UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`SecureNet Technologies, LLC,
`Petitioner
`
`v.
`
`iControl Networks, Inc.,
`Patent Owner
`
`U.S. Patent No. 8,473,619
`Filing Date: Aug. 11, 2008
`Issue Date: June 25, 2013
`
`Title: Forming a Security Network Including Integrated Security System
`Components and Network Devices
`
`
`Inter Partes Review No. ______
`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 8,473,619
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`i
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`Table of Contents
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`C.
`
`Page
`INTRODUCTION .......................................................................................... 1
`I.
`II. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1) ....................... 1
`A.
`Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ........................... 1
`B.
`Related Matters Under 37 C.F.R. § 42.8(b)(2) .................................... 1
`C.
`Lead and Back-Up Counsel under 37 C.F.R. § 42.8(b)(3) .................. 2
`D.
`Service Information .............................................................................. 2
`E.
`Power of Attorney ................................................................................ 2
`III. PAYMENT OF FEES - 37 C.F.R. § 42.103 .................................................. 2
`IV. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37
`C.F.R. §§ 42.104 AND 42.108 ....................................................................... 3
`A. Grounds for Standing Under 37 C.F.R. § 42.104(a) ............................ 3
`B.
`Identification of Challenge Under 37 C.F.R. § 42.104(b) and
`Statement of Precise Relief Requested ................................................ 3
`Threshold Requirement for Inter Partes Review 37 C.F.R. §
`42.108(c) ............................................................................................... 4
`BACKGROUND OF TECHNOLOGY RELATED TO THE ‘619
`PATENT ......................................................................................................... 4
`VI. SUMMARY OF THE ‘619 PATENT ............................................................ 4
`VII. CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.104(B)(3) ................... 4
`A.
`Legal Overview .................................................................................... 4
`B.
`Proposed Claim Constructions ............................................................. 5
`VIII. PERSON HAVING ORDINARY SKILL IN THE ART & STATE
`OF THE ART ................................................................................................. 5
`IX. CLAIMS 17, 18, 20-22, 29-31, 33, 35-41, 48-53 AND 58 OF THE
`‘619 PATENT ARE UNPATENTABLE ....................................................... 5
`A. Overview Of The Prior Art .................................................................. 6
`1.
`Overview of Wimsatt ................................................................. 6
`2.
`Overview of Johnson ................................................................. 6
`3.
`Overview of Severson ................................................................ 7
`4.
`Overview of Naidoo ................................................................... 7
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`V.
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`Table of Contents
`(continued)
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`Page
`Overview of Alexander .............................................................. 7
`5.
`Overview of Anthony ................................................................ 8
`6.
`The Cited References Are Analogous Art ........................................... 8
`B.
`C. Grounds 1-3 – Claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53
`and 58 Are Obvious over Wimsatt in view of Johnson and/or
`Other Prior Art References Under 35 U.S.C. § 103(a) ........................ 8
`1.
`Independent claim 1 ................................................................... 9
`2.
`Dependent claim 16 ................................................................. 30
`3.
`Dependent claim 17 – Ground 1 .............................................. 32
`4.
`Dependent claim 18 – Ground 1 .............................................. 34
`5.
`Dependent claim 20 – Ground 2 .............................................. 35
`6.
`Dependent claim 21 – Ground 1 .............................................. 36
`7.
`Dependent claim 22 – Ground 1 .............................................. 37
`8.
`Dependent claim 24 ................................................................. 38
`9.
`Dependent claim 29 – Ground 1 .............................................. 38
`10. Dependent claim 30 – Ground 1 .............................................. 40
`11. Dependent claim 31 – Ground 1 .............................................. 40
`12. Dependent claim 32 ................................................................. 41
`13. Dependent claim 33 – Ground 1 .............................................. 41
`14. Dependent claim 35 – Ground 2 .............................................. 42
`15. Dependent claim 36 – Ground 1 .............................................. 42
`16. Dependent claims 37 and 38 – Ground 3 ................................. 42
`17. Dependent claim 39 – Ground 3 .............................................. 45
`18. Dependent claim 40 – Ground 3 .............................................. 47
`19. Dependent claim 41 – Ground 3 .............................................. 48
`20. Dependent claim 48 – Ground 3 .............................................. 49
`21. Dependent claims 49 and 50 – Ground 3 ................................. 50
`22. Dependent claim 51 – Ground 3 .............................................. 52
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`Table of Contents
`(continued)
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`Page
`23. Dependent claim 52 – Ground 3 .............................................. 54
`24. Dependent claim 53 – Ground 3 .............................................. 55
`25. Dependent claim 58 – Ground 1 .............................................. 56
`X. NO SECONDARY CONSIDERATIONS OF NON-OBVIOUSNESS
`EXIST ........................................................................................................... 57
`XI. CONCLUSION ............................................................................................. 58
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`EXHIBITS
`
`Description of Document
`
`Exhibit
`No.
`1001 U.S. Patent No. 8,473,619 ("the ‘619 patent")
`1002 Declaration of James Parker
`1003
`File History for U.S. Patent No. 8,473,619
`1004 U.S. Patent Publication No. 2004/0260427 to Wimsatt (“Wimsatt”)
`1005 U.S. Patent No. 6,580,950 to Johnson et al. (“Johnson”)
`1006 U.S. Patent No. 4,951,029 to Severson (“Severson”)
`1007 U.S. Publication No. 2003/0062997 to Naidoo et al. (“Naidoo”)
`1008 U.S. Patent No. 6,748,343 to Alexander et al. (“Alexander”)
`1009 U.S. Publication No. 2003/0137426 to Anthony et al. (“Anthony”)
`1010
`Installation Instructions for PC5401 Data Interface Module (2004)
`“Understanding Universal Plug and Play,” White Paper, Microsoft
`(2000)
`Waiver of Service, iControl Networks, Inc. v. SecureNet Techns.,
`LLC, No. 15-807-GMS, (D. Del. Sept. 30, 2015), ECF No. 5
`1012
`1013 Curriculum Vitae of James Parker
`
`1011
`
`
`
`
`
`iv
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`
`
`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`I.
`INTRODUCTION
`
`SecureNet Technologies, LLC (“Petitioner” or “SecureNet”) petitions for
`
`inter partes review (“IPR”) under 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42 of
`
`claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53 and 58 (“the Petitioned Claims”) of
`
`U.S. Patent No. 8,473,619 (“the ‘619 patent”) (Ex. 1001).
`
`II. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1)
`A. Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1)
`SecureNet Technologies, LLC is the real party-in-interest.
`
`B. Related Matters Under 37 C.F.R. § 42.8(b)(2)
`The ‘619 patent is asserted in iControl Networks, Inc. v. SecureNet
`
`Technologies, LLC, No. 15-807-GMS (D. Del.), which was filed on September 11,
`
`2015.1
`
`Petitioner is also concurrently filing an IPR petition covering claims 1-6, 14-
`
`46, 49-58 and 60-61 of U.S. Patent No. 8,073,931, which is assigned to the Patent
`
`Owner and claims priority to same applications as the ‘619 patent. Petitioner is
`
`also concurrently filing two IPR petitions covering claims 1-4, 6-50 of U.S. Patent
`
`1 iControl Networks, Inc. (“Patent Owner” or “iControl”) filed a Waiver of Service
`
`in that case on September 30, 2015 (Ex. 1012). Based on the PTAB-designated
`
`informative decision docketed as Case No. IPR2013-00010 (Paper 20) (January 30,
`
`2013), this Petition is being timely filed.
`
`1
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`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`No. 8,478,844 (“the ‘844 patent”), which is assigned to the Patent Owner and is the
`
`child patent to the ‘619 patent. Petitioner is also concurrently filing an IPR petition
`
`for claims 25-40 and 42-50 of the ‘844 patent.
`
`Petitioner is not aware of any other judicial or administrative matters that
`
`would affect, or be affected by, a decision in this proceeding.
`
`C. Lead and Back-Up Counsel under 37 C.F.R. § 42.8(b)(3)
`
`Lead Counsel: Erik B. Milch (Reg. No. 42,887) / emilch@cooley.com
`Back-up Counsel:
`Jennifer Volk (Reg. No. 62,305) / jvolkfortier@cooley.com
`Frank Pietrantonio (Reg. No. 32,289) / fpietrantonio@cooley.com
`zSecureNetIPR@cooley.com
`zpatdcdocketing@cooley.com
`Cooley LLP ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700 Washington, DC 20004
`Tel: (703) 456-8573 Fax: (703) 456-8100
`D.
`Service Information
`The Petition is being served by FEDERAL EXPRESS to the ‘619 Patent
`
`Owner’s attorneys of record, IPR Law Group, PC and the known outside counsel
`
`to Patent Owner, Wilson Sonsini Goodrich & Rosati. Petitioner consents to service
`
`by e-mail at the addresses provided above.
`
`Power of Attorney
`
`E.
`Filed concurrently with this petition per 37 C.F.R. § 42.10(b).
`
`III. PAYMENT OF FEES - 37 C.F.R. § 42.103
`This Petition requests review of claims 17, 18, 20-22, 29-31, 33, 35-41, 48-
`
`53 and 58 (a total of 23 claims) of the ‘619 patent and is accompanied by a
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`2
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`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`payment of $26,800. 37 C.F.R. § 42.15. This Petition meets the fee requirements of
`
`35 U.S.C. § 312(a)(1).
`
`IV. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R. §§ 42.104
`AND 42.108
`A. Grounds for Standing Under 37 C.F.R. § 42.104(a)
`Petitioner certifies that the ‘619 patent is eligible for IPR and further
`
`certifies that Petitioner is not barred or estopped from requesting IPR.
`
`B.
`
`Identification of Challenge Under 37 C.F.R. § 42.104(b) and
`Statement of Precise Relief Requested
`
`Petitioner requests that the Board institute inter partes review of claims 17,
`
`18, 20-22, 29-31, 33, 35-41, 48-53 and 58 of the ‘619 patent and requests that each
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`claim be found unpatentable as obvious under 35 U.S.C. § 103(a) on the following
`
`grounds:
`
`Ground ‘619 Claim(s)
`1.
`17, 18, 21-22,
`29-31, 33, 36,
`58
`20, 35
`
`2.
`
`3.
`
`37-41, 48-53
`
`Basis for Challenge
`Obvious over Wimsatt in view of Johnson,
`Severson and Naidoo under 35 U.S.C. § 103(a)
`
`Obvious over Wimsatt in view of Johnson,
`Severson, Naidoo and Anthony under 35 U.S.C. §
`103(a)
`
`Obvious over Wimsatt in view of Johnson,
`Severson and Alexander under 35 U.S.C. § 103(a)
`
`
`This petition is accompanied by the Declaration of James Parker (Ex. 1002,
`
`“Mr. Parker”), an expert in the field.
`
`3
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`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`C. Threshold Requirement for Inter Partes Review 37 C.F.R. §
`42.108(c)
`Inter partes review of claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53 and 58
`
`should be instituted because this Petition establishes a reasonable likelihood that
`
`Petitioner will prevail with respect to each of the claims challenged. 35 U.S.C. §
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`314(a).
`
`V. BACKGROUND OF TECHNOLOGY RELATED TO THE ‘619 PATENT
`Mr. Parker provides a technology tutorial in his declaration. (Ex. 1002, ¶¶
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`30-57.)
`
`VI. SUMMARY OF THE ‘619 PATENT
`The ‘619 patent was filed on August 11, 2008 and claims priority to a
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`divisional application and a long list of continuation-in-part applications and
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`provisional applications, the earliest of which has a filing date of March 16, 2005.
`
`(Ex. 1001.) For purposes of this proceeding, we assume that the earliest possible
`
`priority date of the ‘619 patent is March 16, 2005. We reserve the right to dispute
`
`this priority date at a later time or in another proceeding.
`
`VII. CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.104(b)(3)
`A. Legal Overview
`A claim subject to IPR is given its “broadest reasonable construction in light
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`4
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`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`of the specification of the patent in which it appears.”2 37 C.F.R. § 42.100(b).
`
`B.
`
`Proposed Claim Constructions
`
`Petitioner does not propose any claim constructions for this proceeding. All
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`claim terms and clauses should be given their plain and ordinary meaning as
`
`understood by a person of ordinary skill in the art (“POSITA”). (See Ex. 1002, ¶
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`59.)
`
`VIII. PERSON HAVING ORDINARY SKILL IN THE ART & STATE OF THE ART
`
`The ‘619 patent is directed to integrated security systems that are capable of
`
`being remotely accessed and controlled. (Ex. 1002, ¶¶ 17-24.) At the time of the
`
`alleged invention, a POSITA as of 2005 would hold a bachelor’s degree or the
`
`equivalent in electrical engineering (or related academic fields) and at least three
`
`years of additional work experience in the area of digital and/or telecommunication
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`system design, as applicable to safety and security systems, or equivalent work
`
`experience. (Id., ¶ 19.)
`
`IX. CLAIMS 17, 18, 20-22, 29-31, 33, 35-41, 48-53 AND 58 OF THE ‘619 PATENT
`ARE UNPATENTABLE
`
`As detailed in the sections below, claims 17, 18, 20-22, 29-31, 33, 35-41,
`
`48-53 and 58 of the ‘619 patent are obvious in light of Wimsatt in view of Johnson
`
`2 Petitioners reserve the right to pursue different constructions in litigation. In re
`
`Zletz, 893 F.2d 319, 321 (Fed. Cir. 1989).
`
`5
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`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`and/or one or more other prior art references cited below.
`
`A. Overview Of The Prior Art
`1. Overview of Wimsatt
`Wimsatt published on December 23, 2004 and therefore qualifies as prior art
`
`under 35 U.S.C. § 102(a). The patent issuing from Wimsatt was cited by Patent
`
`Owner in an Information Disclosure Statement (IDS) during prosecution of the
`
`‘619 patent but it was never applied against the claims.
`
`Wimsatt describes a home automation system having a control panel 101
`
`that is connected to a number of co-located devices, called “controlled devices”,
`
`which manage already-existing systems, such as lighting systems or security
`
`systems. (Ex. 1004, ¶ 0023.) The control panel 101 displays an interactive
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`graphical user interface (GUI) that allows the user (e.g., homeowner) to control the
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`controlled devices. (Id., ¶ 0022; Ex. 1002, ¶¶ 61-64.)
`
`2. Overview of Johnson
`Johnson issued on June 17, 2003 and therefore qualifies as prior art under 35
`
`U.S.C. § 102(b). Johnson was cited by Patent Owner in an IDS during prosecution
`
`of the ‘619 patent but it was never applied against the claims.
`
`Johnson discloses an “Internet based home communications system for
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`allowing a homeowner to monitor and control various features of their home from
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`a distant location via a global computer network.” (Ex. 1005, Abstract.) For
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`example, Johnson provides a website where homeowners can log in to access,
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`monitor and control a home’s security system, lighting system, exterior cameras
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`and the like. (Id., 2:8-28, 6:35-59.) The web site is provided through one or more
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`data center 20 servers that are located remotely from the home. (Id., 4:15-53.)
`
`3. Overview of Severson
`Severson issued on August 21, 1990 and therefore qualifies as prior art
`
`under 35 U.S.C. § 102(b). Severson discloses a home security system controller
`
`that automatically discovers newly-added sensors its security network. (Ex. 1006,
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`23:60-26:7; Ex. 1002, ¶¶ 70-72.)
`
`4. Overview of Naidoo
`Naidoo published on April 3, 2003 and therefore qualifies as prior art under
`
`35 U.S.C. § 102(b). Naidoo was used as a primary reference against the claims
`
`during prosecution. It is used here as a secondary reference for a few of the
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`dependent claims. Naidoo discloses transmitting alarm and video data from a
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`premise security gateway 115 to a security server 131, a central monitoring station
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`136, and/or a remote client device 155. (Ex. 1007, FIG. 7, ¶¶ 0069-0070, Ex. 1002,
`
`¶ 73.)
`
`5. Overview of Alexander
`Alexander issued on June 8, 2004 and is prior art under 35 U.S.C. § 102(a).
`
`Alexander discloses an integrated security system connected to a remote server
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`capable of creating and modifying user accounts, and creating and modifying
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`system devices. (Ex. 1008, Abstract, Ex. 1002, ¶74.)
`
`6. Overview of Anthony
`Anthony published on July 24, 2003 and therefore qualifies as prior art
`
`under 35 U.S.C. § 102(b). Anthony discloses security cameras for use in various
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`security operations, including home security. (Ex. 1009, ¶¶ 31-33.) Anthony
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`discloses a security system that allows continuous remote monitoring and analysis.
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`(Ex. 1009, ¶ 38.) Audiovisual signals and other signals from the system can be
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`transmitted via general packet radio service (“GPRS”). (Ex. 1009, ¶¶ 8, 29, 39, 40,
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`44, 57, 92, Ex. 1002, ¶ 75.)
`
`The Cited References Are Analogous Art
`
`B.
`As indicated in the section above and as explained in Mr. Parker’s
`
`declaration, each of the prior art references combined in this Petition is analogous
`
`art to the ‘619 patent and to each other, as each reference is in the same field of
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`endeavor as the ‘619 patent. (Ex. 1002, ¶ 76.)
`
`C. Grounds 1-3 – Claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53 and 58
`Are Obvious over Wimsatt in view of Johnson and/or Other Prior
`Art References Under 35 U.S.C. § 103(a)
`
`Claims 17, 18, 20-22, 29-31, 33, 35-41, 48-53 and 58 are rendered obvious
`
`under 35 U.S.C. § 103(a) for the reasons that follow. The elements of claims 1, 16,
`
`24 and 32 are addressed herein despite the fact that claims 1, 16, 24 and 32 are not
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`8
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`

`
`Petition for Inter Partes Review of
`Patent No. 8,473,619
`the subject of this petition. The elements of claim 1 and 16 are addressed because
`
`claims 17, 18, 20-22, 29-31, 33, 35, 37-41 and 48-53 depend from claim 1 and/or
`
`16. The basis of rejection for each of claims 1 and 16 is incorporated into each of
`
`the claims that depend therefrom.
`
`1.
`
`Independent claim 1
`a.
`For the reasons discussed in the following sections, Wimsatt in view of
`
`Preamble: “A system comprising”
`
`Johnson and Severson discloses all the elements of the claimed system.
`
`b.
`
`Claim element 1[a]: “a gateway located at a first
`location”
`
`
`
`Wimsatt discloses a control panel 101 that is mounted within a user’s home
`
`at a central location. (Ex. 1004, ¶ 0034.) The control panel 101 is the claimed
`
`“gateway” and the user’s home is the claimed “first location.”
`
`c.
`
`Claim element 1[b]: “a connection management
`component coupled to the gateway and automatically
`establishing a wireless coupling with a security system
`installed at the first location”
`
`Wimsatt discloses this limitation in its entirety. For clarity, this limitation is
`
`divided into two parts and discussed separately.
`
`i.
`
`“a connection management component coupled
`to the gateway …”
`
`A POSITA would understand that the “connection management component”
`
`(referred to also throughout as “CMC”) would be a module implemented by a
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`processor to carry out the claimed operations. (Ex. 1002, ¶ 80.) A POSITA would
`
`also have understood that the control panel 101 in Wimsatt must also include a
`
`module to perform the discovery and connection processes that it describes and,
`
`thus, the control panel 101 in Wimsatt must indeed include the “connection
`
`management component” that would be responsible for the claimed couplings of
`
`the system. (Id.) Because the CMC is implemented by the control panel 101 (via its
`
`processor 201), Wimsatt discloses that the CMC is coupled to the control panel
`
`101.
`
`ii.
`
`“a connection management component …
`automatically establishing a wireless coupling
`with a security system installed at the first
`location”
`
`Wimsatt discloses that the user’s home (i.e., the claimed “first location”)
`
`includes a security system. (See, e.g., Ex. 1004, ¶ 0005 (“Home automation
`
`systems may be integrated with a home security system”), ¶ 0012 (describing a
`
`home automation system that controls “security systems”), ¶ 0023 (explaining that
`
`the “invention is particularly useful in home automation environments because it
`
`builds on top of the vast array of controlled devices and subsystems that already
`
`exist for managing … security systems”), ¶¶ 0029-0031 (“tripping a zone on a
`
`burglar alarm … may indicate a household member [is] entering the house”), ¶¶
`
`0043, 0057-0058, 0062, 0065, 0073-0074.)
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`Wimsatt discloses that its control panel 101 can implement a “system
`
`discovery process.” A POSITA would have understood that the CMC module
`
`performs this process. (Ex. 1002, ¶¶ 82-83.) According to Wimsatt, “[w]hen a
`
`control panel 101 is coupled to a controlled device or subsystem, it interrogates
`
`that device or subsystem to learn details of the control interface of that particular
`
`system.” (Ex. 1004, ¶ 0045.) “This interrogation may simply be a matter of
`
`determining the controller type in which case the control panel 101 can look up a
`
`command set and signaling protocol information for that controller type.” (Id.)
`
`Wimsatt also explains that when the interrogation process does not work correctly,
`
`“the control panel can be manually or semi-automatically programmed to
`
`support that controlled device or subsystem.” (Id. (emphasis added)) This last
`
`passage indicates that the interrogation process is automatic (i.e., the control panel
`
`101 automatically discovers the controlled devices) because manual or semi-
`
`automatic programming is only performed when the automatic interrogation fails.
`
`(See also, Ex. 1004, ¶ 0006 (describing the difficulties of manually adding devices
`
`to a network).) Per this disclosure, the control panel 101 can automatically
`
`discover the home security system when the home security system is coupled to the
`
`control panel 101.
`
`Wimsatt further discloses that its control panel 101 can be wireless (referred
`
`to as “control panel 107”) and can wirelessly communicate with any of the
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`controlled devices of the security system as a result of the above discovery process
`
`(e.g., because it now has the signaling protocol information needed for
`
`communication). (Ex. 1004, ¶¶ 0037, 0043.)
`
`d.
`
`Claim element 1[c]: “the security system including
`security system components”
`
`The ‘619 patent discloses that “security system components” can be sensors
`
`or any other components “belonging to the security system.” (Ex. 1001, 4:40-45.)
`
`While Wimsatt does not illustrate sensors in its security system, a POSITA would
`
`have understood that the security system indeed includes sensors. (Ex. 1002, ¶ 85.)
`
`Wimsatt discloses at paragraph [0031] that “tripping a zone on a burglar alarm …
`
`causes the control units to display a security screen having controls that allow the
`
`alarm to be de-activated.” (Ex. 1004, ¶ 0031.) A POSITA would have understood
`
`that a “burglar alarm” is a security system and that at least one sensor is located
`
`within each zone of the house. (Ex. 1002, ¶ 85.) It is this sensor (or sensors) that is
`
`“tripped” and sets off an alarm. Thus, sensors are inherent in Wimsatt.
`
`To the extent Patent Owner disagrees, it would be obvious from Wimsatt
`
`that its security system includes sensors. It was well known at the time of the ‘619
`
`patent that home security systems came equipped with multiple sensors (e.g.,
`
`motion sensors, door sensors, window sensors, etc.) that could be mounted at
`
`various locations throughout a home. (Ex. 1002, ¶ 86.) As Mr. Parker explains in
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`12
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`his declaration, sensors are the “eyes” of a home security system. (Id.) Without
`
`sensors, a home security system is blind and cannot function. (Id.)
`
`To the extent the Patent Owner further argues that a more specific disclosure
`
`of sensors is required, Johnson has that disclosure. As illustrated in the below
`
`excerpted and annotated Figure 5 of Johnson, the security system 60 includes
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`“security sensors.” (See also, Ex. 1005, FIG. 3 (illustrating icons for well-known
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`components of a home security system, e.g., a door sensor, a window sensor and a
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`smoke alarm).)
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`While a POSITA would have understood that Wimsatt already indicates the
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`presence of sensors, it would be obvious to modify Wimsatt to include the plurality
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`of security sensors disclosed in Johnson to make this disclosure more explicit. (Ex.
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`1002, ¶ 88.)
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`e.
`
`the connection
`Claim element 1[d]: “wherein
`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”
`
`For clarity, this limitation is divided into three parts and discussed
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`separately. Petitioner discusses “form[ing] a security network” last because it is the
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`end result of “automatically discovering” and “integrating” the devices.
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`i.
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`“the connection management component …
`automatically discovering the security system
`components”
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`Wimsatt discloses that its control panel 101, including the connection
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`management component, can implement a “system discovery process.” According
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`to Wimsatt, “[w]hen a control panel 101 is coupled to a controlled device or
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`subsystem, it interrogates that device or subsystem to learn details of the control
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`interface of that particular system.” (Ex. 1004, ¶ 0045.) Wimsatt also explains that
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`when the interrogation process does not work correctly, “the control panel can be
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`manually or semi-automatically programmed to support that controlled device or
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`subsystem.” (Id. (emphasis added)) This
`
`last passage
`
`indicates
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`that
`
`the
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`interrogation process is automatic (i.e., the control panel 101 automatically
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`Petition for Inter Partes Review of
`Patent No. 8,473,619
`discovers the controlled devices) because manual or semi-automatic programming
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`is only performed when the automatic interrogation fails. (See also, Ex. 1004, ¶
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`0006 (describing the difficulties of manually adding devices to a network).) Per
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`this disclosure, the control panel 101 can automatically discover the home security
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`system when the home security system is coupled to the control panel 101.
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`Wimsatt also discloses that its control panel 101 implements “Universal
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`Plug-and-Play (UPnP™) processes.” (Ex. 1004, ¶ 0054.) It was well known at the
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`time of the ‘844 patent that UPnP™ was used to auto-discover 2-way devices
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`connected to a shared network. (Ex. 1002, ¶ 91 (citing to Ex. 1011, 7).)
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`Wimsatt does not explicitly disclose that its security system’s sensors are
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`automatically discovered using this process – it only explicitly discloses that the
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`“security system” is discovered. A POSITA would have understood that
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`discovering the security system would also include discovering its sensors. (Ex.
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`1002, ¶ 92.) To the extent Patent Owner disputes this, Severson discloses a security
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`system that includes a controller and a plurality of sensors. (Ex. 1006, FIG. 1, 4:3-
`
`29.) Severson explains that “without human intervention” “each system controller
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`may be operated to ‘self-learn’ each of its sensors.” (Ex. 1006, 25:3-13.) In
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`describing a system installation process, Severson explains that the sensors and
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`controller are mounted at the home and then “the controller is enabled and self-
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`learns each of its sensors/transducers as they report their status.” (Ex. 1006, 25:51-
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`26:7; see also, id., 23:60-25:50.) As a result, “[i]nstallation time is thereby reduced
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`with minimal potential installer error, due to the CPU self-learning its reporting
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`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.)
`
`
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`Motivation to Combine Severson with Wimsatt and Johnson: It would be
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`obvious to a POSITA to combine the auto-discovery disclosure with Wimsatt and
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`Johnson so that the control panel 101 in Wimsatt can auto-discover the security
`
`sensors in addition to the discovering the security system controller. (Ex. 1002, ¶
`
`93.) This would predictably result in an easier sensor installation process and
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`reduce the likelihood of installer error. (Ex. 1002, ¶ 93; see also, Ex. 1006, 26:5-7.)
`
`As previously discussed, Wimsatt already discloses an automatic discovery
`
`process for learning the security system so it would be obvious to a POSITA to
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`further discover the sensors that form part of that system. (Ex. 1004, ¶ 0045; Ex.
`
`1002, ¶ 94.) A POSITA would understand that the control panel 101 would want to
`
`“discover” all of the devices that it and the data center 20 server in Johnson
`
`controls. Severson illustrates the ability and desire for similar controllers to
`
`automatically discover devices at the security component level. 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. (Ex. 1002, ¶ 94.)
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`
`ii.
`
`“the connection management component …
`integrating communications and functions of
`the security system components
`into
`the
`security network”
`
`As background, Wimsatt discloses a home automation system. The purpose
`
`of a home automation system, in general, is to communicate with and control the
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`functionality of multiple home-based devices such as lighting, heating and air
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`conditioning, media equipment, and security systems. (Ex. 1004, ¶¶ 0005-0006.) In
`
`its background section, Wimsatt provides an example of how such systems were
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`known to operate with home security systems: “Home automation systems may be
`
`integrated with a home security system so that when a fire alarm is raised, for
`
`example, internal and external lights will be turned on.” (Ex. 1004, ¶ 0005.) In
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`other words, it was well known at the time of the ‘619 patent that home automation
`
`systems communicated with home-based devices (such as the lights in the above
`
`example) and controlled their functionality (i.e., the system commanded the lights
`
`to “turn on”). Thus, the general concept of integrating communications and
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`functions of home-based devices into a home automation system was well known
`
`long before the earliest priority date of the ‘619 patent. (Ex. 1002, ¶ 95.)
`
`Looking at Wimsatt’s system specifically, the control panel 101, including
`
`the connection management component, “integrat[es]” communications and
`
`functions of its home-based control devices through the system discovery process
`
`discussed above. (See, e.g., Ex. 1004, ¶ 0045.) Through this discovery process, the
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`control panel 101 is able to “learn” various details about the controlled device,
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`such as its command set, signaling protocol information, and the functionality
`
`available for that device. (Ex. 1004, ¶ 0046.) The control panel 101 is then able to
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`communicate with and control the functions of that device. (Ex. 1002, ¶ 96.)
`
`Wimsatt identifies the home’s security system as one type of controlled
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`device. (See, e.g., Ex. 1004, ¶¶ 0012, 0029, 0058.) The specification also states that
`
`“control application software executes on the control unit to communicate control
`
`information such as commands, sensor messages, status messages, and the like
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`with … controlled systems (e.g., security systems …).” (Id. ¶ 0012 (emphasis
`
`added).) It further explains that this software “may enable features of the security
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`system to be enabled/disabled.” (Ex. 1