over Storto in view of Won.

  • Prior Art Relied Upon: Storto (Application # 2017/0351503) and Won (Application # 2006/0031828).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring the IoT device to be configured to download the update responsive to the indication to begin performing the update. Petitioner argued that Storto’s primary embodiment discloses automatically downloading the update as soon as the device is connected, before receiving user permission to install. However, Petitioner asserted that Won explicitly teaches the alternative method claimed: a control device downloads the necessary files from an update server and transmits them to the target device only after receiving a user's update command.
    • Motivation to Combine: A POSITA would combine Storto with Won’s teachings because it was a well-known, alternative design choice for managing software updates. Petitioner argued that Won is directed to the same problem as Storto—using a controlling device to update a remote device lacking a user interface. A POSITA would have been motivated to modify Storto’s pre-download approach to Won’s download-on-command approach to simplify the update process and reduce the number of required message exchanges between the server and the device (e.g., eliminating a separate download command and download-complete notification).
    • Expectation of Success: Petitioner asserted a high expectation of success, as the proposed modification would involve a simple and predictable programmatic change. Combining the teachings would merely alter the timing of the download step within Storto's existing framework, a routine task for a person of ordinary skill in the art.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of the ’756 patent as unpatentable.