SkyBell Technologies, Inc.

Patent Trials and Appeals Board

Jul 15, 2020

IPR2019-00446 (P.T.A.B. Jul. 15, 2020)

Trials@uspto.gov Paper 31
571-272-7822 Date: July 15, 2020

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

RING LLC,
Petitioner,
v.
SKYBELL TECHNOLOGIES, INC.,
Patent Owner.

IPR2019-00446
Patent 9,179,109 B1

Before JEFFREY S. SMITH, DANIEL J. GALLIGAN, and
KAMRAN JIVANI, Administrative Patent Judges.
JIVANI, Administrative Patent Judge.

JUDGMENT
Final Written Decision
Determining All Challenged Claims Unpatentable
35 U.S.C. § 318(a)

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I. INTRODUCTION AND BACKGROUND
Petitioner Ring LLC requested an inter partes review of claims 1, 7,
15, 20, and 21 of U.S. Patent No. 9,179,109 B1 (“the ’109 patent,”
Ex. 1001). Paper 2 (“Petition” or “Pet.”). Patent Owner SkyBell
Technologies, Inc. did not file a Preliminary Response. After considering
the Petitioner’s arguments and the evidence of record, we instituted
review of all challenged claims on all grounds set forth in the Petition.
Paper 11 (“Dec. on Inst.”).
During the trial, Patent Owner filed a Response (Paper 21, “PO
Resp.”), Petitioner filed a Reply (Paper 23, “Reply”), and Patent Owner filed
a Sur-Reply (Paper 25, “Sur-Reply”).
An oral hearing was held on April 16, 2020, a transcript of which
appears in the record. Paper 30.
We have jurisdiction under 35 U.S.C. § 6. This Final Written
Decision, issued pursuant to 35 U.S.C. § 318(a), addresses issues and
arguments raised during the trial in this inter partes review. For the reasons
discussed below, we determine that Petitioner has proven by a
preponderance of the evidence that the challenged claims of the ’109 patent
are unpatentable. See 35 U.S.C. § 316(e) (2018) (“In an inter partes review
instituted under this chapter, the petitioner shall have the burden of proving a
proposition of unpatentability by a preponderance of the evidence.”).
A. Related Matters
The parties note the following related matter: SkyBell Techs., Inc. v.
Ring Inc., 8:18-cv-00014 (C.D. Cal. 2018). Pet. 2–3; Paper 4, 2.
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B. Real Parties-in -Interest
Petitioner identifies the following real parties-in-interest: Ring LLC,
Ring of Security Limited, Ring of Security B.V., Ring of Security Pty. Ltd.,
Ring of Security Asia Co., Ltd., Ring Protect Inc., Wireless Environment,
LLC, Wireless Environment Asia, LLC, Wireless Environment Lighting
Co., Ltd., Wireless Environment UK Ltd., Wireless Lighting Technologies,
LLC, Amazon.com Services, Inc., and Amazon.com, Inc. Pet. 2.
Patent Owner identifies itself as the real party-in-interest. Paper 4, 1.
C. The ’109 Patent and Challenged Claims
The ’109 patent describes a doorbell system, remote computing device
and a camera. Ex. 1001, code (57). Challenged claims 1, 7, 15, and 20 are
independent. Claim 1 is illustrative of the claimed subject matter and
reproduced below.
1. A method of using a doorbell system, wherein the doorbell
system comprises a remote computing device and a doorbell
having a camera, the method comprising:
coupling communicatively the doorbell and the remote
computing device;
detecting, by the doorbell system, an indication of a
presence of a visitor;
entering, by the doorbell, a camera sleep mode wherein the
camera is configured to not record;
opening a doorbell control application on the remote
computing device;
overriding, by the remote computing device via a wireless
communication, a power setting of the doorbell to force the
doorbell to exit the camera sleep mode and enter a camera
recording mode, wherein the camera recording mode consumes
more power than the camera sleep mode; and
receiving a first video, by the remote computing device,
from the doorbell at least partially in response to remotely
overriding the power setting of the doorbell.
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D. Prior Art and Asserted Grounds
Petitioner asserts the following grounds of unpatentability (Pet. 9):
Claim(s) Challenged 35 U.S.C. §1 Reference(s)/Basis
1 103 Siminoff,2 Almomani3
7 103 Siminoff, Imao4
20, 21 103 Siminoff, Imao, Huisking5
15 103 Siminoff ’618,6 Huisking

E. Testimony
Petitioner supports its challenges with a declaration of Vijay
Madisetti, Ph.D. Ex. 1003. Dr. Madisetti testified by deposition on October
24, 2019, and a transcript of his testimony has been entered into evidence.
Ex. 2003. Petitioner further supports its challenges with a supplemental
declaration of Dr. Madisetti. Ex. 1021.
Patent Owner proffers the declaration of Jacob Baker, Ph.D. in
support of its arguments. Ex. 2001. Dr. Baker testified by deposition on
December 19, 2019, and a transcript of his testimony has been entered into
evidence. Ex. 1020.

1 The Leahy-Smith America Invents Act (“AIA”) included revisions to
35 U.S.C. §§ 102 and 103 that became effective before the filing of the
application for the ’109 patent. Therefore, we apply the post-AIA versions
of these sections.
2 US Patent Publication No. 2015/0022620 A1, pub. Jan. 22, 2015
(Ex. 1005, “Siminoff”).
3 US Patent Publication No. 2014/0267740 A1, pub. Sept. 18, 2014
(Ex. 1006, “Almomani”).
4 US Patent No. 7,809,966 B2, issued Oct 15, 2010 (Ex. 1007, “Imao”).
5 US Patent Publication No. 2013/0057695 A1, pub. Mar. 7, 2013
(Ex. 1008, “Huisking”).
6 US Patent Publication No. 2015/0022618 A1, pub. Jan. 22, 2015
(Ex. 1009, “Siminoff ’618”).
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II. CLAIM CONSTRUCTION
The Petition was accorded a filing date of December 17, 2018.
Paper 5, 1. In an inter partes review for a petition filed on or after
November 13, 2018, a claim “shall be construed using the same claim
construction standard that would be used to construe the claim in a civil
action under 35 U.S.C. 282(b).” See Changes to the Claim Construction
Standard for Interpreting Claims in Trial Proceedings Before the Patent Trial
and Appeal Board, 83 Fed. Reg. 51,340 (Oct. 11, 2018) (amending
37 C.F.R. § 42.100(b) effective November 13, 2018) (now codified at 37
C.F.R. § 42.100(b) (2019)). In applying this standard, we are guided by the
principle that the words of a claim “are generally given their ordinary and
customary meaning,” as understood by a person of ordinary skill in the art in
question at the time of the invention. Phillips v. AWH Corp., 415 F.3d 1303,
1312–13 (Fed. Cir. 2005) (en banc) (citation omitted).
Neither party seeks our construction of any claim terms and, therefore,
we do not construe expressly any claim terms. Nidec Motor Corp. v.
Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017)
(quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803
(Fed. Cir. 1999)) (“[W]e need only construe terms ‘that are in controversy,
and only to the extent necessary to resolve the controversy.’”). Instead, we
give the claims their ordinary and customary meaning, as understood by a
person of ordinary skill in the art in question at the time of the invention.7
Phillips v. AWH Corp., 415 F.3d at 1312–13.

7 We discuss the parties’ contentions regarding claim 20’s “opening a
doorbell control application” and claim 15’s “automatically” in the context
of our analysis of those claims. See infra Sections III.E.3., III.F.3.
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III. ANALYSIS OF ASSERTED GROUNDS
A. Principles of Law
Petitioner bears the burden of proving unpatentability of the
challenged claims, and the burden of persuasion never shifts to Patent
Owner. Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375,
1378 (Fed. Cir. 2015). To prevail in its challenges, Petitioner must show by
a preponderance of the evidence that the challenged claims are unpatentable.
35 U.S.C. § 316(e); 37 C.F.R. § 42.1(d).
A claim is unpatentable under 35 U.S.C. § 103 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 said 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) when in evidence, objective evidence of non-
obviousness such as commercial success, long-felt but unsolved needs,
failure of others, and unexpected results. Graham v. John Deere Co., 383
U.S. 1, 17–18 (1966) (“the Graham factors”). The obviousness inquiry
further requires an analysis of “whether there was an apparent reason to
combine the known elements in the fashion claimed by the patent at issue.”
KSR, 550 U.S. at 418 (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006)
(requiring “articulated reasoning with some rational underpinning to support
the legal conclusion of obviousness”)).
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B. Level of Ordinary Skill in the Art
The level of skill in the art is a factual determination that provides a
primary guarantee of objectivity in an obviousness analysis. Al-Site Corp. v.
VSI Int’l Inc., 174 F.3d 1308, 1324 (Fed. Cir. 1999) (citing Graham, 383
U.S. at 17–18; Ryko Mfg. Co. v. Nu-Star, Inc., 950 F.2d 714, 718 (Fed. Cir.
1991)).
Petitioner and its declarant Dr. Madisetti assert that, at the time of the
’109 patent, one of ordinary skill in the would have “a bachelor’s degree in
Electrical Engineering, Computer Engineering, or Computer Science, or
equivalent training, as well as at least one year of technical experience in the
relevant field.” Pet. 9 (citing Ex. 1003 ¶ 28).
Patent Owner and its declarant Dr. Baker “adopt[] Petitioner’s
definition of level of ordinary skill.” PO Resp. 8 (citing Ex. 2001 ¶ 35).
We regard Petitioner’s formulation of the level of skill as consistent
with the prior art before us. See Okajima v. Bourdeau, 261 F.3d 1350, 1355
(Fed. Cir. 2001) (prior art itself may reflect an appropriate level of skill).
Based on the full trial record and in view of the parties’ agreement, we adopt
Petitioner’s formulation of the level of ordinary skill in the art, with the
exception of the language “at least,” which introduces ambiguity, consistent
with the Decision on Institution. See Dec. on Inst. 6–7; Pet. 12–13; PO
Resp. 8; Ex. 1003 ¶ 28; Ex. 2001 ¶ 35.
C. Asserted Obviousness of Claim 1 over Siminoff and Almomani
1. Siminoff
Siminoff is directed to a doorbell system and includes a Smart Device
and a Wireless Communication Doorbell with a camera and a doorbell
button. Ex. 1005 ¶¶ 74, 78–79, 88–91. The Smart Device is coupled to the
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doorbell by a wireless system network and a wireless user’s network. Id.
¶¶ 74–79, 88–89. Further, the Smart Device includes an application that
“provide[s] an interface for User 62 to communicate and interact with
Wireless Communication Doorbell 61” across these networks. Id. ¶ 80.
Siminoff teaches that “all hardware components within Wireless
Communication Doorbell 61 may live in a state of hibernation,” referred to
as “a low power consumption mode.” Id. ¶¶ 87, 90. Claim 1 of Siminoff
recites “switching the processor from low-power mode to active mode in
response to an activation trigger” “wherein the activation trigger
comprises. . . a signal from the user at the remote communication device.”
Id. at Claim 1.
2. Almomani
Almomani “relates to an electronic lock with an integral camera that
allows remote monitoring.” Ex. 1006 ¶ 5. This electronic lock is
“configured with wireless communication capabilities” and “allows the user
to remotely see who is at the door,” for example, by “stream[ing] video
taken by the camera to remote electronic devices.” Id. ¶¶ 5, 20. In
particular, Almomani teaches that “the camera could be selectively activated
remotely by a user.” Id. ¶ 21. Almomani further explains that the user can
use a “dedicated app on a mobile device” that is in wireless communication
with the electronic lock “to activate a remote monitoring mode.” Id. ¶ 21.
“In this mode, the electronic lock could be configured to continuously
stream video, regardless of whether the motion sensor 103 is activated or
not.” Id.
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3. Motivation to Combine Siminoff and Almomani
Relying on Dr. Madisetti, Petitioner asserts, “a person of ordinary
skill in the art . . . would have found it obvious, beneficial, and predictable to
implement Almomani’s method of remotely activating a door-based camera
in the context of Siminoff’s video doorbell system.” Pet. 16 (citing Ex. 1003
¶¶ 55–64). According to Petitioner, Siminoff and Almomani “are both
directed to door-based, home monitoring systems controllable with
applications on mobile devices and both have the same goal of allowing a
user to remotely see who is near an entrance at any given time.” Id. at 17
(citing Ex. 1005 ¶ 79; Ex. 1006 ¶ 5; Ex. 1003 ¶ 56).
Petitioner states that one of ordinary skill in the art
would have been motivated to apply Almomani’s known
camera activation technique to Siminoff’s Wireless
Communication Doorbell to yield the beneficial and predictable
result of Siminoff’s “signal”-based activation trigger not only
causing the doorbell to wake up, but also causing the camera to
activate and begin recording live video that is transmitted to the
smart device.

Id. at 17–18 (citing Ex. 1003 ¶ 57). The combined teachings, Petitioner
argues, “would allow a user to view streaming video of the area around the
Wireless Communication Doorbell ‘at any given time’—explicitly
advancing one of Siminoff’s stated goals,” namely “allowing users to ‘see
who is within view of Wireless Communication Doorbell 61 at any given
time.’” Id. at 18 (citing Ex. 1005 ¶ 79; Ex. 1003 ¶ 58).
Petitioner contends “another stated goal of Siminoff’s disclosure is
reduced power consumption of video doorbells.” Id. at 19 (citing Ex. 1005
¶ 90). According to Petitioner, modifying Siminoff’s system with
Almomani’s technique of activating the doorbell’s camera upon remotely
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waking the doorbell “would allow the doorbell to remain in the hibernation
mode and save power when not in use, but still provide a user with the
option to selectively request a video stream of the area around the doorbell.”
Id. (citing Ex. 1003 ¶ 59). Petitioner further argues that an ordinarily skilled
artisan would find the proposed modification “predictable and likely to
result in success” because of specific teachings and suggestions in Siminoff,
and additionally that such skilled artisan “would have had an expectation of
success” because other doorbells embodying the proposed combination were
already “implemented and commercialized” before the ’109 Patent. Id. at
19–20 (citing Ex. 1005 ¶¶ 66, 86; Ex. 1003 ¶¶ 60–61; Ex. 1010). Finally,
Petitioner asserts that “[a]ny hypothetical modifications to Siminoff’s
system needed to implement Almomani’s features would be within the skill
of” one of ordinary skill in the art. Id. at 20 (citing Ex. 1005 ¶¶ 64, 77, 79;
Ex. 1003 ¶¶ 63; Ex. 1010).
Patent Owner and Dr. Baker counter that Petitioner’s proposed
combination “would frustrate Siminoff’s intended purpose of saving power
by rendering the camera inoperable when motion is not detected.” PO
Resp. 19; Ex. 2001 ¶ 55. Patent Owner elaborates:
Almomani teaches that when the smart phone application is
used to activate recording by the camera it “continuously
stream[s] video, regardless of whether the motion sensor is
activated or not.” Thus, if Almomani’s method of instructing
the camera to record were combined with Siminoff’s Wireless
Communication Doorbell, Siminoff would “continuously
stream video, regardless of whether the motion sensor is
activated.”

PO Resp. 19 (citing Ex. 2001 ¶ 55; Ex. 1006 ¶ 21) (emphasis omitted)
(internal citations omitted).
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We disagree with Patent Owner’s argument because it
mischaracterizes Siminoff’s stated goal. Siminoff seeks to ensure that its
components “do not waste battery power when not in use,” not merely
“rendering the camera inoperable when motion is not detected,” as Patent
Owner contends. Compare Ex. 1005 ¶ 90 (emphasis added), with PO
Resp. 19. Petitioner’s proposed combination would simply define explicitly
an additional situation for use of Siminoff’s components without destroying
the goal of lowering power usage when those components are not in use. As
Petitioner correctly argues, “modifying Siminoff to include Almomani’s
remote camera activation technique would in fact further Siminoff’s goal of
saving power, because it would provide both a low power mode and on-
demand streaming while still consuming less power than doorbell systems
that remain fully-powered at all times in order to provide on-demand
streaming.” Reply 14–15 (citing Pet. 19–21; Ex. 1003 ¶ 59).
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine one of ordinary skill in the art would have been
motivated to combine the teachings of Siminoff and Almomani, as Petitioner
proposes, with a reasonable expectation of success.
4. Claim 1
a) “A method of using a doorbell system . . . comprising:”
Claim 1 recites “[a] method of using a doorbell system, wherein the doorbell
system comprises a remote computing device and a doorbell having a
camera, the method comprising.” Petitioner contends “Siminoff discloses
this limitation because it teaches a method of using a doorbell system that
includes a Smart Device, such as a smartphone, and a Wireless
Communication Doorbell with a camera, as shown in Fig. 15.” Pet. 21
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(citing Ex. 1005 ¶ 88; Ex. 1003 ¶¶ 36–40). In particular, Siminoff describes
that data from Wireless Communication Doorbell 61 is processed by
Server 53 and routed to Smart Device 54 “to inform User 62 via Smart
Device 54 if Battery 24 is about to die (e.g. 10% battery remaining).”
Ex. 1005 ¶ 88. Patent Owner does not dispute Petitioner’s contentions on
this subject matter. See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find Siminoff meets this subject
matter.
b) “coupling communicatively the doorbell and the remote computing
device”
Claim 1 recites “coupling communicatively the doorbell and the
remote computing device.” Petitioner contends “Siminoff teaches
communicatively coupling the Wireless Communication Doorbell 61 and the
Smart Device 54 via a ‘wireless telecommunications network’ (System
Network 52) and a wireless User’s Network 65.” Pet. 22–23 (citing
Ex. 1005 ¶¶ 88, 77). Siminoff teaches, “Devices within the system send data
to System Network 52 where Server 53 processes and routes the data to the
appropriate device.” Ex. 1005 ¶ 88. As stated above, Siminoff describes
that data from Wireless Communication Doorbell 61 is processed by
Server 53 and routed to Smart Device 54 “to inform User 62 via Smart
Device 54 if Battery 24 is about to die (e.g. 10% battery remaining).” Id.
Patent Owner does not dispute Petitioner’s contentions on this limitation.
See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find Siminoff meets the claimed
“coupling communicatively the doorbell and the remote computing device.”
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c) “detecting, by the doorbell system, an indication of a presence of a
visitor”
Claim 1 recites “detecting, by the doorbell system, an indication of a
presence of a visitor.” Petitioner contends “Siminoff discloses this
limitation because it teaches that the Wireless Communication Doorbell
detects the presence of a visitor with a doorbell button push or with an
infrared sensor.” Pet. 24 (citing Ex. 1005 ¶ 66; Ex. 1003 ¶¶ 43–44). In
particular, Siminoff recites, “Camera 18 may record still or moving video,
(e.g. anyone who activates Wireless Communication Doorbell 61 by
pressing Button 8, or triggering Infrared Sensor 42).” Ex. 1005 ¶ 66.
Siminoff additionally states that “the transmission of data to and from
Wireless Communication Device to a Smart Device . . . may be initiated
when the Visitor 63 presses Button 11 of Wireless Communication Doorbell
61.” Id. ¶ 86; see also id. ¶ 45, Fig. 14. Siminoff further discloses that
“[i]nfrared Sensor 42 may trigger Camera 18 to record live video or still
images of Visitor 63 when Visitor 63 crosses the path of the Infrared Sensor
42.” Id. ¶ 46. Patent Owner does not dispute Petitioner’s contentions on
this limitation. See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find Siminoff meets the claimed
“detecting, by the doorbell system, an indication of a presence of a visitor.”
d) “entering, by the doorbell, a camera sleep mode wherein the camera is
configured to not record”
Claim 1 recites “entering, by the doorbell, a camera sleep mode
wherein the camera is configured to not record.” Petitioner contends
“Siminoff discloses this limitation because the Wireless Communication
Doorbell enters a ‘hibernation’ mode during which the camera is inactive
and does not record images or video.” Pet. 24 (citing Ex. 1005 ¶ 90).
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Siminoff discloses that “all hardware components within Wireless
Communication Doorbell 61 may live in a state of hibernation” until
activated. Ex. 1005 ¶ 90; see also id. at code (57), ¶¶ 86–87. Siminoff
refers to this state as “a low power consumption mode.” Id. ¶ 87, code (57).
Siminoff further explains that in this mode, “all components that draw power
from Battery 24, such as . . . Camera 18 do not waste battery power when
not in use.” Id. ¶ 90. Siminoff further discloses “[i]n reference to FIG. 12,
after Button 11 is pressed, Power Processor 51 may provide the power to
activate Camera 18 and Night Vision LEDs 19.” Id. ¶ 76 (emphasis added).
Relying on its declarant Dr. Madisetti, Petitioner contends that “when
Siminoff’s Wireless Communication Doorbell is in hibernation mode/low-
power mode, the camera is in a sleep mode and configured not to record,
because, in order for it to record an image, it must first be provided power
and activated, for example, in response to an activation trigger.” Pet. 25
(citing Ex. 1003 ¶¶ 46). Patent Owner does not dispute Petitioner’s
contentions on this limitation. See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find Siminoff meets the claimed
“entering, by the doorbell, a camera sleep mode wherein the camera is
configured to not record.”
e) “opening a doorbell control application on the remote computing
device”
Claim 1 recites “opening a doorbell control application on the remote
computing device.” Petitioner contends “Siminoff discloses this limitation
because it teaches that an ‘Application 55 may be installed on Smart
Device 54 and provide an interface for User 62 to communicate and interact
with Wireless Communication Doorbell 61.’” Pet. 25 (quoting Ex. 1005
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¶ 80). According to Petitioner, “[t]he Application allows the user to, among
other things, ‘view still images or video taken by Wireless communication
Doorbell 61,’ ‘focus or zoom Camera 18,’ and communicate with a visitor.”
Id. at 26 (citing Ex. 1005 ¶¶ 76, 80). Relying on Dr. Madisetti, Petitioner
further alleges that an ordinarily skilled artisan “would have understood that
the Application is opened on the smart device to allow the user to view
images or video and to control the doorbell.” Id. at 26–27 (citing Ex. 1003
¶¶ 48–50). Patent Owner does not dispute Petitioner’s contentions on this
limitation. See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find Siminoff meets the claimed
“opening a doorbell control application on the remote computing device.”
f) “overriding . . . wherein the camera recording mode consumes more
power than the camera sleep mode”
Claim 1 recites “overriding, by the remote computing device via a
wireless communication, a power setting of the doorbell to force the
doorbell to exit the camera sleep mode and enter a camera recording mode,
wherein the camera recording mode consumes more power than the camera
sleep mode.” Petitioner contends, “Siminoff teaches that several different
activation triggers can bring the Wireless Communication Doorbell out of
the low power/hibernation mode.” Pet. 27 (citing Ex. 1005, claim 1, ¶¶ 45,
46, 66, 76). Siminoff’s claim 1, cited by Petitioner, recites “switching the
processor from low-power mode to active mode in response to an activation
trigger” “wherein the activation trigger comprises . . . a signal from the user
at the remote communication device.” Ex. 1005, claim 1, quoted in Pet. 28.
Petitioner contends, “with respect to the ‘remote communication device’
from which the activation signal recited in claim 1 originates, Siminoff
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teaches that its doorbell system includes a ‘Smart Device’ that wirelessly
controls the Wireless Communication Doorbell, as discussed above.” Pet.
28 (citing Ex. 1005 ¶¶ 77, 79, 88, Fig. 12). Petitioner argues “Siminoff
teaches overriding the Wireless Communications Doorbell’s low
power/hibernation mode with a wireless activation signal from the Smart
Device.” Id. (citing Ex. 1003 ¶ 55). In addition, Petitioner contends that:
Siminoff teaches that at least some of the activation triggers
that wake the Wireless Communication Doorbell also cause the
doorbell to begin providing power to the camera and cause the
camera to record video and/or images that are sent to the Smart
Device (i.e., exit the camera sleep mode and enter a camera
recording mode) . . . .

Id. at 28–29 (citing Ex. 1005 ¶¶ 86, 76, 46, 66).
Petitioner further refers to Almomani as teaching this limitation. Id.
at 29–30. Almomani teaches that “the camera could be selectively activated
remotely by a user” to capture video for streaming. Ex. 1006 ¶ 21. For
example, the user can use a “dedicated app on a mobile device” “to activate
a remote monitoring mode.” Id. “In this mode, the electronic lock could be
configured to continuously stream video . . . .” Id. “This provides the user
with peace of mind to remotely see the area surrounding the electronic lock.”
Id.
Relying on Dr. Madisetti, Petitioner asserts that a person of ordinary
skill in the art
would have found it predictable and obvious to combine
Almomani’s method of using a mobile device and a wireless
communication to selectively activate a remote camera with
Siminoff’s doorbell system so that a user of the smart device
could remotely wake up the Wireless Communication Doorbell
and activate the camera such that it begins recording video.
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Pet. 31 (citing Ex. 1003, 58). Petitioner combines Almomani and Siminoff’s
teachings as follows:
[T]he Wireless Communication Doorbell that is configurable to
exit a low power mode in response to a wireless activation
trigger signal from a user of a remote communication device, as
taught by Siminoff, in view of the wireless camera that is
activated and begins streaming video in response to a wireless
communication from a mobile phone, as taught by Almomani,
renders obvious “overriding, by the remote computing device
via a wireless communication, a power setting of the doorbell to
force the doorbell to exit the camera sleep mode and enter a
camera recording mode.”

Id. at 31–32 (citing Ex. 1003, 50–59).
With respect to the claimed “wherein the camera recording mode
consumes more power than the camera sleep mode,” Petitioner contends
“Siminoff discloses this limitation because it teaches that when the
components of the Wireless Communication Doorbell are in a ‘state of
hibernation’ and inactive, the doorbell is in a ‘low power consumption
mode’ (i.e., a mode that consumes less power) as compared to the doorbell’s
‘active mode.’” Id. at 32 (citing Ex. 1005 ¶¶ 90, 87, Abstract). In contrast,
Petitioner asserts, “when the doorbell exits the hibernation mode, ‘it may
activate all components,’ which may include ‘provid[ing] the power to
activate Camera 18.’” Id. (citing Ex. 1005 ¶¶ 90, 76, 46, 66, 86–87, code
(57); Ex. 1003, 61).
Patent Owner contends Almomani and Siminoff fail to meet this
limitation because “neither reference teaches or discloses (1) that the remote
computing device overrides a power setting of the doorbell or (2) that that
[sic] the remote compute [sic] device causes the camera to enter a camera
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recording mode.” PO Resp. 13. We address each of these contentions in
turn below.
(1) Patent Owner’s argument regarding
“overriding . . . a power setting of the doorbell”
Patent Owner asserts that “[c]laim 1 requires that the ‘remote
computing device’ ‘overrid[e] . . . a power setting of the doorbell,’ not that
the doorbell changes power settings itself.” Sur-Reply 2. According to
Patent Owner, “Siminoff does not disclose that the ‘remote computing
device’ ‘overrides [the] power setting of the doorbell.’” PO Resp. 14 (citing
Ex. 2001 ¶ 44). “Instead, all that is disclosed is that the remote computing
device sends an activation trigger, and in response ‘the processor’ switches
from ‘low power mode to active mode.’” Id. Patent Owner and Dr. Baker
contend, “Siminoff contains no disclosure that the activation trigger itself
forces or causes the doorbell to change the power setting.” Id.; Ex. 2001
¶ 45. Patent Owner elaborates, “[m]ere disclosure that the processor is
switched from lower power mode to active mode in response to receiving a
‘signal,’ does not render obvious to a [person of ordinary skill in the art] that
the remote communication device, itself, can override a power setting of the
doorbell as required by the claim.” Sur-Reply 3.
We disagree with Patent Owner’s argument because it is not
commensurate with the scope of claim 1. Claim 1 recites, in relevant part,
“overriding, by the remote computing device via a wireless communication,
a power setting of the doorbell.” Thus, the claim language requires a
method in which the remote computing device sends a wireless
communication to override a power setting of the doorbell. Contrary to
Patent Owner’s argument, claim 1 recites neither the contents of that
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wireless communication nor the functions used to accomplish overriding the
doorbell’s power signal. See Sur-Reply 2 (asserting that “[t]he ’109 patent
requires that the remote computing device contain the code and instructions
for changing the power setting of the doorbell”); see also id. at 3 (arguing
that “Petitioner points to no disclosure from Siminoff concerning the
contents of [Siminoff’s] ‘signal’”). Indeed, Patent Owner fails to cite any
limitations of the challenged claim in support of this argument. Id.
The Specification is similarly silent as to contents of the wireless
communication and the functions through which the doorbell’s power signal
is overridden. The Specification recites, “the remote computing device 204
may send a signal 604 to the doorbell 202 that overrides the sleep mode
(e.g., changes a power setting 702) to cause the doorbell 202 to ‘wake up.’”
Ex. 1001, 12:16–19. The Specification makes no mention of the contents of
signal 604 sent from remote computing device 204 to doorbell 202 nor
imposes any requirement that the overriding occurs without the use of any
code residing at doorbell 202. Therefore, reading the claim language in light
of the Specification, we decline Patent Owner’s invitation to import into the
claim language a requirement “that the remote computing device contain the
code and instructions for changing the power setting of the doorbell.” Sur-
Reply 2.
We further disagree with Patent Owner’s argument because it fails to
account for the complete teachings of Siminoff cited by Petitioner. Patent
Owner asserts that, although Siminoff discloses changing the power setting
of the doorbell in response to activation triggers “such as a ‘button signal’
created by pushing a button, or a ‘sensor signal’ created by triggering the
infrared sensor in the doorbell,” Petitioner’s reliance on these activation
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triggers is allegedly misplaced because “[n]one of these activation signals
originate from the remote computing device.” Sur-Reply 3. We are not
persuaded by this argument because Siminoff’s claim 1 recites “switching
the processor from low-power mode to active mode in response to an
activation trigger” “wherein the activation trigger comprises . . . a signal
from the user at the remote communication device.” Ex. 1005, claim 1.
Based on this disclosure, we agree with Petitioner and Dr. Madisetti that,
“[b]ecause Siminoff makes no distinction between these ‘activation
triggers,’ a POSITA would, at the very least, find it obvious that the
activation trigger from the remote computing device changes the power
setting of the ‘Doorbell’ (just like the other two activation triggers).”
Reply 7–8 (citing Ex. 1003 ¶¶ 50–52, 57, 60, pages 45–46, 50–59).
(2) Patent Owner’s argument regarding
“camera recording mode”
Claim 1 recites, in relevant part, “overriding . . . to force the doorbell
to exit the camera sleep mode and enter a camera recording mode.” Patent
Owner contends that “the Petition and Dr. Madisetti fail to show that
Siminoff discloses ‘enter a camera recording mode’ in response to the
communication from the remote computing device as required by the claim.”
PO Resp. 15 (citing Ex. 2001 ¶ 46). According to Patent Owner, “Siminoff
provides no teaching that the activation trigger sent from the remote
computing device has any effect on the camera.” Id.
Patent Owner further argues that Almomani fails to teach the claimed
entering a camera recording mode because “Almomani simply discusses
using the remote computing device to ‘selectively active’ or ‘activate a
remote monitoring mode’ in which the lock ‘continuously streams video.’”
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Id. at 17 (citing Pet. 29–30; Ex. 1003, 58–59). Patent Owner elaborates that
the “‘recording mode’ requires the recording of video” and argues that
“[t]here is no disclosure in Almomani of recording the continuously
streamed video for later use.” Id. (citing Ex. 1003 ¶ 51). According to
Patent Owner, Petitioner’s declarant Dr. Madisetti concedes that “a POSITA
would not generally consider ‘the ability to continuously stream video [a]s
the equivalent of entering a camera recording mode as required by this
limitation.’” Sur-Reply 5 (citing Ex. 2003, 32:18–24).
We disagree with Patent Owner’s argument because it fails to account
for the complete teachings of Siminoff and Almomani cited by Petitioner. In
particular, we disagree with Patent Owner that Siminoff lacks a teaching or
suggestion of entering a camera recording mode in response to the wireless
communication from the remote computing device (PO Resp. 15) because
Siminoff describes “upon depressing Button 11 or another trigger may cause
Camera 18 of Wireless Communication Doorbell 61 to record a static or
continuous video image.” Ex. 1005 ¶¶ 86, 107. Siminoff thus teaches using
its activation triggers to cause the camera within its doorbell to record video.
Id. As discussed above, Siminoff discloses its activation triggers include “a
signal from the user at the remote communication device.” Ex. 1005, claim
1. Accordingly, we agree with Petitioner that Patent Owner’s “argument is
unpersuasive because it ignores Siminoff’s explanation that the infrared
sensor, the button, or ‘another trigger’ can cause the doorbell to activate and
begin recording a static or continuous video image.” Reply 8.
Moreover, assuming arguendo we were to agree with Patent Owner
that Almomani’s live stream mode does not, standing alone, meet the
claimed camera recording mode, Patent Owner fails to explain persuasively
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why the cited combined teachings of Almomani and Siminoff would not
meet the disputed limitation. Specifically, Siminoff discloses, “[i]n one
aspect of the present disclosure, the video and/or still images recorded by
Camera 18 may be collected and stored in Database 64 within System
Network 52, in conjunction with the routing of said video and/or still
images.” Ex. 1005 ¶ 76. Siminoff thus teaches storing the video recorded at
its camera for later use. Patent Owner fails to explain persuasively why
Almomani’s live stream mode, when combined with this teaching of
Siminoff, would not meet the claimed camera recording mode. See Sur-
Reply 5–6. Instead, Patent Owner contends “the combination of Siminoff
with Almomani would frustrate Siminoff’s intended purpose of saving
power.” Id. at 6. We address this argument above in the context of
Petitioner’s showing of a motivation to combine Siminoff and Almomani.
See supra Section III.C.3.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine the combined teachings of Siminoff and Almomani
meet the claimed “overriding, by the remote computing device via a wireless
communication, a power setting of the doorbell to force the doorbell to exit
the camera sleep mode and enter a camera recording mode, wherein the
camera recording mode consumes more power than the camera sleep mode.”
g) “receiving a first video . . . in response to remotely overriding the power
setting of the doorbell”
Claim 1 recites “receiving a first video, by the remote computing
device, from the doorbell at least partially in response to remotely overriding
the power setting of the doorbell.” Petitioner contends that Siminoff and
Almomani together render this limitation obvious. Petitioner argues that
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“Siminoff teaches that its Smart Device receives video captured by the
camera of the Wireless Communication Doorbell in response to activation
triggers bringing the doorbell out of the hibernation mode.” Pet. 33 (citing
Ex. 1005 ¶¶ 86, 66, 46, 76). In addition, the portion of Almomani upon
which Petitioner relies (Pet. 34) teaches “the camera could be selectively
activated remotely by a user. For example, the user could access and set
configurable options through a designated website or use a dedicated app on
a mobile device.” Ex. 1006 ¶ 21. Almonani continues:
If the user wanted to remotely monitor the electronic lock 100,
the user could log in to a designated website (or use an app) to
activate a remote monitoring mode. In this mode, the electronic
lock could be configured to continuously stream video,
regardless of whether the motion sensor 103 is activated or not.

Id. Relying on Dr. Madisetti, Petitioner contends an ordinarily skilled
artisan “would have found it predictable and obvious to combine
Almomani’s method of streaming video with Siminoff’s doorbell system so
the Smart Device receives video from the Wireless Communication Doorbell
when the Smart Device wakes the doorbell up with the wireless activation
signal.” Pet. 34 (citing Ex. 1003, 64). Specifically, Petitioner asserts:
Thus, receiving a video at the Smart Device in response
to waking up the Wireless Communication Doorbell from
hibernation mode with an activation trigger, where one
activation trigger is a signal from a remote device, as taught by
Siminoff, in view of Almomani’s teaching of receiving a video
at a mobile device from a door-based camera after remotely
activating it with a mobile device, renders obvious “receiving a
first video, by the remote computing device, from the doorbell
at least partially in response to remotely overriding the power
setting of the doorbell.”

Id. (citing Ex. 1003, 61–64).
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Patent Owner does not dispute Petitioner’s contentions on this
limitation. See generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we determine the combined
teachings of Siminoff and Almomani meet the claimed “receiving a first
video, by the remote computing device, from the doorbell at least partially in
response to remotely overriding the power setting of the doorbell.”
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine Petitioner has established by a preponderance of the
evidence that the combined teachings of Siminoff and Almomani render
obvious claim 1.
D. Asserted Obviousness of Claim 7 over Siminoff and Imao
1. Imao
Imao describes a system with a network camera that “distributes
photographed still image data or photographed moving image data.”
Ex. 1007, 15:31–39. Imao teaches that its network camera is controlled
“according to an instruction sent by a client apparatus via a network.” Id. at
15:39–43. For example, Imao’s system allows a user to “display
photographed images, operate the camera, or perform system settings” with
a “mobile phone.” Id. at 15:49–53. Imao teaches that its camera has a “low
power consumption state,” and when “no application communication is
performed, the network camera 1401 powers off each hardware device in the
camera system unit 1403.” Id. at 16:62–65. The camera wakes from its low
power state upon receiving “a TCP packet requesting a start of a TCP
connection” from a client apparatus for an application such as video
streaming. Id. at 16:62–17:28, 17:54–18:3. When the communication
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session request is received, the camera system “powers on devices necessary
for performing the application communication.” Id.
2. Motivation to Combine Siminoff and Imao
Petitioner asserts that a person of ordinary skill in the art “would have
found it obvious, beneficial, and predictable to implement Imao’s method of
waking a camera upon receiving a communication session in the context of
Siminoff’s video doorbell system in order to increase the responsiveness of
the doorbell.” Pet. 36 (citing Ex. 1003 ¶¶ 69–76). According to Petitioner,
both references are “directed to allowing a user to remotely view images and
video from a network camera on a client device.” Id. (citing Ex. 1005 ¶ 79;
Ex. 1007, 15:44–48; Ex. 1003 ¶ 70).
Petitioner contends that an ordinarily skilled artisan “would have been
motivated to apply Imao’s known camera activation technique to Siminoff’s
Wireless Communication Doorbell to yield the predictable result of
Siminoff’s activation signal being a packet that requests a start of a
communication session, such that the Wireless Communication Doorbell
records a video when it receives the activation signal.” Id. at 37 (citing
Ex. 1003 ¶ 71). According to Petitioner, “the proposed modification would
reduce lag when a user requests video because the doorbell would begin
waking before the request is provided.” Id. at 38 (citing Ex. 1003 ¶ 72).
Also, “modifying Siminoff to include Imao’s remote camera activation
technique would allow the doorbell to stay in the hibernation mode and to
save power when not in use, but, at the same time, be responsive to the user
commands by coming out of hibernation in anticipation of a user sending
commands.” Id. at 38–39 (citing Ex. 1003 ¶ 72). Petitioner contends that
one of ordinary skill in the art would find the proposed modification
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predictable and likely to result in success because “[s]ubstituting and
modifying standardized and interchangeable components within a system
such as Siminoff’s would have been well within the skill of a POSITA in
2014.” Id. at 39 (citing Ex. 1005 ¶¶ 64, 77, 79; Ex. 1007, 15:50–55, 18:15–
17; Ex. 1003 ¶¶ 74–75; Ex. 1011).
Patent Owner does not address Petitioner’s contentions. See generally
PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find one of ordinary skill in the
art would have been motivated to combine the teachings of Siminoff and
Imao, as Petitioner proposes, and would have had a reasonable expectation
of success in doing so.
3. Claim 7
a) “A method of using a doorbell system . . . comprising: coupling . . .;
detecting . . .; entering . . . configured not to record”
Claim 7 recites, “[a] method of using a doorbell system, wherein the
doorbell system comprises a remote computing device and a doorbell having
a camera, the method comprising: coupling communicatively the doorbell
and the remote computing device; detecting, by the doorbell system, an
indication of a presence of a visitor; entering, by the doorbell, a camera sleep
mode in which the camera is configured to not record.”
Petitioner relies on Siminoff as meeting this subject matter in the
same manner as discussed above in the context of commensurate limitations
of claim 1. Pet. 40 (incorporating analysis of commensurate limitations of
claim 1). Patent Owner does not address these limitations of claim 7. See
generally PO Resp.; Sur-Reply.
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Based on the complete trial record, we find that Siminoff meets this
claimed subject matter for the same reasons discussed above in the context
of claim 1. See supra Section III.C.4.a.–d.
b) “exiting . . . in response to receiving, by the doorbell, a first wireless
communication session from the remote computing device”
Claim 7 recites, “exiting, by the doorbell, the camera sleep mode and
entering a camera recording mode in response to receiving, by the doorbell,
a first wireless communication session from the remote computing device.”
Petitioner contends that Siminoff and Imao meet the claimed exiting step.
Pet. 40–45. In particular, Petitioner contends “Siminoff teaches that several
different activation triggers . . . can bring the Wireless Communication
Doorbell out of the low power/hibernation mode,” including “a signal from
the user at the remote communication device.” Id. at 41 (citing Ex. 1005,
claim 1, ¶¶ 46, 66, 76). Petitioner continues, “Siminoff teaches that its
doorbell system includes a ‘Smart Device’ that wirelessly controls the
Wireless Communication Doorbell.” Id. (citing Ex. 1005, ¶¶ 77, 79, 88,
Fig. 12). Petitioner further alleges, “Siminoff teaches that at least some of
the activation triggers that wake the Wireless Communication Doorbell also
cause the doorbell to provide power to the camera and cause the camera to
record video and/or images that are sent to the Smart Device (i.e., exit the
camera sleep mode and enter a camera recording mode.” Id. at 41–42 (citing
Ex. 1005, ¶¶ 46, 66, 76, 86).
Against this backdrop, Petitioner contends, “it was well known prior
to the ’109 Patent for a network camera to wake up and begin recording
when it receives a communication session over a wireless network.” Id. at
42 (citing Ex. 1003, 77). As an example, Petitioner asserts, “Imao’s network
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camera exits the low power state and powers on the components, such as the
imaging unit, when . . . receiving a communication session in the form of a
‘TCP packet requesting a start of a TCP connection.’” Id. at 43–44 (citing
Ex. 1007, 17:8–28, 17:31–36, 18:10–17; Ex. 1003, 80–81). Petitioner adds,
“Imao teaches that one type of application communication session that may
be started by this technique is video streaming.” Id. at 44 (citing Ex. 1007,
17:16–28, 17:54–18:1).
Patent Owner does not address Petitioner’s contentions. See generally
PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find the combined teachings of
Siminoff and Imao meet the claimed “exiting, by the doorbell, the camera
sleep mode and entering a camera recording mode in response to receiving,
by the doorbell, a first wireless communication session from the remote
computing device.”
c) “receiving, by the remote computing device, a first video recorded by
the camera of the doorbell”
Claim 7 recites, “receiving, by the remote computing device, a first
video recorded by the camera of the doorbell.” Petitioner relies on Siminoff
as meeting this claim limitation because Siminoff discloses, “[i]n one aspect,
upon depressing Button 11 or another trigger may cause Camera 18 of
Wireless Communication Doorbell 61 to record a static or continuous video
image, which is sent to User 62 along with notification at Smart Device 54.”
Ex. 1005 ¶ 86 (quoted in Pet. 45–46).
Patent Owner does not address Petitioner’s contentions. See generally
PO Resp.; Sur-Reply.
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Based on the foregoing evidence, we find Siminoff meets the claimed
receiving, by the remote computing device, a first video recorded by the
camera of the doorbell.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine Petitioner has established by a preponderance of the
evidence that the combined teachings of Siminoff and Imao render obvious
claim 7.
E. Asserted Obviousness of Claims 20 and 21 over Siminoff, Imao,
and Huisking
1. Huisking
Huisking teaches a doorbell system including “[a]n audio/video
intercom doorbell” with “a camera, a microphone, a speaker, and one or
more doorbell user interfaces.” Ex. 1008 ¶ 37. Huisking describes
establishing a communication session between the doorbell system and a
smartphone so that, for example, the smartphone may be alerted to doorbell
events. Id. ¶¶ 62–63.
Huisking describes various embodiments including these doorbell
event alerts. For instance,
On mobile computing device platforms which support multi-
tasking applications, at a time of application startup, the
application may initiate an audio session with the doorbell
security system board 210 over an IP (internet protocol) link
using SIP (Session Initiation Protocol) protocol. The
application may run in background mode thus permitting a user
to work on other applications.

Id. ¶ 62. Huisking continues, “[t]he background application/OS (operating
system) may listen on a VOIP (Voice Over IP) socket, and arrival of data
packets on this socket may notify the user of the event.” Id.
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“On platforms which do not support multi-tasking
(Background/Foreground applications) operations, a separate server based
notification may be required to notify the mobile computing device
application about a doorbell event.” Id. ¶ 64. Huisking describes that, in
this embodiment, notifications may be pushed by various types of servers to
mobile computing device 220 in order to display an event on the device. Id.
In a portion of Huisking on which Petitioner relies, Huisking discloses
“an embodiment of the present invention configured to support Android.”
Ex. 1008 ¶ 85, cited in Pet. 54. Therein, Huisking describes establishing a
Session Initiation Protocol (SIP) “when the Android device is powered on by
starting the application and running it in the background.” Ex. 1008 ¶ 85. A
“doorbell press event may be notified by transmitting data over the SIP
connection between the board 210 and the registered Android device 220
(which may be running the application in the background).” Id. The SIP
may be used to establish audio communication between the board 210 and
the Android device 220, whereas video and control signal communication
may be established over HTTP or TCP/IP connections, respectively. Id.
Huisking similarly describes establishing a SIP connection when an iOS
device “is powered on” or “when the application starts up” and using this
connection to transmit audio data for a doorbell press event to the device.
Id. ¶¶ 83–84.
2. Motivation to Combine Siminoff, Imao, and Huisking
Petitioner asserts, “a person of ordinary skill in the art would have
found it obvious, beneficial, and predictable to modify the combination of
Siminoff and Imao to include Huisking’s technique of establishing a
communication session between a doorbell and a mobile device when the
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mobile device wakes up.” Pet. 48 (citing Ex. 1003 ¶¶ 83–93). According to
Petitioner, all three references are “directed to networked camera systems
that stream video to a mobile device.” Id. (citing Ex. 1008 ¶ 48).
Petitioner contends that an ordinarily skilled artisan “would have been
motivated to apply Huisking’s method of starting a communication session
immediately upon waking up a smartphone to Siminoff’s system in order to
improve the responsiveness of the doorbell to user commands, such as
streaming video requests.” Id. at 49 (citing Ex. 1003 ¶ 86). According to
Petitioner and Dr. Madisetti, the proposed modification would “allow[] the
doorbell to be ready to respond to user commands when the doorbell
application is subsequently opened.” Id. at 50; Ex. 1003 ¶ 87. Also,
“modifying Siminoff . . . would allow the doorbell to stay in the hibernation
mode and to save power when not in use, but, at the same time, be
responsive to the user commands by coming out of hibernation in
anticipation of a user sending commands.” Pet. 50 (citing Ex. 1003 ¶ 88).
Petitioner contends that one of ordinary skill in the art would find the
proposed modification predictable and likely to result in success because
“[s]ubstituting and modifying standardized and interchangeable components
within a system such as Siminoff’s would have been well within the skill of
a POSITA in 2014.” Id. at 50–51 (citing Ex. 1008 ¶¶ 26, 54; Ex. 1003
¶¶ 89–90; Ex. 1011).
Patent Owner does not address Petitioner’s contentions. See generally
PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find one of ordinary skill in the
art would have been motivated to combine, as Petitioner proposes,
“Huisking’s known technique of establishing a communication session
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between a doorbell and a mobile device when the mobile device wakes up to
Siminoff’s doorbell system (as modified by Imao) because the combination
amounts to applying a known technique to a video doorbell ready for
improvement” (Pet. 51 citing Ex. 1003 ¶ 91), and would have had a
reasonable expectation of success in doing so.
3. Claim 20
a) “A method of using a doorbell system . . . comprising”
Claim 20 recites, “[a] method of using a doorbell system, wherein the
doorbell system comprises a remote computing device and a doorbell having
a camera, the method comprising.”
Petitioner relies on Siminoff as meeting this subject matter in the
same manner as discussed above in the context of the commensurate
limitation of claim 1. Pet. 52 (incorporating analysis of the commensurate
limitation of claim 1). Patent Owner does not address this limitation of
claim 20. See generally PO Resp.; Sur-Reply.
Based on the complete trial record, we find that Siminoff meets this
claimed subject matter for the same reasons discussed above in the context
of claim 1. See supra Section III.C.4.a.
b) “sending . . . in response to waking the remote computing device prior
to opening a doorbell control application on the . . . device”
Claim 20 recites, “sending a first signal from the remote computing
device to the doorbell in response to waking the remote computing device
prior to opening a doorbell control application on the remote computing
device.” Petitioner relies upon Siminoff in view of Imao and Huisking as
meeting this limitation, and in particular on Huisking as teaching that, “in
Huisking’s doorbell system, the mobile device establishes a communication
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session with the doorbell in response to the device waking up and starting—
but not opening—an application so that the mobile device can communicate
with the doorbell.” Pet. 54 (citing Ex. 1008 ¶ 62; Ex. 1003 ¶ 101). Patent
Owner counters that the cited portions of Huisking fail to the meet the claim
limitation at issue because “as taught by Huisking, whether running in the
foreground or in the background the application has still been opened as of
the time that Huisking teaches that the signal is sent.” PO Resp. 21 (citing
Ex. 2001 ¶ 60).
We turn first to the question of what is encompassed by the claimed
communication between the remote computing device and the doorbell. We
begin our analysis with the disputed claim language, as would have been
understood by an artisan of ordinary skill in the content of the remainder of
the claim and the Specification. Here, the plain language of claim 20 clearly
contemplates communication between the remote computing device and the
doorbell before the application is open because the claim language defines a
method in which the remote computing device wakes up and sends a first
signal to the doorbell before the application is opened. Ex. 1001, 20:59–62.
We note the claim language is silent as to how or by whom the application is
opened. See id.
Petitioner contends, and we agree, that “the embodiment in the
[S]pecification that most closely parallels the limitations of claim 20 is also
consistent with the above understanding,” namely that claim 20
encompasses methods in which the remote computing device is powered on
and in communication with the doorbell before the doorbell control
application is opened. Reply 19; see Ex. 1021 ¶ 12. The relevant portion of
the Specification states:
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In several embodiments, a signal 604 can be sent from
the remote computing device 204 to the doorbell 202 in
response to waking the remote computing device 204 prior to
opening a doorbell control application 600 on the remote
computing device 204 . . . . The first signal 604 may be sent in
response to, for example, turning on the remote computing
device 204.

Ex. 1001, 16:1–11. We find this portion of the Specification describes an
embodiment in which the remote computing device is turned on,
communication occurs between the remote computing device and doorbell,
and then the doorbell control application on the device is opened.
Drs. Madisetti and Baker agree that, in this embodiment, the
communication between the remote computing device and doorbell
occurring prior to opening the application is performed via the application.
Ex. 1020, 47:2–5 (Deposition Testimony of Dr. Baker) (“Q. Would you
agree, then, that the doorbell control application is the means by which the
remote computing device communicates with the doorbell? A. Yes.”);
Ex. 1021 ¶ 12 (Supplemental Declaration of Dr. Madisetti). Based on this
testimony, we find one of ordinary skill in the art would understand that the
disputed claim language encompasses communication between the remote
computing device and the doorbell, via the doorbell control application,
before the doorbell control application is opened.
We turn next to the question of what is encompassed by the claimed
opening of the doorbell control application. Petitioner contends that one of
ordinary skill in the art would have a general understanding in computer
science at the time that “an application running in the background of a
mobile device is not ‘open.’” Reply 17 (citing Ex. 1021 ¶ 5). According to
Petitioner, “[w]hether an application is ‘open’ is based on the perspective of
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a user—and thus an application is not open until it is brought to the
foreground and viewable by the user.” Id. (citing Ex. 1021 ¶ 5). In support
of this assertion, Petitioner proffers Dr. Madisetti’s testimony and several
examples of usage of “the terms ‘open’ and ‘opening’ in computer science
patent literature to describe a mobile application being brought to the
foreground of a computing device—rather than the application merely
starting and running in the background.” Id. (citing Ex. 1021 ¶¶ 6–10). For
instance, Petitioner and Dr. Madisetti direct our attention the following uses
of “open”:
• U.S. Patent No. 10,367,814, which states, in relevant part,
“even if the mobile device user does not actively open
unsecured mobile application 702, its background process 706
may be activated by default once mobile device 720 is powered
on.” (id. citing Ex. 1019, 24:52–57; Ex. 1021 ¶ 6);
• U.S. Patent No. 9,071,923, which states, in relevant part, “[t]he
automatic archiver program determines whether to archive an
application based on, for example, how frequently a user opens
the application (e.g., touching on the application icon and
brining [sic] the application to the foreground).” (id. at 18
citing Ex. 1015, 2:25–28; Ex. 1021 ¶ 7);
• U.S. Pat. No. 9,338,594, which states, in relevant part, “[i]n
some embodiments, the collection of location information . . .
is done at the time that Bob opens up his app (e.g., in the
foreground), or can also be done in the background.” (id. at 18
citing Ex. 1018, 3:52–57; Ex. 1021 ¶ 7).
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Patent Owner and Dr. Baker counter that, “[c]ontrary to the arguments
made in the Petition, a [person of ordinary skill in the art] would understand,
based on at least the teaching of Huisking[,] that an application that is started
is opened.” PO Resp. 20; Ex. 2001 ¶ 59. Patent Owner elaborates that
Huisking teaches that “at a time of application startup, the application may
initiate an audio session with the doorbell security system board 210.” PO
Resp. 21 (quoting Ex. 1008 ¶ 62). According to Patent Owner, this teaching
of Huisking shows “the signal from the remote computing device is sent
only after opening the doorbell control application on the remote computing
device, not before.” Id. (citing Ex. 2001 ¶ 59). Patent Owner does not
respond to Petitioner’s evidence of common usage of the term “open” in
computer science. See generally Sur-Reply.
As we observed above, claim 20 is silent on how or by whom the
application is opened. See Ex. 1001, 20:59–62. The Specification, however,
describes the doorbell control application being opened by the user. See,
e.g., Ex. 1001, 9:60–65 (“The user can open the software application on the
computing device 204 and instruct the application to show live video and/or
audio from the security device 202 . . . .”); see also id. at 12:24–28 (“In
some embodiments, a remote computing device can display a live video
from the doorbell camera in response to a user opening a doorbell control
application on the remote computing device.”), 13:55–57, 14:20–23. We
find these passages of the Specification suggest that the user opens the
application.
Petitioner’s evidence of common usage of the term “open” in the art,
including the testimony of Dr. Madisetti and the various additional
references described above, is unrebutted in the record before us. We find
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this evidence supports Petitioner’s contention that one of ordinary skill in the
art would understand that “an application is not ‘open’ until it is brought to
the foreground and viewable by the user.” Reply 17 (citing Ex. 1021 ¶ 5).
Rather than rebut Petitioner’s evidence, Patent Owner offers only
Dr. Baker’s conclusory declaration testimony that an “application is
‘started,’ i.e. open, when the signal is sent by the remote computing device
to start the SIP session.” PO Resp. 20 (citing Ex. 2001 ¶ 58). This
statement, however, is in tension with Dr. Baker’s subsequent deposition
testimony that the ’109 Patent discloses an embodiment of its invention in
which the remote computing device is turned on, communication occurs
between the remote computing device and the doorbell, and the doorbell
control application is not yet opened by the user. Ex. 1020, 47:21–48:7
(discussing Ex. 1001, 16:1–11). In particular, Dr. Baker opines, “I think it’s
safe to assume that the application is not opened by the user, but running as
a background program.” Id. Patent Owner does not explain in the record
before us how one might harmonize this statement with Dr. Baker’s earlier
testimony that an ordinarily skilled artisan would understand an application
started in the background to be open. See Ex. 2001 ¶ 58.
Accordingly, based on the complete trial record and in particular on
the foregoing facts and analysis, we find a person of ordinary skill in the art
would have understood claim 20 to encompass communication between the
device and doorbell, including via the application running in the background
upon startup of the device, prior to the application being opened by the user.
With this understanding of the claim scope, we turn next to the teachings of
Huisking.
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Petitioner contends, “Huisking’s teaching of a doorbell application
running in the background and sending a request signal prior to a user
bringing the application to the foreground, together with Siminoff and Imao,
renders obvious claim 20.” Reply 21; see also Pet. 54 (citing Ex. 1008 ¶ 62;
Ex. 1003 ¶ 101). Patent Owner counters that the cited portions of Huisking
fail to the meet the claim limitation at issue because “as taught by Huisking,
whether running in the foreground or in the background[,] the application
has still been opened as of the time that Huisking teaches that the signal is
sent.” PO Resp. 21 (citing Ex. 2001 ¶ 60).
We find Huisking teaches using a Session Initiation Protocol (SIP) to
establish communication between its doorbell and an application on a
remote device upon start of the device and before the application is brought
to the foreground of the device. Huisking discloses, “[o]n mobile computing
device platforms which support multi-tasking applications, at a time of
application startup, the application may initiate an audio session with the
doorbell security system board 210 over an IP (internet protocol) link using
SIP (Session Initiation Protocol) protocol. The application may run in
background mode thus permitting a user to work on other applications.”
Ex. 1008 ¶ 62. Huisking further describes establishing audio
communication between its doorbell security system board 210 and an
Android device 220 using SIP “when the Android device is powered on by
starting the application and running it in the background.” Ex. 1008 ¶ 85. A
“doorbell press event may be notified by transmitting data over the SIP
connection between the board 210 and the registered Android device 220
(which may be running the application in the background).” Id. Huisking
similarly describes establishing a SIP connection when an iOS device “is
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powered on” or “when the application starts up” and using this connection to
transmit audio data for a doorbell press event to the device. Id. ¶¶ 83–84.
Although Huisking does not use the word “open” to describe its
application, regardless of whether running in the background or foreground,
(see generally Ex. 1008), Huisking discloses that the communication
established upon waking the device and starting the application allows the
background application to “listen on a VOIP (Voice Over IP) socket” for the
“arrival of data packets on this socket [to] notify the user of the event.” Id.
¶ 62. “The application may run in background mode thus permitting a user
to work on other applications.” Id. In light of these teachings, we disagree
with Patent Owner’s assertion that Huisking’s “application has still been
opened as of the time that Huisking teaches that the signal is sent.”
PO Resp. 21 (citing Ex. 2001 ¶ 60). Rather, we find that one of ordinary
skill in the art would understand Huisking’s establishing a SIP connection
between doorbell security system board 200 and a remote device when the
device is powered on and running in the background to meet the claimed
“prior to opening a doorbell control application on the remote computing
device.” See Ex. 1008 ¶¶ 62, 83–85; see also Pet. 52–55; Reply 15–18.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine the cited teachings of Huisking meet this claimed
subject matter.
c) “exiting, . . . a camera sleep mode in which the doorbell camera is
configured to not record and entering a camera recording mode;”
Claim 20 recites, “exiting, by the doorbell, in response to the first
signal, a camera sleep mode in which the doorbell camera is configured to
not record and entering a camera recording mode.”
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Petitioner relies on Imao’s teaching of receiving a request for a TCP
communication session as meeting this claim limitation in the same manner
as discussed above in the context of the commensurate limitation of claim 7.
Pet. 55 (incorporating analysis of the commensurate limitation of claim 7).
Patent Owner does not address this limitation of claim 20. See generally PO
Resp.; Sur-Reply.
Based on the complete trial record, we find that Imao meets this
claimed subject matter for the same reasons discussed above in the context
of claim 7. See supra Section III.D.3.b.
d) “wherein the camera recording mode consumes more power than the
camera sleep mode.”
Claim 20 recites, “wherein the camera recording mode consumes
more power than the camera sleep mode.”
Petitioner relies on Siminoff as meeting this claim limitation in the
same manner as discussed above in the context of the commensurate
limitation of claim 1. Pet. 56 (incorporating analysis of the commensurate
limitation of claim 1). Patent Owner does not address this limitation of
claim 20. See generally PO Resp.; Sur-Reply.
Based on the complete trial record, we find that Siminoff meets this
claimed subject matter for the same reasons discussed above in the context
of claim 1. See supra Section III.C.4.f.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine Petitioner has established by a preponderance of the
evidence that the combined teachings of Siminoff, Imao, and Huisking
render obvious claim 20.
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4. Claim 21
a) “The method of claim 20, further comprising recording, by the doorbell
camera, a first video in response to the first signal.”
Claim 21 recites, “[t]he method of claim 20, further comprising
recording, by the doorbell camera, a first video in response to the first
signal.” Petitioner relies on Siminoff and Imao’s teachings as meeting this
claim limitation in the same manner as discussed above in the context of the
commensurate limitation of claim 7. Pet. 56–57 (incorporating analysis of
the commensurate limitation of claim 7). Patent Owner does not address this
limitation of claim 21. See generally PO Resp.; Sur-Reply.
Based on the complete trial record, we find that Siminoff and Imao’s
teachings meet this claimed subject matter for the same reasons discussed
above in the context of claim 7. See supra Section III.D.3.c.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine Petitioner has established by a preponderance of the
evidence that the combined teachings of Siminoff, Imao, and Huisking
render obvious claim 21.
F. Asserted Obviousness of Claim 15 over Siminoff ’618 and Huisking
1. Siminoff ’618
Siminoff ’618 is a published parent application to the Siminoff
reference discussed above. Like Siminoff, Siminoff ’618 teaches activation
triggers that bring Wireless Communication Doorbell 61 out of hibernation
mode. Ex. 1009 ¶¶ 69, 75. Claims 1 and 2 of Siminoff ’618 recite switching
the doorbell “from low-power mode to active mode in response to an
activation trigger” where “the activation trigger includes . . . activation of an
application running on a remote device.” Ex. 1009, claims 1 and 2.
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2. Motivation to Combine Siminoff ’618 and Huisking
Petitioner asserts, an ordinarily skilled artisan “would have found it
obvious, beneficial, and predictable to implement Huisking’s technique in
the context of Siminoff ’618, such that when the application on the Smart
Device is activated (as recited in claims 1 and 2), a signal is transmitted to
the Wireless Communication Doorbell that not only brings it out of
hibernation but also triggers the camera to begin recording.” Pet. 59–60
(citing Ex. 1003 ¶¶ 100–108). According to Petitioner, both references are
“directed to wireless video doorbell systems that stream video to a mobile
device.” Id. at 60 (citing Ex. 1008 ¶ 48; Ex. 1009 ¶ 62; Ex. 1003¶ 101).
Petitioner contends that an ordinarily skilled artisan would have been
“motivated to apply Huisking’s known video doorbell technique to the
Wireless Communication Doorbell of Siminoff ’618.” Id. at 61 (citing
Ex. 1003 ¶ 102). According to Petitioner, the proposed modification “would
have furthered Siminoff’s goal of allowing users to ‘see who is within view
of Wireless Communication Doorbell 61 at any given time’ in a reduced
amount of time.” Id. (citing Ex. 1009 ¶ 62; Ex. 1003 ¶ 103). Petitioner
further contends “the above combination would allow the doorbell to save
power in hibernation mode, but, at the same time, allow a user to selectively
request a video stream of the area around the doorbell by activating the
application.” Id. at 62 (citing Ex. 1003 ¶ 105). According to Petitioner, one
of ordinary skill in the art would find the proposed modification predictable
and likely to result in success because “[s]ubstituting and modifying
standardized and interchangeable components within a system such as
Siminoff’s would have been well within the skill of a POSITA in 2014.” Id.
at 62–63 (citing Ex. 1003 ¶¶ 106–107; Ex. 1011).
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Patent Owner does not address Petitioner’s contentions. See generally
PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find one of ordinary skill in the
art would have been motivated to combine, as Petitioner proposes,
“Huisking’s known video doorbell technique to the Wireless
Communication Doorbell of Siminoff ’618 to yield the predictable result of
Siminoff’s Smart Device sending a signal (e.g., an HTTP request) to the
doorbell when the application is opened and the doorbell’s camera activating
and recording video to be displayed in the application on the mobile device,”
(Pet. 61 citing Ex. 1003 ¶ 102), and would have had a reasonable
expectation of success in doing so.
3. Claim 15
a) “A method of using a doorbell system . . . comprising:”
Claim 15 recites, “[a] method of using a doorbell system, wherein the
doorbell system comprises a remote computing device and a doorbell having
a doorbell camera, the method comprising.”
Petitioner contends, “[j]ust like Siminoff, Siminoff ’618 teaches a
method of using a doorbell system that includes a Smart Device, such as a
smartphone, and a Wireless Communication Doorbell with a camera.”
Pet. 63–64 (citing Ex. 1009 ¶ 71; Ex. 1003, 124–128). Petitioner continues,
“Siminoff ’618 teaches that the smart device ‘may be any electronic device
capable of receiving and transmitting data via the internet’ including
‘smartphones.’” Id. at 64 (citing Ex. 1009 ¶ 62).
Patent Owner does not address this subject matter of claim 15. See
generally PO Resp.; Sur-Reply.
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Based on the foregoing evidence, we find that Siminoff ’618 meets
this claimed subject matter.
b) “coupling communicatively the doorbell and the remote computing
device”
Claim 15 recites, “coupling communicatively the doorbell and the
remote computing device.”
Petitioner contends, “Siminoff ’618 teaches communicatively
coupling the Wireless Communication Doorbell and the smart device via a
‘wireless telecommunications network’ (System Network 52) and a wireless
User’s Network 65.” Pet. 64–65 (citing Ex. 1009 ¶¶ 60, 61, 71; Ex. 1003
¶¶ 128–124).
Patent Owner does not address this limitation of claim 15. See
generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find that Siminoff ’618 meets
this claimed subject matter.
c) “detecting, by the doorbell system, an indication of a presence of a
visitor”
Claim 15 recites, “detecting, by the doorbell system, an indication of a
presence of a visitor.”
Petitioner contends that Siminoff ’618 teaches detecting the presence
of a visitor with a doorbell button push or with an infrared sensor. Pet. 66
(citing Ex. 1009 ¶¶ 29, 49, 69).
Patent Owner does not address this limitation of claim 15. See
generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find that Siminoff ’618 meets
this claimed subject matter.
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d) “opening a doorbell control application on the remote computing
device”
Claim 15 recites, “opening a doorbell control application on the
remote computing device.”
Petitioner contends that Siminoff ’618 teaches “Application 55 may
be installed on Smart Device 54 and provide an interface for User 62 to
communicate and Interact with Wireless Communication Doorbell 61,”
including allowing “the user to view still images or video taken by the
Wireless Communication Doorbell 61, focus or zoom Camera 18, and
communicate with a visitor.” Pet. 66–67 (citing Ex. 1009 ¶¶ 59, 63).
Patent Owner does not address this limitation of claim 15. See
generally PO Resp.; Sur-Reply.
Based on the foregoing evidence, we find that Siminoff ’618 meets
this claimed subject matter.
e) “sending, automatically, a first signal from the . . . device to the
doorbell in response to opening the doorbell control application”
Claim 15 recites, “sending, automatically, a first signal from the
remote computing device to the doorbell in response to opening the doorbell
control application.”
Petitioner contends Siminoff ’618 and Huisking together meet this
limitation. Pet. 68–70. According to Petitioner, “Siminoff ’618 teaches that
several different activation triggers can bring the Wireless Communication
Doorbell out of the low power/hibernation mode” and that one such trigger
is “activation of an application running on a remote device.” Id. at 68 (citing
Ex. 1009 ¶¶ 29, 49, 59, claims 1, 2).
Regarding the claimed automatic sending, Petitioner combines the
foregoing disclosures of Siminoff ’618 with “Huisking’s teaching of
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automatically sending an HTTP request signal from a remote device to a
wireless doorbell in response to opening an application on the remote
device.” Id. at 70. In particular, Petitioner relies on Huisking’s teachings
that: after “the application is invoked, the user may be able to view the video
(H.264, MJPEG) being captured by the camera installed with the doorbell
unit” (Ex. 1008 ¶¶ 36, 46, 48); “[w]hen the application starts, an HTTP
request may be sent to the board 210 which may respond with the web page
containing a video frame (first in a sequence of digital video frames” (Ex.
1008 ¶¶ 97, 98); and when the control application is “brought to the
foreground,” “[t]he mobile computing device application may subsequently
initiate an http (HyperText Transfer Protocol)/RTP (Realtime Transport
Protocol) session with the board to download the video” (Ex. 1008 ¶¶ 62,
65). Pet. 58, 59, 69.
Patent Owner contends Petitioner’s proposed combination fails to
meet the claimed “sending, automatically” because “the cited teaching from
Huisking states only that the sending of this signal is optional, and there is
no disclosure that the signal is sent in response to opening the doorbell
control application as required by the claim.” PO Resp. 22 (citing Ex. 2001
¶ 65). Patent Owner and Dr. Baker explain, “every citation to Huisking
relied on by the Petition and Dr. Madisetti provides that sending the signal to
the doorbell is optional—Huisking uses only the word ‘may.’” Id. at 24; Ex.
2001 ¶ 66. Patent Owner further asserts, “in the paragraph 62 embodiment,
the application is already opened and the signal is only sent ‘if the user
acknowledges the event.’” PO Resp. 24
The ’109 patent’s Specification states, “automatically, i.e. without the
user instructing.” Ex. 1001, 15:11–16. Petitioner treats this statement as
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definitional. Reply 21–22. Patent Owner does not address the import of this
statement on the claim term. Sur-Reply 8–10. The United States Court of
Appeals for the Federal Circuit instructs that a patentee is free to act as their
own lexicographer in order “to define the specific terms used to describe his
or her invention, [but] this must be done with reasonable clarity,
deliberateness, and precision.” In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
1994). Here, we agree with Petitioner and find this statement defines the
claim term automatically as “without the user instructing” because the
definition employs the term “i.e.” (“id est” or “that is”), which “signals an
intent to define the word to which it refers.” Edwards Lifesciences LLC v.
Cook Inc., 582 F.3d 1322, 1334 (Fed. Cir. 2009); see SkinMedica, Inc. v.
Histogen Inc., 727 F.3d 1187, 1202 (Fed. Cir. 2013) (“i.e.” is definitional
when it “comports with the inventors’ other uses . . . in the specification and
with each and every other reference”).
With this understanding of the claim term “automatically,” we turn to
the cited passages of Huisking. Huisking discloses:
• “The background application/OS (operating system) may listen
on a VOIP (Voice Over IP) socket, and arrival of data packets
on this socket may notify the user of the event. If the user
acknowledges the event, . . . . the application may be brought to
the foreground. The mobile computing device application may
subsequently initiate an http (HyperText Transfer Protocol)
/RTP (Realtime Transport Protocol) session.” (Ex. 1008 ¶ 62);
• “If a user acknowledges the event, then the OS may bring up
the doorbell security system application. The application may
then initiate an http/RTP session with the board 210 to
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download the video and may use the SIP connection for bi-
directional audio communication.” (id. ¶ 65);
• “When the application starts, an HTTP request may be sent to
the board 210 . . . .” (id. ¶¶ 97, 98).
Petitioner asserts that, as described in these passages, “Huisking’s
HTTP request signal is sent ‘automatically’ upon the application opening
because it is the application that initiates the sending, not the user—the user
simply opens the application.” Reply 21–22. Patent Owner contends that
these passages fail to “teach the timing associated with that sending of the
signal at all” and instead “only teach that the application is brought to the
foreground and then, at some unspecified time in the future, a signal ‘may’
be sent.” Sur-Reply 8–9.
We disagree with Patent Owner’s argument because it is misdirected
at “timing.” As stated above, the Specification defines the claim term
automatically as “without the user instructing.” Ex. 1001, 15:11–16. This
definition does not require that the claimed sending be performed
immediately in response to opening the doorbell control application, as
Patent Owner’s argument suggests. Rather, claim 15, as read in light of the
Specification’s definition of automatically, requires only that the sending
occur without the user instructing after opening the application.
With respect to Patent Owner’s argument that, in Huisking’s
embodiment at paragraph 62, “the application is already opened and the
signal is only sent ‘if the user acknowledges the event’” (PO Resp. 24; Sur-
Reply 9), we disagree with Patent Owner’s argument because it is premised
on the notion that Huisking’s application is open upon powering the device
when the application monitors in the background for a doorbell event. As
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discussed above in the context of claim 20, we find one of ordinary skill in
the art would not understand Huisking’s application to be “open” until it is
brought to the foreground. See supra Section III.E.3.b.
Finally, we agree with Petitioner that “Huisking’s HTTP request
signal is sent ‘automatically’ upon the application opening because it is the
application that initiates the sending, not the user—the user simply opens
the application.” Reply 21–22. The cited passages of Huisking describe
that, once the user opens the application by bringing it to the foreground, the
HTTP request signal is sent without the user instructing. Ex. 1008 ¶¶ 62, 65,
97, 98. We further agree with Petitioner that Huisking’s use of “may” in the
cited passages denotes merely that configurations excluding the HTTP
request signal are contemplated, but when included, the HTTP request signal
is sent after opening the application without the user instructing. Reply 23
(citing Ex. 1008 ¶¶ 62, 97, 98).
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine the cited teachings of Huisking meet this claimed
subject matter.
f) “exiting, . . . wherein the camera recording mode consumes more
power than the camera sleep mode”
Claim 15 recites, “exiting, by the doorbell, in response to the first
signal, a camera sleep mode in which the doorbell camera is configured to
not record and entering, by the doorbell, a camera recording mode, wherein
the camera recording mode consumes more power than the camera sleep
mode.”
Petitioner contends Siminoff ’618 and Huisking together meet this
limitation. “[W]ith respect to the recited ‘camera sleep mode,’ Siminoff
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’618 teaches that the Wireless Communication Doorbell enters a
‘hibernation’ mode during which the camera is inactive and does not record
images or video.” Pet. 70 (citing Ex. 1009 ¶ 73). “Siminoff ’618 calls this
state of hibernation ‘a low power consumption mode.’” Id. (citing Ex. 1009
¶ 73, code (57)). Siminoff ’618 further teaches that, during the low power
consumption mode, the camera is inactive and without power until activated
by an activation trigger. See Ex. 1009 ¶ 59 (“In reference to FIG. 12, after
Button 11 is pressed, Power Processor 51 may provide the power to activate
Camera 18”); see also id. ¶¶ 29, 46, 49, code (57). Claims 1 and 2 of
Siminoff ’618 recite switching the doorbell “from low-power mode to active
mode in response to an activation trigger” where “the activation trigger
includes . . . activation of an application running on a remote device.” Id.,
claims 1, 2.
Petitioner further alleges, “Huisking teaches that in response to the
application being opened on its mobile device and the HTTP request being
sent to the doorbell camera, real-time video from the camera is streamed to
the remote device.” Pet. 72–73 (citing Ex. 1009 ¶¶ 97, 98). According to
Petitioner, an artisan of ordinary skill “would have found it obvious to
implement Huisking’s technique in Siminoff[ ’618]’s video doorbell system
so that when the doorbell application on Siminoff’s smart device is activated
and the activation trigger is sent to the Wireless Communication Doorbell to
wake it up, real-time video would be streamed to the smart device for
immediate viewing by the user.” Id. at 73 (citing Ex. 1003, 145).
Patent Owner does not address this limitation of claim 15. See
generally PO Resp.; Sur-Reply.
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Based on the foregoing evidence, we find that Siminoff ’618 and
Huisking together meet this claimed subject matter.
Accordingly, based on the complete trial record and for the foregoing
reasons, we determine Petitioner has established by a preponderance of the
evidence that the combined teachings of Siminoff ’618 and Huisking render
obvious claim 15.

IV. CONCLUSION8
For the reasons discussed above, we determine Petitioner has proven,
by a preponderance of the evidence, that the challenged claims are
unpatentable, as summarized in the following table:

8 Should Patent Owner wish to pursue amendment of the challenged claims
in a reissue or reexamination proceeding subsequent to the issuance of this
decision, we draw Patent Owner’s attention to the April 2019 Notice
Regarding Options for Amendments by Patent Owner Through Reissue or
Reexamination During a Pending AIA Trial Proceeding. See 84 Fed. Reg.
16654 (Apr. 22, 2019). If Patent Owner chooses to file a reissue application
or a request for reexamination of the challenged patent, we remind Patent
Owner of its continuing obligation to notify the Board of any such related
matters in updated mandatory notices. See 37 C.F.R. § 42.8(a)(3), (b)(2).
Claim(s)
35
U.S.C.
§
Reference(s)/Basis
Claims
Shown
Unpatentable
Claims
Not Shown
Unpatentable
1 103 Siminoff,
Almomani
1
7 103 Siminoff, Imao 7
20, 21 103 Siminoff, Imao,
Huisking
20, 21
15 103 Siminoff ’618,
Huisking
15
Overall
Outcome
1, 7, 15, 20,
21

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V. ORDER
Accordingly, it is:
ORDERED that claims 1, 7, 15, 20, 21 of the ’109 patent have been
shown to be unpatentable; and
FURTHERED ORDERED that, because this is a Final Written
Decision, parties to the proceeding seeking judicial review of the Decision
must comply with the notice and service requirements of 37 C.F.R. § 90.2.
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PETITIONER:
Scott T. Jarratt
Andrew S. Ehmke
Brian Graham
HAYNES AND BOONE, LLP
scott.jarratt.ipr@haynesboone.com
andy.ehmke.ipr@haynesboone.com
brian.graham.ipr@haynesboone.com

PATENT OWNER:
Neil Rubin
Kent Shum
RUSS AUGUST & KABAT
nrubin@raklaw.com
kshum@raklaw.com