Obviousness

Obviousness Analysis under 35 U.S.C. § 103 for U.S. Patent 8,914,526

This section analyzes the obviousness of U.S. Patent 8,914,526 under 35 U.S.C. § 103, considering combinations of prior art references. The objective is to identify whether the claimed invention, as a whole, would have been obvious to a person having ordinary skill in the art at the time of the invention (priority date: December 17, 1998).

Prior Art References:

1. Corcoran and Desbonnet, "Browser-style interfaces to a home automation network" (1997) (hereinafter "Corcoran"): This non-patent literature reference describes the use of a web browser and the World Wide Web (WWW) for both local and remote standard interfaces in a home automation network. It discusses browsing and navigation of network devices and context structures, and how a user can control these devices from any computer with an Internet connection via a conventional web browser and Java. However, Corcoran assumes that for remote monitoring and control, the site to be controlled is actively connected to the Internet at the time remote operation is desired.
2. PCT Patent Publication Number WO 94/24803 (hereinafter "WO '803"): This publication describes a communication node between data and telecommunication networks that enables communication between users using different types of terminals, such as telephones and computers.
3. PCT Patent Publication Number WO 98/19445 (hereinafter "WO '445"): This publication describes a service node between Internet networks and a telecommunications network used to order telephony services via HTML pages from a computer with a WWW browser. It also describes a method of calling a subscriber where the call is ordered by computer but the connection is set up between telephones. The service node communicates using HTTP protocol and stores subscriber data for telephony services.

Obviousness Combinations and Rationale:

The independent claims of US 8,914,526 (Claims 1, 57, 58, and 59) generally describe a system for remote access of home or user premises networks using a web browser, an extranet (which can be a VPN), communication servers, and in-home connection gateways. A key feature is the on-demand connection establishment initiated by the extranet's communication server to the home gateway, allowing monitoring and control via web pages served from the gateway, and explicit mention that the communication server does not directly connect to the networked components within the home.

Combination 1: Corcoran in view of WO '803 and WO '445

A person having ordinary skill in the art (PHOSITA) at the time of the invention would have been motivated to combine the teachings of Corcoran with those of WO '803 and WO '445 to arrive at the claimed invention.

Corcoran clearly establishes the concept of using a standard web browser for both local and remote monitoring and control of home automation networks. It teaches that the interface supports browsing and navigation of network devices and allows control from any internet-connected computer via a web browser. This addresses the core idea of web-based control and monitoring.

However, Corcoran has a notable limitation: it assumes the home automation site is actively connected to the Internet for remote operation. This is where the teachings of WO '803 and WO '445 become relevant.

• WO '803 discloses a communication node between data and telecommunication networks, enabling communication between different types of terminals. This teaches the general concept of interconnecting different networks and devices.
• WO '445 describes a service node between Internet and telecommunication networks that uses HTML pages and HTTP protocol for ordering telephony services and setting up connections. Critically, it describes a system where a service node communicates with computers using HTTP and stores subscriber data for telephony services, implying an on-demand connection or interaction.

Motivation for Combination:

The PHOSITA, recognizing the limitation in Corcoran regarding the need for a continuously active internet connection at the home, would have been motivated to find a more efficient and cost-effective way to establish remote connections. WO '445 provides a clear teaching of a "service node" (analogous to the communications server in '526) interacting with client computers over the Internet using HTTP and establishing connections over a telecommunications network based on stored subscriber data. It would have been obvious to adapt this "on-demand connection" mechanism from WO '445 to the remote home automation scenario described in Corcoran.

Specifically:

• Extranet and Communications Server (Claim 1, 58, 59): Corcoran describes remote access over the Internet. WO '445 describes a service node on an Internet network facilitating connections. The concept of an "extranet" as a private network overlaid on the Internet (as taught in US 8,914,526) would be an obvious architectural choice for security and managed access, particularly given the existing knowledge of VPNs for security and privacy at the priority date. The communications server in the extranet, as in US 8,914,526, would simply be the service node of WO '445, adapted to manage connections to home gateways rather than just telephony services.
• Connection Gateway (Claim 1, 57, 58, 59): Corcoran discusses "network devices" within the home automation network. The "gateway" in US 8,914,526 acts as a hub and internet connection mechanism for these devices. It would be obvious to a PHOSITA to implement Corcoran's network devices through a dedicated gateway at the user premises that can establish an on-demand connection to the external network, leveraging the teachings of WO '803 and WO '445 regarding communication nodes and service nodes facilitating connections over telecommunication networks. This gateway would contain the web server to serve information related to user premises appliances, as described in US 8,914,526, thereby handling the interaction with the home network devices locally and serving web pages to the remote user.
• On-Demand Connection and Authorization: The problem of an expensive, continuously active connection in Corcoran would naturally lead a PHOSITA to consider an "on-demand" connection. WO '445's service node that stores subscriber data and sets up connections provides a direct motivation for this. Integrating user authentication (as described in US 8,914,526) with the URL access and connection initiation process would be a standard security practice for any remote access system, especially one involving a "private" extranet.
• Serving Webpages from the Gateway (Claim 1, 57, 58, 59): Corcoran teaches using web pages for control and monitoring. US 8,914,526 specifies that the extranet obtains information from the connection gateway and serves a webpage to the Internet browser, and that control is possible only by interaction with information served by the gateway. This is directly supported by Corcoran's teaching of a "browser-style interface" where the user accesses HTML pages on the gateway for monitoring and control. The gateway web server serving information through HTML pages to the user is explicitly mentioned in US 8,914,526 and would be a straightforward implementation given Corcoran's premise.
• Mobile Device Access (Claim 59): Corcoran mentions access from "any computer with an Internet connection". At the priority date, the concept of mobile devices with web browsing capabilities was emerging (e.g., PDAs, early mobile phones with WAP). It would be an obvious design choice for a PHOSITA to extend the web-based remote monitoring and control system of Corcoran, combined with the on-demand connection mechanisms of WO '445, to mobile devices, especially given the general desire for ubiquitous access to control and monitoring systems. WO '445 already deals with "different types of terminals" for communication.

Therefore, the combination of Corcoran, WO '803, and WO '445 would render the independent claims of US 8,914,526 obvious to a PHOSITA. The motivation would be to overcome the limitations of continuous internet connectivity in Corcoran by employing known methods of on-demand connection establishment and authenticated access over telecommunication networks, as taught by the PCT publications, within the context of web-based home automation.