Trials@uspto.gov
`571-272-7822
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` Paper 9
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` Entered: March 30, 2017
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SECURENET TECHNOLOGIES, LLC,
`Petitioner,
`
`v.
`
`ICONTROL NETWORKS, INC.,
`Patent Owner.
`____________
`
`Case IPR2016-01919
`Case IPR2016-01920
`Patent 8,473,619 B21
`____________
`
`
`
`Before KEN B. BARRETT, PATRICK M. BOUCHER, and
`MINN CHUNG, Administrative Patent Judges.
`
`CHUNG, Administrative Patent Judge.
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314(a) and 37 C.F.R. § 42.108
`
`
`1 This Order will be entered in each case. The parties are not authorized to
`use this caption style.
`
`
`571-272-7822
`
` Paper 9
`
`
` Entered: March 30, 2017
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SECURENET TECHNOLOGIES, LLC,
`Petitioner,
`
`v.
`
`ICONTROL NETWORKS, INC.,
`Patent Owner.
`____________
`
`Case IPR2016-01919
`Case IPR2016-01920
`Patent 8,473,619 B21
`____________
`
`
`
`Before KEN B. BARRETT, PATRICK M. BOUCHER, and
`MINN CHUNG, Administrative Patent Judges.
`
`CHUNG, Administrative Patent Judge.
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314(a) and 37 C.F.R. § 42.108
`
`
`1 This Order will be entered in each case. The parties are not authorized to
`use this caption style.
`
`
`
`IPR2016-01919
`IPR2016-01920
`Patent 8,473,619 B2
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`I. INTRODUCTION
`SecureNet Technologies, LLC (“Petitioner”) filed a Petition
`requesting an inter partes review of claims 1–9, 12–16, 19, 23–28, 32, 34,
`42–47, 54–57, and 59–62 of U.S. Patent No. 8,473,619 B2 (Ex. 1001, “the
`’619 patent”). IPR2016-01919, Paper 1 (“Pet.”). Petitioner filed another
`Petition challenging claims 17, 18, 20–22, 29–31, 33, 35–41, 48–53, and 58
`of the same patent. IPR2016-01920, Paper 1 (“’1920 Pet.”).2 Icontrol
`Networks, Inc. (“Patent Owner”) filed a Preliminary Response in each case.
`IPR2016-01919, Paper 6 (“Prelim. Resp.”); IPR2016-01920, Paper 6
`(“’1920 Prelim. Resp.”). We have authority to determine whether to
`institute an inter partes review. 35 U.S.C. § 314(b); 37 C.F.R. § 42.4(a).
`The standard for instituting an inter partes review is set forth in
`35 U.S.C. § 314(a), which provides that an inter partes review may not be
`instituted unless the information presented in the Petition “shows that there
`is a reasonable likelihood that the petitioner would prevail with respect to at
`least 1 of the claims challenged in the petition.” Upon consideration of the
`Petitions and the Preliminary Responses, we conclude that the information
`presented in the Petitions does not establish a reasonable likelihood that
`Petitioner would prevail in showing the unpatentability of any of the claims
`challenged in the Petitions on the grounds set forth therein. Accordingly, we
`deny Petitioner’s request to institute an inter partes review in each Petition.
`
`
`2 Because of the substantial overlap in the two proceedings, we will cite only
`to the Petition, the Preliminary Response, Papers, and Exhibits in IPR2016-
`01919 unless otherwise noted.
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`II. BACKGROUND
`A. Real Party In Interest
`SecureNet Technologies, LLC identifies itself as the real-party-in-
`interest. Pet. 1.
`
`B. Related Proceedings
`Petitioner asserts that the ’619 patent has been asserted in the
`following patent infringement case: Icontrol Networks, Inc. v. SecureNet
`Technologies, LLC, No. 15-807-GMS (D. Del.). Pet. 1. Petitioner also filed
`petitions seeking inter partes review of certain claims of U.S. Patent
`No. 8,073,931 in IPR2016-01909 and of U.S. Patent No. 8,478,844 in
`IPR2016-01911 and IPR2016-01916. Pet. 1–2; Paper 4, 2.
`
`
`III. THE ’619 PATENT
`A. Described Invention
`The ’619 patent describes an add-on security system that integrates
`with the conventional security systems existing at the premises to provide
`remote monitoring and control functions. Ex. 1001, Abstract, col. 3, ll. 45–
`62. According to the ’619 patent, the remote monitoring and control
`functions are provided by introducing a combination of two interconnected
`modules: a gateway and a security server. Id. at col. 6, l. 66–col. 7, l. 3.
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`Figure 1 of the ’619 patent is reproduced below.
`
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`Figure 1 shows a block diagram of an integrated system in an exemplary
`embodiment of the ’619 patent. Id. at col. 3, ll. 7–8, col. 6, ll. 53–54. As
`shown in Figure 1, integrated system 100 includes gateway 102 and security
`servers 104 coupled to conventional home security system 110. Id. at col. 6,
`ll. 54–57; see also col. 4, ll. 34–40 (describing the integrated system as
`comprising a gateway (also referred to as an iHub gateway) and security
`servers (also referred to as iConnect servers)). At a customer’s home or
`business, the gateway connects and manages home security and monitoring
`devices. Id. at col. 6, ll. 57–59. The gateway also communicates over
`communication network 108 with the security servers located in the service
`provider’s data center 106. Id. at col. 6, ll. 59–64. The combination of the
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`gateway and the security servers enables the users to remotely monitor the
`premises and control the premises’ security system by using remote client
`devices 120, such as PCs and mobile devices. Id. at col. 6, l. 66–col. 7, l. 27.
`The gateway integrates into a home network and communicates with
`the home security panel in wired and wireless installations. Id. at col. 4,
`ll. 37–40, col. 11, l. 53–55. The gateway supports various wireless protocols
`and can interconnect with home security control panels over a wireless
`communication link. Id. at col. 11, 58–60. Figure 13 of the ’619 patent is
`reproduced below.
`
`
`Figure 13 shows a block diagram of an integrated security system wirelessly
`interfacing to a home or business security system. Id. at col. 23, ll. 19–20.
`As shown in Figure 13, gateway 1320 is coupled to security system 1310,
`which may be any type of home or business security system. Id. at col. 23,
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`ll. 21–22, 34–35. Security system 1310 includes RF-capable wireless
`security panel (WSP) 1311 that acts as the master controller for security
`system 1310. Id. at col. 23, ll. 38–41. Gateway 1320 monitors and controls
`WSP 1311 and associated wireless devices 1313 and 1314 of security system
`1310 over RF link 1370 using wireless transceiver 1325. Id. at col. 24,
`ll. 14–23. As shown in Figure 13, gateway 1320 includes WSP manager
`1323, device manager 1324, and wireless protocol manager 1326. Id. at
`col. 24, ll. 4–5, Fig. 13. These components in conjunction implement
`interface protocols and algorithms to communicate with security system
`1310. Id. at col. 24, ll. 4–14.
`Figure 12 (not reproduced herein) illustrates a method of integrating
`the gateway with an existing security system in an exemplary embodiment.
`Id. at col. 22, ll. 17–19. Upon power up, the gateway initiates software and
`RF sequence 1220 to locate an existing security system by finding the
`wireless security panel of the security system. Id. at col. 22, ll. 23–25,
`Fig. 12. The gateway and installer then initiate sequence 1230 “to ‘learn’
`the gateway into the security system,” followed by sequence 1240 “to
`discover and learn the existence and capabilities” of the devices within the
`existing security system. Id. at col. 22, ll. 25–30. Figure 14 (not reproduced
`herein) is a flowchart that illustrates “wirelessly ‘learning’ the [g]ateway
`into an existing security system and discovering extant sensors.” Id. at
`col. 24, l. 66–col. 25, l. 2. Upon power up, the gateway initiates sequences
`1420 and 1425 to identify WSPs 1311 and wireless devices 1313, including
`all sensors in the existing security system. Id. at col. 25, ll. 2–6, Fig. 14
`(sequence 1420, sequence 1425 (“Use Wireless transceiver to find all
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`sensors”)). In another embodiment, the gateway is automatically installed
`with the security system by automatically discovering devices at the
`premises, such as sensors and cameras, and adding the discovered devices to
`the network of the integrated system. Id. at col. 25, ll. 44–45, 55–58.
`After the gateway has completed the discovery and learning of the
`sensors and other devices and has been integrated into the existing security
`system, the integrated security system becomes operational. Id. at col. 22,
`ll. 41–44. The gateway has the ability to listen to network traffic and keep
`track of the status of all devices in the integrated system. Id. at col. 26,
`ll. 44–47, col. 27, ll. 6–8. The gateway utilizes the sensor updates, state
`changes, and supervisory signals of the network to maintain a current system
`of the premises being protected by the integrated system. Id. at col. 27,
`ll. 8–10. This data is sent to the security system server and stored in a
`database for use by server components. Id. at col. 27, ll. 11–13.
`As discussed above, Figure 1 illustrates a gateway communicating
`with a security server over a communication network. Figure 2 (not
`reproduced herein) provides a more detailed illustration of the components
`of the security server. Id. at col. 7, ll. 34–36, Fig. 2. According to the ’619
`patent, the server components provide access to, and management of, the
`objects associated with the integrated security system installation. Id. at
`col. 8, ll. 29–31. Objects monitored by the gateway within the network
`where the gateway is located (i.e., the site or premises) are called “devices,”
`which include sensors, cameras, home security panels, and other automation
`devices. Id. at col. 8, ll. 31–35, 37–41. The server components, identified as
`iConnect Business Components in Figure 2, store information about the
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`objects that are managed by the server. Id. at col. 9, ll. 47–49. For example,
`the iConnect Business Components has an interface, called DeviceConnect
`260 (shown in Figure 2), to define the properties of the new devices that
`have been added to the integrated security system at the premises, including
`how the devices can be managed. Id. at col. 10, ll. 18–23. Common types
`of supported devices include sensors, home security panels, and IP cameras.
`Id. at col. 10, ll. 23–28.
`As shown in Figures 1 and 2, the users or customers use client devices
`120, such as a PC, a web browser, or a mobile device, to connect to the
`security servers to remotely monitor, control, and manage the security
`system at the premises. Id. at col. 6, l. 66–col. 7, l. 27, col. 7, l. 31–col. 8,
`l. 11, Figs. 1, 2.
`
`B. Illustrative Claim
`Of the challenged claims, claims 1, 60, and 61 are independent.
`Claim 1 is illustrative of the challenged claims and is reproduced below with
`the key disputed limitations emphasized in italics and added paragraph
`breaks and indentations for the “wherein” clauses.
`1.
`A system comprising:
`a gateway located at a first location;
`a connection management component coupled to the
`gateway and automatically establishing a wireless coupling with
`a security system installed at the first location, the security
`system including security system components,
`wherein the connection management component forms a
`security network by automatically discovering the security
`system components and integrating communications and
`functions of the security system components into the
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`security network; and
`a security server at a second location different from the
`first location,
`wherein the security server is coupled to the gateway,
`wherein the gateway receives security data from the
`security system components, device data of a plurality of
`network devices coupled to a local network of the first
`location that is independent of the security network, and
`remote data from the security server,
`wherein
`the gateway generates processed data by
`processing at the gateway the security data, the device
`data, and the remote data,
`wherein the gateway determines a state change of the
`security system using the processed data and maintains
`objects at the security server using the processed data,
`wherein the objects correspond to the security system
`components and the plurality of network devices.
`
`Ex. 1001, col. 46, ll. 29–54.
`
`IV. PETITIONER’S CHALLENGES
`A. Prior Art Cited in Petitioner’s Challenges
`Petitioner cites the following references in its challenges to
`patentability:
`
`Reference and Relevant Dates
`
`Designation Exhibit No.
`
`U.S. Patent Application Pub. No. 2004/0260427
`Al (filed Apr. 8, 2004; published Dec. 23, 2004) Wimsatt
`U.S. Patent No. 6,580,950 B1 (filed Apr. 28,
`2000; issued June 17, 2003)
`
`Johnson
`
`Ex. 1004
`
`Ex. 1005
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`Reference and Relevant Dates
`
`Designation Exhibit No.
`
`U.S. Patent No. 4,951,029 (filed Feb. 16, 1988;
`issued Aug. 21, 1990)
`
`U.S. Patent Application Pub. No. 2003/0062997
`A1 (filed Oct. 2, 2001; published Apr. 3, 2003)
`
`U.S. Patent No. 6,748,343 B2 (filed Sept. 28,
`2001; issued June 8, 2004)
`
`Severson
`
`Ex. 1006
`
`Naidoo
`
`Ex. 1007
`
`Alexander
`
`Ex. 1008
`
`U.S. Patent Application Pub. No. 2003/0137426
`A1 (filed Jan. 17, 2003; published July 24, 2003) Anthony
`
`Ex. 1009
`
`B. Asserted Grounds of Unpatentability
`Petitioner asserts the following grounds of unpatentability in
`IPR2016-01919 (Pet. 3):
`
`Claims Challenged
`
`Statutory Basis
`
`References
`
`1–9, 12–16, 19, 23–28, 32,
`34, 42–47, 54–57, 59–62
`
`§ 103(a)
`
`Wimsatt, Johnson, and
`Severson
`
`
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`Petitioner asserts the following grounds of unpatentability in
`IPR2016-01920 (’1920 Pet. 3):
`
`Claims Challenged
`
`Statutory Basis
`
`References
`
`17, 18, 21, 22, 29–31, 33,
`36, 58
`
`20, 35
`
`§ 103(a)
`
`§ 103(a)
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`Wimsatt, Johnson, Severson,
`and Naidoo
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`Wimsatt, Johnson, Severson,
`Naidoo, and Anthony
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`Claims Challenged
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`Statutory Basis
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`References
`
`37–41, 48–53
`
`§ 103(a)
`
`Wimsatt, Johnson, Severson,
`Naidoo, and Alexander
`
`
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`V. CLAIM CONSTRUCTION
`In an inter partes review, claim terms in an unexpired patent are given
`their broadest reasonable construction in light of the specification of the
`patent in which they appear. 37 C.F.R. § 42.100(b); see Cuozzo Speed
`Techs., LLC v. Lee, 136 S. Ct. 2131, 2144 (2016) (holding that 37 C.F.R.
`§ 42.100(b) “represents a reasonable exercise of the rulemaking authority
`that Congress delegated to the . . . Office”). Under the broadest reasonable
`interpretation standard, and absent any special definitions, claim terms
`generally are given their ordinary and customary meaning, as would be
`understood by one of ordinary skill in the art, in view of the specification. In
`re Translogic Tech. Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007).
`Petitioner does not propose any claim constructions in these
`proceedings. Pet. 4–5. Patent Owner criticizes Petitioner’s approach but
`does not propose its own construction for any claim term. Prelim. Resp. 8–
`9. For purposes of this decision, we need not construe any claim term
`explicitly in order to determine whether there is a reasonable likelihood of
`Petitioner prevailing with respect to the challenged claims. See 35 U.S.C.
`§ 314(a); Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803
`(Fed. Cir. 1999) (“[O]nly those terms need be construed that are in
`controversy, and only to the extent necessary to resolve the controversy.”).
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`VI. ANALYSIS OF PETITIONER’S PRIOR ART CHALLENGES
`A. Obviousness over Wimsatt, Johnson, and Severson
`Petitioner contends claims 1–9, 12–16, 19, 23–28, 32, 34, 42–47, 54–
`57, and 59–62 are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`combination of Wimsatt, Johnson, and Severson. Pet. 7–64. Petitioner
`submits a Declaration of James Parker (Ex. 1002) in support of its
`contention. We have reviewed the parties’ contentions and supporting
`evidence. Given the evidence of record, we are not persuaded that Petitioner
`has established a reasonable likelihood of prevailing on this asserted ground
`as to any of these claims for the reasons explained below.
`
`1. Relevant Principles of Law
`A claim is unpatentable under § 103(a) if the differences between the
`claimed subject matter and the prior art are such that the subject matter, as a
`whole, would have been obvious at the time the invention was made to a
`person having ordinary skill in the art to which the subject matter pertains.
`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). The question of
`obviousness is resolved on the basis of underlying factual determinations,
`including: (1) the scope and content of the prior art; (2) any differences
`between the claimed subject matter and the prior art; (3) the level of skill in
`the art; and (4) where in evidence, objective indicia of non-obviousness (i.e.,
`secondary considerations). Graham v. John Deere Co., 383 U.S. 1, 17–18
`(1966).
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`2. Overview of Wimsatt (Ex. 1004)
`Wimsatt describes a system and method for implementing a
`contextually sensitive user interface for home automation systems.
`Ex. 1004, Abstract, ¶¶ 3, 22. Figure 1 of Wimsatt is reproduced below.
`
`
`Figure 1 depicts an exemplary environment for implementing the system and
`method of Wimsatt. Id. ¶¶ 15, 34. According to Wimsatt, control panels
`101 implement a programmable human interface that may include a touch-
`screen graphical user interface. Id. ¶¶ 34, 35. Wireless control panels 107
`may also be used to implement similar functionality as control panels 101 in
`a wireless networking environment. Id. ¶ 37.
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`As shown in Figure 1 above, control panels 101 or 107 couple to
`home automation subsystems, such as lighting control subsystem 113 and
`entertainment control subsystem 115. Id. ¶ 39. The control panels connect
`to the subsystem interfaces using signaling protocols adopted by the
`subsystems. Id.
`Wimsatt contemplates adding or adapting its control panels “on top
`of” the existing home automation subsystems, such as lighting control
`systems and security systems. See id. ¶ 23 (stating that the disclosed
`invention is useful because it builds “on top of” the existing home
`automation subsystems and that “a particular advantage” of the invention is
`adapting to the existing controlled devices or subsystems). Reflecting this
`intended use, Wimsatt describes a process implemented in control panels
`101 or 107 for discovering the existing subsystems at the premises. Id. ¶ 45.
`When a control panel is coupled to a controlled device or subsystem, it
`interrogates the device or subsystem to learn the details of the control
`interface of the device or subsystem. Id. In some cases, this interrogation
`may simply be a matter of determining the controller type of the subsystem.
`Id. If the subsystem or the controlled device returns insufficient information
`during interrogation, the control panel can be programmed manually to
`support the controlled device or subsystem. Id.
`According to Wimsatt, unlike conventional home automation systems,
`which required a separate, independent control system for each subsystem
`with a separate, dedicated human interface, Wimsatt’s control panels can
`access and control any of the controlled devices or subsystems that are
`coupled to the control panels. Id. ¶¶ 43–44. By utilizing common interface
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`elements, the control panels of Wimsatt present substantially the same set of
`controls and provide similar graphical user interfaces to various home
`automation subsystems in a context sensitive manner. Id. ¶¶ 63, 77.
`
`3. Overview of Johnson (Ex. 1005)
`Johnson discloses an “Internet based home communications system
`for allowing a homeowner to monitor and control various features of their
`home from a distant location via a global computer network.” Ex. 1005,
`Abstract. Johnson discloses a system comprising a plurality of control
`devices, a control unit in communication with the devices and connected to
`the Internet, and a data center having server computers connected to the
`Internet and the control unit. Id. at col. 2, ll. 8–14.
`The homeowner is capable of monitoring and controlling the
`control device within the home by accessing a web page
`displayed by the data center through a conventional web browser
`on a computer. The homeowner can view, monitor and control
`features of their home through the web page such as viewing
`interior images of their home or adjusting the thermostat for the
`interior of their home. In addition, the control unit may notify
`the appropriate supplier when propane or food becomes low
`within the home through the global computer network.
`
`Id. at col. 2, ll. 19–28. Control devices include “lighting controls, heating
`controls, moisture controls, freeze controls, pet feeding devices, propane
`gauge, interior cameras, exterior cameras, security system, smoke alarm and
`various other devices.” Id. at col. 2, ll. 13–18.
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`4. Overview of Severson (Ex. 1006)
`Severson discloses a programmable security alarm system including a
`system controller “which is programmably responsive to a plurality of
`distributed wireless and hardwired alarm sensors/transducers and which
`communicates with neighboring system controllers and a central station
`interactively monitoring a number of subscriber systems.” Ex. 1006, col. 1,
`ll. 5–12. Each system controller is programmable with sensor/transducer
`numbers, options, and features. Id. at col. 23, ll. 60–63. Severson explains:
`
`Even further and without human intervention, once the
`sensors transducers are initially programmed, each system
`controller may be operated to “self-learn” each of its sensors. In
`this mode as the sensors/transducers report to the controller for
`the first time and after the controller confirms the existence of a
`proper house code or unit number, they are logged into the
`controller’s RAM memory. Human error is thus minimized even
`though during hand programming with the wireless key pad 13,
`the circuitry performs a similar subroutine to log the assigned
`[sensor/transducer] S/T numbers into RAM.
`
`Id. at col. 25, ll. 2–13.
`
`5. Discussion
`a. Claims 1, 60, and 61
`Independent claims 1, 60, and 61 all recite “the connection
`management component” “forms” or “forming” “a security network by
`automatically discovering the security system components and integrating
`communications and functions of the security system components into the
`security network” and “the gateway . . . maintains objects at the security
`server using the processed data, wherein the objects correspond to the
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`security system components and the plurality of network devices.”
`Ex. 1001, col. 46, ll. 35–39, 49–54; col. 49, l. 52–col. 50, l. 3; col. 50, ll. 12–
`19, 26–32, 40–45. These two limitations are identified by Petitioner as
`claim limitations 1[d] and 1[h], respectively, with respect to claim 1. Pet.
`13, 25. We discuss each of these limitations below.
`
`i) Limitation 1[d]
`Petitioner contends that the combination of Wimsatt, Johnson, and
`Severson renders obvious the claim limitation identified by Petitioner as
`limitation 1[d], i.e., the limitation reciting “the connection management
`component forms a security network by automatically discovering the
`security system components and integrating communications and functions
`of the security system components into the security network” (the “two-part
`network formation limitation”). Pet. 13–18. The plain language of this
`claim limitation indicates that “the connection management component
`forms a security network” by performing two separate operations—that is,
`by “automatically discovering the security system components” and
`“integrating communications and functions of the security system
`components into the security network.” We first address the parties’
`disputes regarding whether Wimsatt or Wimsatt in view of Severson teaches
`“automatically discovering the security system components.”
`Petitioner asserts that, although Wimsatt does not illustrate sensors in
`its security system, a person of ordinary skill in the art would have
`understood Wimsatt’s security system to include sensors and that those
`sensors would be the “security system components” recited in the claims.
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`Id. at 10. Petitioner concedes that “Wimsatt does not explicitly disclose that
`its security system’s sensors are automatically discovered using this
`[Universal Plug-and-Play (UPnP)] process – it only explicitly discloses that
`the ‘security system’ is discovered.” Id. at 14. Petitioner then argues “[a]
`POSITA would have understood that discovering the security system would
`also include discovering its sensors.” Id. (citing Ex. 1002 ¶ 92). Patent
`Owner asserts (Prelim. Resp. 12), and we agree, that this argument from
`Petitioner is too conclusory to satisfy Petitioner’s burden. The cited portion
`of the expert testimony merely repeats, without adequate elaboration or
`explanation, Petitioner’s argument and, therefore, similarly is conclusory.
`See Ex. 1002 ¶ 92.
`Petitioner, arguing in the alternative, turns to Severson for the
`disclosure of a system having a controller that may “self-learn” sensors
`“without human intervention.” Pet. 14 (citing Ex. 1006, col. 25, ll. 3–13).
`Petitioner asserts
`In describing a system installation process, Severson explains
`that the sensors and controller are mounted at the home and then
`“the controller
`is enabled and self-learns each of
`its
`sensors/transducers as they report their status.” (Ex. 1006,
`25:51-26:7; see also,
`id., 23:60-25:50.)
` As a result,
`“[i]nstallation time is thereby reduced with minimal potential
`installer error, due to the CPU self-learning its reporting
`sensors.” (Id., 25:51-26:7.) This is similar to the auto-discovery
`process described in the ‘619 patent. (See, e.g., Ex. 1001,
`FIG. 14, 24:66-26:5.)
`
`Id. at 14–15.
`Patent Owner disputes this contention and argues that Severson’s self-
`learning is not “automatically discovering” within the meaning of the
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`claimed invention. Prelim. Resp. 13–14. Petitioner does not propose a
`construction for “automatically discovering,” but, as quoted above, merely
`asserts that Severson’s process is “similar” to that disclosed in the ’619
`patent. Pet. 15 (citing Ex. 1001, Fig. 14, col. 24, l. 66–col. 26, l. 5). The
`process described in the ’619 patent and upon which Petitioner relies,
`however, indicates that the first step after gateway power-up, and before
`entering “learn mode,” is for the gateway to “identify” accessible wireless
`security panels and wireless devices. Ex. 1001, col. 25, ll. 1–11, Fig. 14
`(software sequences 1420 and 1425). In contrast, as Patent Owner notes,
`Severson discloses that the sensors and controllers are initially programmed
`in a manual process. Prelim. Resp. 13–14 (citing Ex. 1006, col. 25, ll. 3–6
`(“Even further and without human intervention, once the sensors
`transducers are initially programmed, each system controller may be
`operated to ‘self-learn’ each of its sensors.”) (emphasis by Patent Owner),
`22–24, 51–61). Indeed, Severson describes that Severson’s controller “self-
`learns” the sensors when those sensors report their status after first being
`programmed manually. Ex. 1006, col. 25, ll. 51–65. Thus, Severson
`suggests that the sensors must first be identified for the controller before
`Severson’s controller “self-learns” those sensors “without human
`intervention.” Even if Severson’s process is “similar” to the learning
`process described in the ’619 patent, we are not persuaded Petitioner has
`demonstrated sufficiently that Severson discloses “automatically discovering
`the security system components,” as recited in the claims 1, 60, and 61.
`Petitioner contends that it would have been obvious to a person of
`ordinary skill in the art to combine the “auto-discovery disclosure” of
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`Severson with Wimsatt and Johnson “so that the control panel 101 in
`Wimsatt can auto-discover the security sensors in addition to the discovering
`the security system controller.” Pet. 15. Citing Severson and the Parker
`Declaration, Petitioner asserts that “[t]his would predictably result in an
`easier sensor installation process and reduce the likelihood of installer
`error.” Id. (citing Ex. 1002 ¶ 93; Ex. 1006, col. 26, ll. 5–7). Patent Owner
`argues that Petitioner’s contention is at odds with Wimsatt’s description that
`its control panels communicate with a security system, not the underlying
`security system components, such as the security sensors. Prelim. Resp. 15–
`16 (citing Ex. 1004 ¶¶ 5, 23, 30, 31, 58, 62, 65). Patent Owner asserts that,
`because “Wimsatt’s control panels are limited to functionality regarding the
`status of a security system” and do not communicate with or control
`individual security system components, Petitioner’s proposed modification
`would unnecessarily complicate installation, not simplify it. Id. at 16.
`We agree with Patent Owner that Wimsatt’s control panels do not
`communicate directly with the security system components, such as the
`sensors. As discussed above in our overview of Wimsatt, Wimsatt is
`directed to providing control panels with consistent user interfaces to
`existing home subsystems, such as home automation systems and security
`systems. Ex. 1004 ¶¶ 3, 22, 23, 77. Hence, Wimsatt’s control panels
`discover the existing subsystems at the premises, such as a security system,
`and learn the details of the control interface of the subsystems, but do not in
`general discover or communicate with the components internal to the
`subsystems, such as the security system components or sensors. Id. ¶ 45.
`Indeed, Wimsatt describes that “[i]n most cases it is not necessary for every
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`control panel 101/107 to have detailed knowledge of a particular controlled
`device or subsystem. Instead, it is sufficient to be aware of the existence of
`each controlled device and the functionality available from that device.” Id.
`¶ 46 (emphases added). Furthermore, because Wimsatt contemplates adding
`or adapting its control panels “on top of” the existing security systems (id.
`¶ 23), Wimsatt’s discovery process would have expected that the sensors
`would have already been installed and the sensor installation process
`previously completed. Hence, the record indicates that Wimsatt is not
`concerned with sensor installation processes, such as those described in
`Severson. Petitioner does not explain why the combination of Wimsatt and
`Severson would nonetheless “predictably result in an easier sensor
`installation process and reduce the likelihood of installer error.” Pet. 15.
`The cited portion of the expert testimony repeats, without adequate
`elaboration or explanation, Petitioner’s unpersuasive argument and,
`therefore, similarly is unpersuasive. See Ex. 1002 ¶ 93.
`Petitioner’s argument that Severson “illustrates the ability and desire
`for similar controllers to automatically discover devices at the security
`component level” (Pet. 15) is similarly unpersuasive because Wimsatt is not
`concerned with discovering security system components.
`The rest of Petitioner’s arguments regarding the reasons to combine
`Wimsatt with Severson and Johnson are too conclusory to satisfy
`Petitioner’s burden. For example, similar to Petitioner’s conclusory
`contention discussed above, Petitioner asserts that “Wimsatt already
`discloses an automatic discovery process for learning the security system so
`it would be obvious to a POSITA to further discover the sensors that form
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`part of that system.” Id. (citing Ex. 1002 ¶ 94). Petitioner also contends that
`“[a] POSITA would understand that adding an extra step in the automatic
`discovery process to include discovery of the sensors would be easy to
`implement.” Id. (citing Ex. 1002 ¶ 94). The cited portion of the expert
`testimony again repeats, without adequate elaboration or explanation,
`Petitioner’s conclusory assertions. See Ex. 1002 ¶ 94. These conclusory
`statements are insufficient to provide the requisite “reasoned explanation” to
`justify combining Wimsatt
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