Filed on behalf of Petitioner
`By: Richard F. Giunta
`
`Daniel T. Wehner
`
`Randy J. Pritzker
`
`WOLF, GREENFIELD & SACKS, P.C.
`
`600 Atlantic Avenue
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`Boston, MA 02210
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`Tel: (617) 646-8000
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`Fax: (617) 646-8646
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`RGiunta-PTAB@wolfgreenfield.com
`
`
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`Paper No. __
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`
`RPX Corporation
`Petitioner
`
`v.
`
`MD Security Solutions, LLC
`Patent Owner
`_____________
`
`Case No. TBD
`Patent No. 7,864,983
`_____________
`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,864,983
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.1 et seq.
`
`
`
`
`

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`
`
`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION ............................................................................................. 1
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`II. MANDATORY NOTICES ............................................................................... 2
`
`A. Real Parties-in-Interest ................................................................................ 2
`
`B. Related Matters ............................................................................................ 2
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`C. Counsel and Service Information ................................................................ 3
`
`III. NOTICE OF FEES PAID .................................................................................. 3
`
`IV. CERTIFICATION OF GROUNDS FOR STANDING .................................... 3
`
`V.
`
`IDENTIFICATION OF CHALLENGE AND RELIEF REQUESTED ........... 4
`
`A. Level of Ordinary Skill in the Art ............................................................... 5
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`B. Technology Overview ................................................................................. 6
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`C. The ‘983 Patent ............................................................................................ 7
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`VI. CLAIM INTERPRETATION ........................................................................... 9
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`A. “structure” .................................................................................................. 10
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`B. “telecommunications network” ................................................................. 10
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`C. “handheld telecommunications unit” ........................................................ 11
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`D. “silhouette” ................................................................................................ 11
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`VII. THRESHOLD REQUIREMENT FOR INTER PARTES REVIEW ............... 12
`
`VIII. CLAIM-BY-CLAIM EXPLANATION OF GROUNDS FOR
`UNPATENTABILITY OF CLAIMS 1-20 ..................................................... 12
`
`A. Ground 1: Claims 1-8, 11, and 18-20 Would Have Been Obvious
`over Lee ..................................................................................................... 14
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`
`
`i
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`
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`B. Ground 2: Claims 9, 10 and 12-17 Would Have Been Obvious over
`B. Ground 2: Claims 9, 10 and 12-17 Would Have Been Obvious over
`Lee and Ozer .............................................................................................. 30
`Lee and Ozer ............................................................................................ ..3O
`
`C. Ground 3: Claims 1-8, 11, and 18-20 Would Have Been Obvious
`C. Ground 3: Claims 1-8, 11, and 18-20 Would Have Been Obvious
`over Milinusic and Osann .......................................................................... 37
`over Milinusic and Osann ........................................................................ ..37
`
`D. Ground 4: Claims 9, 10 and 12-17 Are Obvious over Milinusic,
`D. Ground 4: Claims 9, 10 and 12-17 Are Obvious over Milinusic,
`Osann, and Ozer ........................................................................................ 55
`Osann, and Ozer ...................................................................................... ..55
`
`IX. CONCLUSION ................................................................................................ 60
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`IX. CONCLUSION .............................................................................................. ..6O
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`ii
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`
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`CASES
`
`TABLE OF AUTHORITIES
`
`Fresenius USA, Inc. v. Baxter Intern., Inc.,
`582 F.3d 1288 (Fed. Cir. 2009) ............................................................................ 33
`
`MD Security Solutions LLC v. CenturyLink, Inc.,
`No. 6:15-cv-01967 .................................................................................................. 3
`
`MD Security Solutions LLC v. Protection 1, Inc.,
`No. 6:15-cv-01968 .................................................................................................. 3
`
`MD Security Solutions, LLC v. Bright House Networks, LLC,
`No. 6:15-cv-00777 .................................................................................................. 2
`
`STATUTES
`
`35 U.S.C. §102(a) ............................................................................................... 5, 14
`
`35 U.S.C. § 102(b) ................................................................................................... 30
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`35 U.S.C. §102(e) ................................................................................... 5, 14, 30, 38
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`35 U.S.C. § 103(a) ..................................................................................................... 4
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`35 U.S.C. § 311 .......................................................................................................... 1
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`35 U.S.C. § 314(a) ................................................................................................... 12
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`REGULATIONS
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`37 C.F.R. § 42.100(b) .............................................................................................. 10
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`37 C.F.R. § 42.104(a) ................................................................................................. 3
`
`
`
`iii
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`
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`I.
`
`INTRODUCTION
`RPX Corporation (“RPX”) requests inter partes review of claims 1-20 of U.S.
`
`Patent No. 7,864,983 (“the ‘983 patent”) (Ex. 1001) pursuant to 35 U.S.C. § 311.
`
`The claimed subject matter of the ‘983 patent was well known before its filing date.
`
`See, e.g., Declaration of Tal Lavian, Ph.D. (“Lavian”), ¶¶16-17.
`
`The ‘983 patent is directed to a security alarm system for protecting a structure
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`(e.g., home or building) and that can be remotely accessed via a handheld
`
`telecommunications unit such as a cell phone, personal digital assistant (PDA) or
`
`personal computer. (Ex. 1001 at 1:15-30; 5:67-6:6; 13:51-16:47). The security
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`system includes one or more cameras and one or more motion detectors that activate
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`the camera(s) when motion is detected in a monitored area proximate the structure.
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`(Id.) The cameras capture images of the monitored area when the presence of a
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`potential threat is detected and the images can be accessed locally or remotely to
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`allow the potential threat to be evaluated. (Id.)
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`The security system may also analyze images captured by the camera(s) to
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`classify objects detected therein and determine whether the detected objects pose a
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`threat (e.g., by distinguishing between a young child who is likely not a threat and an
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`adult or by distinguishing between a bear or other large animal that may pose a threat
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`and a small animal like a cat that does not). (Id. at 9:35-46). The ‘983 patent
`
`describes several prior art security systems that included object identification (also
`
`1
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`

`
`
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`known as classification) functionality. (Id. at 1:51-2:26).
`
`As discussed below, systems meeting all of the requirements of the claims
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`were known to those of skill in the art before the ‘983 patent was filed. Multiple
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`independent grounds are provided below based upon prior art references that describe
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`security systems that are used to protect structures, including systems that use
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`motion-activated cameras to capture images of monitored areas, perform image
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`analysis to classify objects to distinguish between objects that may pose a threat and
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`those that do not, and that are accessible by the types of remote telecommunications
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`devices described in the ‘983 patent. All of the challenged claims would have been
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`obvious to a person of ordinary skill in the art.
`
`II. MANDATORY NOTICES
`
`A. Real Parties-in-Interest
`
`RPX is the sole real party-in-interest in this proceeding. RPX has not
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`communicated with any client about its intent to contest the validity of this patent, or
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`the preparation, content or filing of this petition. RPX has complete, unilateral
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`control of all aspects of this proceeding and is also solely responsible for all costs and
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`expenses associated with this proceeding.
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`B. Related Matters
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`A decision in this proceeding could affect or be affected by the following cases
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`pending in the United States District Court for the Middle District of Florida and
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`involving the ‘983 patent: MD Security Solutions, LLC v. Bright House Networks,
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`2
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`

`
`
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`LLC, No. 6:15-cv-00777, MD Security Solutions LLC v. CenturyLink, Inc., No. 6:15-
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`cv-01967, and MD Security Solutions LLC v. Protection 1, Inc., No. 6:15-cv-01968.
`
`C. Counsel and Service Information
`
`Lead Counsel
`
`Richard F. Giunta (Registration No. 36,149)
`
`Backup Counsel
`
`Daniel T. Wehner (Registration No. 63,480)
`
`Backup Counsel
`
`Randy J. Pritzker (Registration No. 35,986)
`
`Service Information E-mail: RGiunta-PTAB@wolfgreenfield.com
` DWehner-PTAB@wolfgreenfield.com
` RPritzker-PTAB@wolfgreenfield.com
`
`Post and hand delivery: Wolf, Greenfield & Sacks, P.C.
` 600 Atlantic Avenue
` Boston, MA 02210-2206
` Telephone: 617-646-8000
` Facsimile: 617-646-8646
`
`Counsel for RPX consents to service of all documents via electronic mail.
`
`III. NOTICE OF FEES PAID
`
`Fees are submitted herewith. If any additional fees are due at any time during
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`the inter partes review proceedings, the undersigned authorizes the Office to charge
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`such fees to Deposit Account No. 23/2825.
`
`IV. CERTIFICATION OF GROUNDS FOR STANDING
`
`RPX certifies, pursuant to 37 C.F.R. § 42.104(a), that the ’983 patent is
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`available for inter partes review and that RPX is not barred or estopped from
`
`requesting inter partes review as to the ’983 patent claims identified herein.
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`3
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`

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`
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`V.
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`IDENTIFICATION OF CHALLENGE AND RELIEF REQUESTED
`
`RPX requests cancellation of claims 1-20 of the ‘983 patent. The table below
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`indicates the references, applicable claims, and basis for each Ground.
`
`
`
`REFERENCE(S)
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`CLAIMS
`
`BASIS
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`1 U.S. Pat. Pub. No. 2005/0267605 (“Lee”) (Ex. 1002)
`
`1-8, 11, 18-20 § 103(a)
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`2 Lee (Ex. 1002) and U.S. Pat. Pub. No. 2004/0120581
`
`9, 10, 12-17
`
`§ 103(a)
`
`(“Ozer”) (Ex. 1005)
`
`3 U.S. Pat. No. 7,106,333 (“Milinusic”) (Ex. 1003) and
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`1-8, 11, 18-20 § 103(a)
`
`U.S. Pat. No. 7,253,732 (“Osann”) (Ex. 1004)
`
`4 Milinusic (Ex. 1003), Osann (Ex. 1004), and Ozer
`
`9, 10, 12-17
`
`§ 103(a)
`
`(Ex. 1005)
`
`The Grounds are not redundant for multiple reasons. Although each of the
`
`primary references (Lee and Milinusic) describes a security alarm system that
`
`includes motion-activated cameras that can be controlled by and send images to
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`handheld telecommunications devices, there are differences in the explicit teachings
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`of the references that are relevant to particular claim terms. For example, while Lee
`
`discloses motion detectors that can trigger the activation of cameras, Lee does not
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`explicitly disclose arranging the detectors and cameras to have overlapping fields of
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`view. Thus, an issue is raised in connection with the Lee grounds about whether a
`
`POSA would have considered overlapping the fields of view of cameras and motion
`
`4
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`

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`
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`detectors to have been obvious, whereas no such issue arises in connection with the
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`Milinusic grounds because Milinusic explicitly discloses this feature.
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`Conversely, Milinusic does not explicitly teach that the cameras and motion
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`detectors have fields of view external to a structure. Thus, an issue is raised in the
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`Milinusic grounds about whether a POSA would have considered monitoring the
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`exterior of a structure to be an obvious use of Milinusic’s system, whereas no such
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`issue arises in connection with the Lee grounds because Lee explicitly discloses this
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`feature. Thus, different issues are raised by the grounds so they are not redundant.
`
`In addition, Lee (Grounds 1 and 2) and Milinusic (Grounds 3 and 4) both are
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`prior art under 35 U.S.C. §102(a) and/or 35 U.S.C. §102(e) and could potentially be
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`antedated, but Milinusic’s filing date precede Lee’s by more than three years. It is
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`unclear at this stage whether the patent owner will be able to establish any earlier
`
`invention date, but the three-year difference in filing date makes it far less likely that
`
`Milinusic can be sworn behind than Lee. Grounds 3 and 4 relying on Milinusic
`
`should not be found redundant in view of Grounds 1 and 2 relying on Lee for this
`
`additional reason.
`
`A.
`
`Level of Ordinary Skill in the Art
`
`The ‘983 patent discloses a security alarm system that has one or more motion-
`
`activated cameras, performs image analysis on images captured by the camera(s) and
`
`is accessible over a telecommunications network by a handheld telecommunications
`
`5
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`
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`unit. A person of ordinary skill in the art in the timeframe of the 2006 priority date of
`
`the ‘983 patent (“POSA”) would have had at least a B.S. in Electrical Engineering,
`
`Computer Engineering or Computer Science or the equivalent, along with 2 years of
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`working experience in image processing and/or developing telecommunications
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`systems such as networked computer systems. (Lavian, ¶¶13-14).
`
`B.
`
`Technology Overview
`
`Security alarm systems designed to protect structures such as homes and
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`commercial buildings often include one or more cameras to monitor the structure and
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`capture images of possible threats (e.g., intruders). The camera(s) may provide
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`continuous video surveillance of a monitored area or may be configured to capture
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`images in response to an event (e.g., sound, motion, etc.) detected by a sensor (e.g., a
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`motion sensor, a sound sensor, etc.) monitoring the area.
`
`When an event (e.g., presence of a potential intruder) is detected by the
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`security system, an alarm may be generated to alert personnel either on site (e.g.,
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`residents of a home) and/or located remotely (e.g., homeowners not at home, a
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`security/alarm company, local police, etc.). To reduce false alarms when the
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`security system is triggered by something that is not an actual threat, some security
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`systems analyze one or more images captured by the camera(s) to identify objects in
`
`the image, and generate an alert only when the object is classified as a threat.
`
`6
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`

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`
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`C.
`
`The ‘983 Patent
`
`FIG. 1 of the ‘983 patent, reproduced below, illustrates the components of a
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`security alarm system.
`
`
`The security system includes one or more motion detectors 10 and one or more
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`cameras 12 coupled to the motion detector(s) 10 that activate the camera(s) 12 to
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`record images in response to detecting motion. (Ex. 1001 at 6:48-53; 38-45). The
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`motion detector(s) 10 and camera(s) 12 are mounted on or near a house, a business or
`
`other structure to monitor an area around the exterior of the structure. (Id. at 6:54-
`
`8:22; FIG. 3). The security system includes an on-site computer 14, which includes a
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`processor, and is arranged to receive images from camera(s) 12 and to control the
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`operation of motion detector(s) 10 and/or camera(s) 12. (Id. at 8:31-37; 8:46-59).
`
`Computer 14 may perform image processing to determine whether objects in
`
`captured images are a threat, and generate a countermeasure (e.g., an audible alarm or
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`a communication to a remote location) when the object is identified as a threat. (Id. at
`
`7
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`

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`
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`9:66-10:36). Computer 14 receives control commands from, and provides images to,
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`a handheld telecommunications unit 42 over a telecommunications network. (Id. at
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`11:1-11; 11:31-50).
`
`The ‘983 patent includes twenty total and two independent claims (i.e., claims
`
`1 and 11). Claims 1-10 are directed to an alarm system for protecting a structure and
`
`claims 11-20 are directed to a method of protecting a structure. Claims 1-8, 11, and
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`18-20 (including independent claims 1 and 11) recite components including one or
`
`more cameras, one or more motion detectors coupled to and configured to activate
`
`the cameras upon detection of motion, a processor arranged to control the camera(s)
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`and/or motion detector(s), a telecommunications module to couple the processor to a
`
`telecommunications network, and a handheld telecommunications unit to
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`communicate with the processor over the network. Dependent claims 9, 10, and 12-
`
`17 recite limitations related to an object identification process that derives
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`“silhouettes” of objects in an image to identify an object, and performs an action
`
`based on the object identification.
`
`The ‘983 patent is a continuation of U.S. Patent No. 7,526,105 (“the ‘105
`
`patent”) and claims priority to U.S. Provisional Applications Nos. 60/743,894 filed
`
`March 29, 2006 and 60/804,660 filed June 14, 2006. The independent claims in the
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`‘105 patent include limitations similar to those in claims 9 and 12 of the ‘983 patent
`
`relating to object identification using “silhouettes.” The prior art (“Shiota”) cited
`
`8
`
`

`
`
`
`during prosecution of the ‘105 patent described a security system that continuously
`
`recorded video. (Ex. 1012 at 32). The claims in the ‘105 patent were allowed in
`
`response to arguments that the cited prior art did not disclose cameras with a dormant
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`state in which images are not obtained and an active state triggered when motion is
`
`detected (Ex. 1012 at 11; 32-33).
`
`The ‘983 independent claims replace the “silhouette” limitations of the issued
`
`independent claims of the ‘105 patent with limitations relating to transmitting
`
`commands from, and providing images to, a handheld telecommunications unit. The
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`originally-filed claims in the ‘983 patent were allowed in a first action, with the
`
`Examiner stating that the prior art of record did not disclose transmitting commands
`
`from, and providing images to, a handheld telecommunications unit.
`
`None of the references relied upon in this Petition were of record during
`
`prosecution of either of the applications that issued as the ‘105 and ‘983 patents. The
`
`prior art relied on in each Ground meets the limitations relating to activating a camera
`
`from a dormant state to an active state in response to motion detected by a motion
`
`detector, the use of silhouettes, transmitting commands from, and providing images
`
`to, a handheld telecommunications unit, as well as all of the other limitations of each
`
`of the challenged claims as demonstrated below.
`
`VI. CLAIM INTERPRETATION
`
`Each claim term should be given its broadest reasonable interpretation (“BRI”)
`
`9
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`

`
`
`
`consistent with the specification. 37 C.F.R. § 42.100(b). The BRI for any term
`
`defined in the specification is the definition provided. The BRI for any term not
`
`defined in the specification is the plain and ordinary meaning consistent with the
`
`specification. The BRI for every claim term is applied in this petition.
`
`A.
`
`“structure”
`
`All claims (i.e., claims 1-20) require an alarm system (claims 1-10) or a
`
`method (claim 11-20) for protecting a “structure.” The specification does not define
`
`“structure” but provides several examples of “premises or structure” including a
`
`house, a warehouse, and a business. (Ex. 1001 at 6:54-65). Thus, the BRI of the term
`
`“structure” includes at least the types of structures identified in the specification. The
`
`plain and ordinary meaning, consistent with the specification, of a “structure” to a
`
`POSA in 2006 encompasses at least a house, a “business” (i.e., a commercial
`
`building) and a warehouse. (Id. at 6:58-65; Lavian, ¶23).
`
`B.
`
`“telecommunications network”
`
`All of the claims (i.e., claims 1-20) require a telecommunications module
`
`capable of communications over a “telecommunications network,” which is not
`
`defined in the specification. The specification describes communications between
`
`the handheld telecommunications unit and the processor using a telephone network
`
`(Ex. 1001 at 11:23-30) or a computer network, such as the Internet. (Id. at 13:21-24).
`
`The plain and ordinary meaning, consistent with the specification, of a
`
`10
`
`

`
`
`
`“telecommunications network” to a POSA in 2006 is “a collection of nodes and links
`
`that enable the transmission of information between two computing entities,” and
`
`encompasses at least telephone networks and computer networks, such as the
`
`Internet. (Lavian, ¶24).
`
`C.
`
`“handheld telecommunications unit”
`
`Claims 1-20 all require a “handheld telecommunications unit” for transmitting
`
`commands for a processor via a telecommunications module. “Handheld
`
`telecommunications unit” is a term that is not defined in the specification. However,
`
`the specification provides several examples of handheld telecommunication units
`
`including a cellular telephone, an iPod, a PDA, and a laptop computer. (Ex. 1001 at
`
`6:2-6). The plain and ordinary meaning, consistent with the specification, of a
`
`“handheld telecommunications unit” to a POSA in 2006 encompasses at least the
`
`examples provided in the specification of a cellular telephone, an iPod, a personal
`
`digital assistant (PDA), and a laptop computer. (Lavian, ¶25).
`
`D.
`
`“silhouette”
`
`Claims 9, 10, and 12-17 require a processor arranged to derive a “silhouette” of
`
`any objects in an image. “Silhouette” is not defined in the specification. The term
`
`silhouette generally refers to the shape or outline of an object. (Lavian, ¶26). The
`
`specification describes derivation of a silhouette of an object as being based on a
`
`number of descriptors that are typical for the object (e.g., human body), or on other
`
`11
`
`

`
`
`
`factors which can be used to distinguish, discriminate and/or differentiate the object
`
`from other types of objects. (Ex. 1001 at 9:35-39). The plain and ordinary meaning,
`
`consistent with the specification, of a “silhouette” to a POSA in 2006 relates to a
`
`representation of the outline of an object and encompasses at least representations
`
`derived using the techniques described in the ‘983 specification. (Lavian, ¶26).
`
`VII. THRESHOLD REQUIREMENT FOR INTER PARTES REVIEW
`
`This Petition and the supporting evidence (including Dr. Lavian’s declaration)
`
`demonstrate “a reasonable likelihood that petitioner would prevail with respect to at
`
`least one of the claims challenged in the petition.” 35 U.S.C. § 314(a). All the claims
`
`are obvious over the prior art relied upon in this Petition, as explained in detail by Dr.
`
`Lavian (Ex. 1010), who holds a Ph.D. in computer science from the University of
`
`California, Berkeley where he is a Lecturer and Industry Fellow in the Center of
`
`Entrepreneurship and Technology, an academic center within the College of
`
`Engineering.
`
`VIII. CLAIM-BY-CLAIM EXPLANATION OF GROUNDS FOR
`UNPATENTABILITY OF CLAIMS 1-20
`
`The ‘983 patent includes independent claims 1 and 11. Claims 1 and 11 are
`
`different classes of claims (system and method) but substantively recite many similar
`
`limitations. Exemplary claim 1 is reproduced below. The letters in brackets
`
`preceding the claim elements (e.g., [A]) are used throughout this Petition as shorthand
`
`references for those elements:
`
`12
`
`

`
`
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`1. An alarm system for protecting a structure, comprising:
`[A] at least one motion detector arranged to have a field of view
`external of the structure and including an area proximate the
`structure;
`[B1] at least one camera associated with and coupled to each of said
`at least one motion detector,
`[B2] each of said at least one camera being arranged relative to the
`associated one of said at least one motion detector such that said
`camera has a field of view encompassing at least part of the field of
`view of the associated one of said at least one motion detector,
`[B3] each of said at least one camera having a dormant state in
`which images are not obtained and an active state in which images
`are obtained and being activated into the active state when the
`associated one of said at least one motion detector detects motion;
`[C] a processor coupled to said at least one camera and arranged to
`control said at least one camera and receive the image obtained by
`said at least one camera;
`[D] a telecommunications module coupled to said processor, said
`telecommunications module being capable of communications over
`a telecommunications network; and
`[E] a handheld telecommunications unit for transmitting commands
`for said processor via said telecommunications module to cause
`said processor to provide images to said telecommunications
`module to be transmitted to the telecommunications unit.
`
`Elements A and B1 recite what the specification describes as “standard, off-
`
`the-shelf components.” (Ex. 1001 at 7:19-20 and 8:23). Element B2 describes a
`
`13
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`

`
`
`
`well-known arrangement where camera(s) and motion detector(s) are used to
`
`protect a structure, with each camera having a field of view that overlaps at least
`
`partially with the field of view of any motion detector that will activate the camera.
`
`(Lavian, ¶20). Element B3 recites the well-known functionality of a motion-
`
`activated camera. (Lavian, ¶20). Elements C, D, and E recite well-known
`
`components of a security alarm system that can be controlled from and provide
`
`images to a handheld device over a telecommunications network. (Lavian, ¶21).
`
`A. Ground 1: Claims 1-8, 11, and 18-20 Would Have Been
`Obvious over Lee
`Lee (Ex. 1002)1 is a published U.S. patent application with a filing date of
`
`January 6, 2005 and a publication date of December 1, 2005, and is prior art to the
`
`‘983 patent under 35 U.S.C. §102(a) and (e). Lee discloses a home entertainment
`
`security, surveillance, and automation control system that includes a main control
`
`unit 100, a plurality of remote devices, including a surveillance and security device
`
`(“S&S device”) 212, and various user input devices capable of receiving commands
`
`from a user or homeowner. (abstract, FIG. 1; Lavian, ¶31).
`
`S&S device 212 includes at least one camera module 920 and at least one
`
`sensor module 930. ([0103]-[0104]; [0110]; Lavian, ¶33, 39). Camera modules and
`
`sensor modules both include sensors, which may be motion sensors. (Id.). Camera
`
`modules 920 include both a camera 922 and a sensor 923, which may be a motion
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`1 Unless otherwise indicated, all citations in Section VIII.A are to Ex. 1002 (Lee).
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`detector, coupled to the camera 922. ([0104];[0110]). S&S device 212 can be set to
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`operate in “INTERRUPT mode” in which the camera is activated to record images
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`when the motion detector detects motion in its field of view. ([0107]-[0108]; [0110]-
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`[0111]; Lavian, ¶¶33 and 39-40). Therefore, the camera 922 is associated with and
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`coupled to the motion sensor 923 as claimed in the ‘983 patent. (Lavian, ¶40).
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`To protect a house, which meets the BRI of a structure (§VI.A), a plurality of
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`S&S devices 212 are installed at “the necessary sites inside and outside the house.”
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`([0105]; [0112]). A POSA would have understood that the “necessary sites” for
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`protecting a house include areas proximate the access points to the house (e.g., doors
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`and windows), so that an installation of Lee’s system would have the cameras and
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`motion detectors of the S&S device(s) 212 with fields of view external of and
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`proximate the house to detect motion and capture images of any intruders seeking to
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`enter the house. ([0105]; [0112]; Lavian, ¶33, 38-39). When the system is triggered,
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`the user can be alerted in various ways, including via a text message, a live image
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`sent to a display device 50, a telephone call to the user’s mobile telephone if the user
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`is not home, and/or via remote monitoring by the user over the Internet. ([0111];
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`Lavian, ¶37). A POSA would therefore have understood that Lee’s system is an
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`alarm system for protecting a structure, as claimed in the ‘983 patent. (Lavian, ¶37).
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`Because camera 922 and sensor 923 are disposed in the same module (i.e.,
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`camera module 920) and both are arranged to detect information about an intruder, a
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`POSA would have understood Lee to implicitly disclose that the field of view of the
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`camera 922 encompasses at least part of the field of view of the motion detector 923.
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`([0104];[0028]; FIG. 9; Lavian, ¶41). Alternatively, to achieve Lee’s stated purpose
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`of detecting (via a motion detector) the presence of an intruder in a place and
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`detecting information (via a camera) about an intruder in that place ([0028]; [0108]),
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`and to implement the “INTERRUPT mode” of a camera, it would have been obvious
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`to a POSA to arrange the camera to have a field of view that encompasses at least
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`part of the field of view of its associated motion sensor, as claimed in the ‘983 patent.
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`(Lavian, ¶¶41-42).
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`S&S device 212 may be set to operate in an “ON mode,” an “OFF mode,” or
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`the “INTERRUPT mode.” ([0107]; Lavian, ¶¶33, 44). When S&S device 212 is in
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`“ON mode,” the camera 922 captures images non-stop, whereas in the “OFF mode”
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`the camera is not working. [0107]. In “INTERRUPT mode” the camera is turned
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`“on” (i.e., to obtain images) when a triggered signal is received from the associated
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`sensor and is “off” (i.e., not obtaining images) otherwise. ([0107]-[0108]; Lavian,
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`¶¶33, 44). Thus, a POSA would have recognized that in “INTERRUPT mode,” prior
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`to receiving a triggered signal, the camera is in a “dormant” state and does not obtain
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`images, and when a trigger signal is received, the camera is activated into an “active”
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`state and obtains images. ([0107]-[0108]; Lavian, ¶¶44-45).
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`Lee’s main control unit 100 includes a microprocessor 150 configured to
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`control the system and perform communication with S&S devices 212. (FIGs. 1-2;
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`[0057]-[0058]; [0068]; Lavian, ¶¶32, 46). A POSA would have recognized that
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`microprocessor 150 is a “processor” as claimed in the ‘983 patent and is coupled to
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`camera 922 via a power line communication module 101, power line 200, and camera
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`interface 921. (FIGs. 2 and 9; Lavian, ¶¶46-48). The microprocessor 150 is arranged
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`to receive surveillance data (e.g., images) from the camera in S&S device 212.
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`([0108]; Lavian, ¶48).
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`Main control unit 100 includes multiple telecommunications modules coupled
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`to its processor 150 and capable of communications over a telecommunications
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`network, as claimed in the ‘983 patent. (Lavian, ¶¶49-50; §VI.B, supra). These
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`communications interfaces include an RF/wireless interface 190 ([0067]), a telephone
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`line interface (e.g., Public Switched Telephone Network (PSTN)) 292 ([0062]), a
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`computer network (e.g., LAN/Internet) interface 290 (FIG. 1;[0062]), a cell phone
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`interface ([0060]), and a PDA interface ([0060]). (Lavian, ¶49).
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`The main control unit 100 controls the operation of S&S device 212 in
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`response to commands received from one or more user devices that may include a
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`remote control 281, a cell phone 283, a PDA 282, and a remote computer 291
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`([0057]; [0060];[0062]; [0107]; [0109]; Lavian, ¶32). Each of the cell phone 283,
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`PDA 282, and remote computer 291 is a “handheld telecommunications unit” as
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`claimed in the ‘983 patent and each is explicitly mentioned in the ‘983 as an example
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`of such. (Ex. 1001 5:67-6:6; Lavian, ¶52-53; §VI.B, supra).
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`The claims require that the handheld telecommunications unit transmit
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`commands to cause the processor to provide images to the telecommunications
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`module to be transmitted to the telecommunications unit. Lee’s remote computer 291
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`includes application software that enables the remote computer to both receive video
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`data (which includes images) from the system and send control data to the system.
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`[0062]. A POSA would have understood that the remote computer 291 is a handheld
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`communications unit that transmits commands to the main control unit 100, which
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`causes the microprocessor 150 to provide images to the telecommunications module
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`(e.g., Internet and/or PSTN interface) of the main control unit 100 to be transmitted
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`to the remote computer 291, as claimed in the ‘983 paten