Alarm.com Inc.
`
`v.
`
`Vivint, Inc.
`
`IPR2016-00116 IPR2016-00161 IPR2016-00173
`Patent 6,147,601 Patent 6,462,654 Patent 6,535,123
`
`January 31, 2017
`
`Petitioner’s Slide 1
`Petitioner’s Slide 1
`
`Alarm.com Inc. v. Vivint, Inc.
`IPR2016-00116
`Petitioner Alarm.com's Exhibit 1131
`
`
`
`v.
`
`Vivint, Inc.
`
`IPR2016-00116 IPR2016-00161 IPR2016-00173
`Patent 6,147,601 Patent 6,462,654 Patent 6,535,123
`
`January 31, 2017
`
`Petitioner’s Slide 1
`Petitioner’s Slide 1
`
`Alarm.com Inc. v. Vivint, Inc.
`IPR2016-00116
`Petitioner Alarm.com's Exhibit 1131
`
`
`
`Instituted Grounds
`
`Claims Instituted
`
`
`
`Basis
`
`601: 1, 2, 4, 6, 10-13, 15, 17, 22, 23, 25-27,
`29, 33-35, 38
`123: 1-4, 6, 10, 13-15, 17
`601: 7, 19, 28
`123: 5, 16
`601: 5, 8, 9, 21, 30, 31, 37, 39, 40
`601: 20, 41
`123: 7-9, 11, 12, 18-20
`601: 14, 17, 18, 36, 38
`601: 39
`654: 9, 27
`654: 10, 14
`654: 17, 25, 26, 28
`654: 18, 22
`
`Obviousness: Shetty
`
`Obviousness: Shetty and Levac
`
`Obviousness: Shetty and Britton
`
`Obviousness: Shetty, Levac and Britton
`
`Obviousness: Shetty and French
`Obviousness: Shetty, Levac, Britton and French
`Obviousness: Shetty and Garton
`Obviousness: Shetty, Levac and Garton
`Obviousness: Shetty, Garton and Britton
`Obviousness: Shetty, Levac, Garton and Britton
`
`Institution Decision IPR2016-00116, Paper 14 at 46
`Institution Decision IPR2016-00161, Paper 16 at 48
`Institution Decision IPR2016-00173, Paper 14 at 39
`
`Petitioner’s Slide 2
`
`
`
`Issue
`
`Shetty discloses or renders obvious
`user-defined message profiles
`
`Shetty discloses or renders obvious
`remote configuration of message
`profiles
`Shetty discloses or renders obvious
`communication device identification
`codes
`
`Shetty in view of Britton renders
`obvious normal status messages
`
`Shetty in view of Levac renders
`obvious transmitting notifications to
`different communication devices at
`different times
`
`Combining Levac with Shetty was
`obvious
`
`Disputed Issues
`Petition
`Citation
`
`Claims Affected
`
`
`
`601: 1, 22
`654: 9, 17, 25, 27, 28
`123: 1, 13
`601: 1, 22
`654: 9, 17, 25, 27, 28
`123: 1, 13
`
`601: 26
`123: 3, 14
`
`601: 5, 8, 9, 21, 30,
`31, 37, 39, 40
`654: 25
`123: 7
`
`601: 14-16
`654: 19-21
`123: 12-14
`601: 16-17
`654: 21-27
`123: 14-16
`
`601: 26
`123: 21-22
`
`601: 40-43
`654: 42-45
`123: 35-38
`
`601: 19
`
`601: 29-30
`
`Response
`Citation
`
`Reply
`Citation
`
`601: II.B.
`654: III.B.
`123: II.B.
`601: II.A.
`654: III.A.
`123: II.A.
`
`601: II.C.
`123: II.C.
`
`601: I.
`654: I.
`123: I.
`601: II.
`654: II.A-C.
`123: II.
`
`601: III.
`123: III.A-B.
`
`601: IV.
`654: III.C.
`123: III.
`
`601: V.
`654: III.
`123: IV.
`
`601: III.A-
`B.
`
`601: IV.A.
`
`601: 7, 19, 28
`654: 10, 14, 18, 22
`123: 5, 16
`
`601: 31-33
`654: 31-32
`123: 27-28
`
`601: III.C.
`654: IV.
`123: II.D.
`
`601: IV.B.
`654: II.D.
`123: III.C.
`
`Petitioner’s Slide 3
`
`
`
`Undisputed Issues
`
`Petition Citation
`
`
`
`Issue
`
`601: 10-11
`654: 17-18
`123: 10
`601: 11-13
`654: 18-19
`601: 13-16
`654: 19-21
`123: 10-14
`601: 19
`654: 27
`123: 16-17
`601: 44-46
`654: 48-49
`123: 38-40
`
`601: 53-54
`
`654: 32-33
`
`Shetty discloses a sensor determining the state of (a
`parameter of) remote equipment.
`
`Shetty discloses an interface unit that generates and
`forwards exception messages to a computer server.
`Shetty discloses a computer server that receives incoming
`exception messages and sends outgoing exception
`messages to communication devices in response.
`
`Shetty renders obvious transmission of remote equipment
`ID codes.
`
`It was obvious to combine Britton with Shetty (alone or in
`view of the other references).
`
`It was obvious to combine French with Shetty (alone or in
`view of the other references).
`It was obvious to combine Garton with Shetty (alone or in
`view of the other references).
`
`Petitioner’s Slide 4
`
`
`
`Sandelman Overview
`
`Petitioner’s Slide 5
`
`
`
`Claim Construction
`
`Board Construction
`
`Patent Owner
`Construction
`
`“message profile containing outgoing message
`routing instructions”
`“data record including instructions specifying at
`least one communication device to which an
`outgoing message can be routed in response to
`an incoming exception message”
`“data record including instructions specifying
`which communication device associated with
`which individuals an outgoing message can
`be routed in response to an incoming exception
`message”
`
`Petitioner’s Slide 6
`
`
`
`Message Profile Containing
`Outgoing Message Routing Instructions
`
`’601 Patent, Claim 1 (excerpt)
`c) enabling a user to remotely configure or modify a
`user-defined message profile containing outgoing
`message routing instructions, the user-defined
`message profile being storable on the computer server;
`d) determining whether an incoming message is an
`incoming exception message indicative of improper
`operation of the piece of remote equipment;
`e) if it is determined in step d) that an incoming message
`is an incoming exception message, forwarding at least
`one outgoing exception message based on the
`incoming message to at least one user-defined
`communication device specifiable in the user-
`defined message profile . . .
`’601 Patent, IPR2016-00116 Ex. 1101 at 8:58-9:3
`
`Petitioner’s Slide 7
`
`
`
`Shetty’s User Profiles
`
`A user profile database 106 contains information relating to all
`users of the data manager including a user profile which defines
`which events will require that the user be notified (see below).
`Shetty, IPR2016-00116 Ex. 1103 at 2:18-21
`
`. . . comparing said event signals to a profile of events
`corresponding to the user, and delivering a notification signal to
`the user if the event signals match the profile.
`Shetty, IPR2016-00116 Ex. 1103 at 1:33-35
`
`Additionally, each user may have multiple aliases or profiles.
`Shetty, IPR2016-00116 Ex. 1103 at 2:49-51
`
`For example, assume there are two users: user one and user two.
`Each user has two profiles: user one—profile one, user one—
`profile two, user two—profile one, and user two—profile two.
`Each profile of each user has a different set of events which must
`occur before the user is notified.
`
`Shetty, IPR2016-00116 Ex. 1103 at 2:53-57
`
`Petitioner’s Slide 8
`
`
`
`Sandelman and Shetty
`
`Sandelman
`
`Shetty
`
`Petitioner’s Slide 9
`
`
`
`Shetty’s Configuration of User Profiles
`
` A
`
` user interface 110 allows a user to access both the user profile
`database 106 and the event database 108.
`Shetty, IPR2016-00116 Ex. 1103 at 2:34-35
`
`A PHOSITA in 1998 would have recognized that the purpose of
`user access to Shetty’s user profile database would have at least
`been to configure and modify the user profiles.
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 82
`
`Petitioner’s Slide 10
`
`
`
`Plain Meaning of Access
`
`Exhibit
`
`Title
`
`
`
`Definition
`
`1126.0006
`
`1127.0005
`
`1128.0006
`
`1129.0005
`
`The New IEEE Standard Dictionary
`of Electrical and Electronics Terms,
`Fifth ed. (1993)
`
`IBM Dictionary of Computing,
`Tenth ed. (1994)
`McGraw-Hill Dictionary of
`Scientific and Technical Terms,
`Fifth ed. (1994)
`Microsoft Computer Dictionary,
`Fourth ed. (1999)
`
`“access (1). (A) The process of obtaining data
`from or placing data into a storage device. . . .
`(B) To obtain data from or place data into a
`storage device as in (A).”
` “access . . . (4) To obtain data from or put data
`in storage.”
`
`“access . . . [COMPUT SCI] The reading of data
`from storage or the writing of data into storage.”
`
`“access vb. To gain entry to memory in order to
`read or write data.”
`
`Q. I understand that’s what it could mean, but could [access]
`also mean update or modification as Elmasri’s database
`book explained?
`A. There are different types of access operations, retrieval or
`update, as it says.
`Q. And you agree with that?
`A. Yes.
`
`Denning Dep. Tr., IPR2016-00116 Ex. 1118 at 39:13-39:20
`
`Petitioner’s Slide 11
`
`
`
`Shetty Discloses Write Access
`
`Q. Yep. If a user were to input information relating to fleet
`or machine data, that would cause data to be written to
`the fleet and machine database means 104; correct?
`A. Yes.
`Q. So users at least have write access to the fleet and
`machine database 104; correct?
`A. Yes. I stand corrected. Earlier I referred to that cylinder
`incorrectly.
`Q. And a POSITA would have had the necessary knowledge
`and skill to implement read, write access to the fleet and
`machine database, correct?
`A. Yes.
`
`Denning Dep. Tr., IPR2016-00116 Ex. 1118 at 50:3-15
`
`Petitioner’s Slide 12
`
`
`
`Shetty’s Purpose
`
`However, with the large increase in the number of
`sensors and data being collected, the amount of data
`to be analyzed becomes unmanageable.
`
`Additionally, different persons, for example, the
`operator, the owner, etc. . . . , may have need for
`different information.
`
`The present invention is directed to overcoming one
`or more of the problems identified above.
`
`Shetty, IPR2016-00116 Ex. 1103 at 1:18-25
`
`Petitioner’s Slide 13
`
`
`
`Shetty Teaches Customizable Profiles
`
`Additionally, each user may have multiple aliases or
`profiles. Each alias has a different purpose and
`therefore a different list of events which trigger
`notification of the user.
`
`For example, assume there are two users: user one and
`user two. Each user has two profiles: user one—
`profile one, user one—profile two, user two—profile
`one, and user two—profile two. Each profile of each
`user has a different set of events which must occur
`before the user is notified.
`
`Each profile can be predefined for a different event or
`different set of events. Each profile may also trigger a
`different mode or modes of communication (page,
`Email, fax).
`
`Shetty, IPR2016-00116 Ex. 1103 at 2:50-61
`
`Petitioner’s Slide 14
`
`
`
`Shetty’s Remote Workstations
`
`[T]he computer that receives machine events,
`compares the events to user profiles, and notifies
`users is the “data manager.”
`. . .
`Because the third work station 410 and the database
`server work station 406 receive events from the
`monitored machines, store those events, and issue
`notifications to users, it is clear that remote work
`station 410 and database workstation 406 are the
`“data managers” described in connection with
`Figure 1. And as taught by Shetty, and as clearly
`shown in Figure 1, users access the databases of the
`. . .
`data manager, including the “user profile database
`106,” via a “user interface 110.”
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 82
`
`Petitioner’s Slide 15
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 83
`
`Users can also access the data stored on the third
`work station 406 [sic] and receive electronic mail via
`first and second remote work stations 420, 422.
`
`Events may be stored on both the third work station
`410 and the database server work station 406. Each
`work station 406, 410 may analyze the events and
`notify the users as described above.
`Shetty, IPR2016-00116 Ex. 1103 at 4:9-15
`
`
`
`Motivation to Extend Shetty
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 83
`
`Petitioner’s Slide 16
`
`In particular, remote configuration would have been
`desirable because the patent specifically addressed the
`problem of remote user notification, rather than
`notification at the central data manager computer as was
`more common in earlier systems.
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 83
`
`
`
`Users of a notification system based on Shetty would
`desire and benefit from the ability to remotely
`configure the user profiles on the data manager in the
`same manner that they would remotely configure other
`alarm notification systems already in common use.
`
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 84
`
`Further, enabling remote configuration of user profiles
`in Shetty’s system would have required only routine
`application of networking and user interface techniques
`that were already well-known in the art.
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 85
`
`
`
`Communication Device Identification Codes
`
`’601 Patent, Claim 26
`A system according to claim 22, said system monitoring
`a plurality of pieces of equipment, each piece having an
`identification code, said server further comprising:
`
` a
`
` first memory on which equipment identification codes
`of all monitored equipment are stored;
`
` a
`
` second memory in which communication device
`identification codes of all of said user-defined
`communication devices are stored, said communication
`device identification codes being configured in a
`plurality of said user-defined message profiles.
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 11:20-29
`
`Petitioner’s Slide 17
`
`
`
`Sandelman’s Communication Devices
`
`Based on the configuration of the user’s message
`profile, the outgoing exception message (or
`messages) is then delivered to the specified end
`device or devices. FIGS. 3a-d show a more detailed
`view of the various outbound links 12a-d that
`connect the server 1 to the various electronic media.
`In FIG. 3a, server 1 sends the message over a
`telephone line 18a to the Internet 122 and deposits
`the message in the user’s e-mail box 6. In FIG. 3b,
`server 1 sends the message over a telephone line 18b
`through the public telephone switched network
`(PTSN) 19 to the user’s fax machine 7. In FIG. 3c,
`server 1 sends the message over a telephone line 18c
`to the user’s pager service 53 and thence to the
`user’s pager or PCS 8. In FIG. 3d, server 1 sends
`the message over a telephone line 18d through the
`PTSN 19 to the user’s voice mail box 9.
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 6:7-21
`
`Petitioner’s Slide 18
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 137
`
`[B]ecause the ’601 Patent teaches that an “email
`receiving device” is an “email box,” a logical
`device rather than a physical device, an email
`address is the only identifier capable of
`identifying the email receiving “device.”
`
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 157
`
`
`
`Sandelman’s Communication Devices
`
`’601 Patent, IPR2016-00116 Ex. 1101 Figs. 3a-3d
`
`Petitioner’s Slide 19
`
`
`
`Sandelman’s Communication Device Identification Codes
`
`The contractor is provided with an account on the message
`delivery system that he can access via the Internet. The
`contractor sets up the specific parameters of which
`exception conditions are reported to which individuals.
`The contractor also sets up by which media (fax, e-
`mail, PCS) these individuals are to be notified. Multiple
`individuals may be alerted as to a exception condition. All
`of this data constitutes the contractor’s message profile.
`’601 Patent, IPR2016-00116 Ex. 1101 at 4:39-47
`
`An example of the system’s operation is as follows. When
`a user-contractor 121 first signs up with the system 50, he
`receives an account on the electronic message delivery
`server 1. Via the Internet, the contractor 121 is prompted
`through software to enter the pager numbers, cellular
`telephone numbers, facsimile machine numbers, and
`Internet addresses of any individuals who are to be
`contacted in the event of an exception condition in
`building equipment 2-5 for which the contractor is
`responsible. The user-contractor 121 may also set the
`software to notify him of the periodic successful routine
`status check messages conveyed from equipment 2-5.
`’601 Patent, IPR2016-00116 Ex. 1101 at 7:50-61
`
`Petitioner’s Slide 20
`
`
`
`Sandelman’s Discussion of Communication Device
`Identification Codes
`
`Mr. Zatarain
`141. I have carefully reviewed the ’601 Patent, and its only
`detailed disclosure concerning CDICs identifies “cellular
`telephone numbers ... and Internet addresses” as examples of
`such codes:
`“An example of the system’s operation is as follows.
`When a user-contractor 121 first signs up with the
`system 50, he receives an account on the electronic
`message delivery server 1. Via the Internet, the
`contractor 121 is prompted through software to
`enter the pager numbers, cellular telephone
`numbers, facsimile machine numbers, and Internet
`addresses of any individuals who are to be contacted
`in the event of an exception condition in building
`equipment 2-5 for which the contractor is responsible.
`The user-contractor 121 may also set the software to
`notify him of the periodic successful routine status
`check messages conveyed from equipment 2-5. Ex.
`1101 at 7:50-61.”
`
`
`Zatarain Reply Decl., IPR2016-00116 Ex. 1130 ¶ 141
`
`Mr. Denning
`Q. No. I’m asking what communication device
`identification codes are taught by the ’601
`Patent?
`
`
`A. The ’601 specifically addresses your question in
`column seven, line 53. Actually, go back up to
`the top. “An example of the system’s operation
`is as follows. When a user-contractor first signs
`up with the system, he receives an account on
`the electronic message delivery server 1. Via the
`Internet, the contractor is prompted through
`software to enter the pager numbers, cellular
`phone numbers, fax machine numbers and
`Internet addresses of individuals who are to
`be contacted in the event of an exception
`condition.”
`
`
`
`Denning Dep. Tr., IPR2016-00116 Ex. 1118 at 79:9-22
`
`Petitioner’s Slide 21
`
`
`
`Levac Overview
`
`
`The present invention relates to an innovative
`system and method for automatically
`conveying a message generated by one of a
`variety of message sources to designated
`message recipients who receive
`communications via at least one of many
`types of communication devices, such as a
`character display, which display messages
`using different formats and which may be
`located at various communication
`destinations.
`
`Levac, IPR2016-00116 Ex. 1105 at 2:20-28
`
`Petitioner’s Slide 22
`
`
`
`Motivation to Combine Levac with Shetty
`
`[B]oth references are directed at solving the same
`general problem of delivering notifications to users
`from a central computer server, with the notification
`messages based on data collected by the server from
`remote sources.
`
`
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 114
`
`Shetty taught that outgoing messages were sent to
`different types of user devices, but provided no
`implementation details. Levac provided
`implementation details suitable for a wide variety of
`message notification applications.
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 115
`
`Levac taught that users could utilize a .msa file to
`specify the content of a message and the times that a
`particular message would be sent. These features
`were natural extensions of Shetty’s disclosure of user
`customization of notification options.
`Zatarain Decl., IPR2016-00116 Ex. 1107 ¶ 116
`
`Petitioner’s Slide 23
`
`
`
`Levac Message Parameters
`
`6. RUNTIME: identifies the period of time the
`message should run; consists of the size of the
`RUNTIME structure followed by the RUNTIME
`structure; required stream.
`
` …
`
`
`
`
`7. VARSTART: describes the variable conditions that
`must be satisfied before triggering a message to run;
`consists of the length of the VARSTART stream
`followed by the VARSTART stream; optional stream.
`Levac, IPR2016-00116 Ex. 1105 at 5:7-38
`
`Petitioner’s Slide 24
`
`
`
`“Normal Status” Claims
`
`’601 Patent, Claim 5
`A method according to claim 1, wherein step (e)
`further comprises the step of determining whether an
`incoming message is a normal status message
`indicative of proper operation of the piece of
`remote equipment.
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 11:20-29
`
`’123 Patent, Claim 18
`A system according to claim 14, wherein said server
`periodically generates a normal status message to
`said user-defined communications devices if an
`information source reports a normal status
`condition, said normal status message including an
`identification code of the respective information
`source.
`
`’123 Patent, IPR2016-00173 Ex. 1101 at 18:28-33
`
`Petitioner’s Slide 25
`
`
`
`Sandelman’s “Unit Checking in” Messages
`
`
`In addition to notifying contractors when a problem arises,
`the interface may be programmed to check in once a day
`with an “all systems okay” message. This “okay” message
`also gets routed to the message delivery system.
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 4:60-64
`
`The missing message subroutine compares the entire list
`to the list of HVAC interfaces that actually checked in as
`“okay”. If an interface failed to check in “okay” the
`message delivery system sends out the appropriate
`messages…
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 5:4-7
`
`Petitioner’s Slide 26
`
`
`
`Britton’s “Check-In” Messages
`
`
`Each protected premise panel 32 is configured
`to initiate its own “check-in” message. The
`receiving equipment 34 is configured to
`acknowledge the receipt of the check-in
`message…
`
`Britton, IPR2016-00116 Ex. 1104 at 8:6-9
`
`If, however, the receiving equipment 34 fails
`to receive a scheduled or appointed Next
`Check-In Message within the proscribed lapse
`of time, it generates an “alert” signal for that
`protected premise.
`
`Britton, IPR2016-00116 Ex. 1104 at 8:49-52
`
`Petitioner’s Slide 27
`
`
`
`Sandelman and Britton
`
`Sandelman (’601 Patent)
`The missing message subroutine compares the entire
`list to the list of HVAC interfaces that actually checked
`in as “okay”. If an interface failed to check in “okay” the
`message delivery system sends out the appropriate
`messages…
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 4:60-64
`
`The missing message subroutine compares the entire
`list to the list of HVAC interfaces that actually checked
`in as “okay”. If an interface failed to check in “okay” the
`message delivery system sends out the appropriate
`messages…
`
`’601 Patent, IPR2016-00116 Ex. 1101 at 5:4-7
`
`
`
`Britton
`
`Each protected premise panel 32 is configured to
`initiate its own “check-in” message. The receiving
`equipment 34 is configured to acknowledge the receipt
`of the check-in message…
`
`
`Britton, IPR2016-00116 Ex. 1104 at 8:6-9
`If, however, the receiving equipment 34 fails to receive
`a scheduled or appointed Next Check-In Message
`within the proscribed lapse of time, it generates an
`“alert” signal for that protected premise.
`
`
`Britton, IPR2016-00116 Ex. 1104 at 8:49-52
`
`Petitioner’s Slide 28
`
`
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