PTAB

IPR2014-00037

Google Inc v. Unwired Planet LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Controlling Access to Location Information for Wireless Communications Devices
  • Brief Description: The ’752 patent describes methods for protecting user privacy by managing access to a mobile device's location information. The disclosed system uses subscriber profiles containing permission sets to grant or deny location information requests from client applications based on predefined rules, such as temporal or spatial limitations.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 25-29 are anticipated by Havinis ’102 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Havinis ’102 (Patent 6,360,102).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Havinis ’102 teaches every limitation of the challenged claims. Havinis ’102 discloses a telecommunications system that allows a mobile subscriber to define a "Subscriber Location Privacy Profile" (SLPP), which constitutes the claimed subscriber profile. The SLPP contains a list of authorized client applications (Location Applications or LAs) and a permission set defining the conditions under which they can access the device's location. These conditions explicitly include temporal limitations such as "certain hours of the day, certain days of the week," thereby satisfying the claim requirement for "at least one of a spatial limitation...or a temporal limitation." The system retrieves and queries this SLPP to determine if a requesting application is authorized and if the temporal conditions are met, and denies access if they are not. Petitioner asserted this mapping covers all steps of independent claim 25 and that dependent claims 26-29 are also taught through disclosures of notifying applications of rejection and allowing subscribers to update the SLPP.

Ground 2: Obviousness - Claims 25-29 are obvious over Havinis ’102 in view of Piccionelli under 35 U.S.C. §103.

  • Prior Art Relied Upon: Havinis ’102 (Patent 6,360,102) and Piccionelli (Patent 6,154,172).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Havinis ’102 teaches most claim limitations. To the extent Havinis ’102 is found not to explicitly teach a spatial limitation, Piccionelli supplies it. Piccionelli discloses a system for limiting information distribution based on geographic location, using a "pre-stored...table or list of products or services which have geographic limitations or restrictions." Petitioner contended this list is analogous to a subscriber profile, and the associated geographic restrictions constitute a permission set with a spatial limitation on access to location information.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Piccionelli’s geographic-based access controls with the SLPP system of Havinis ’102. This would be a predictable modification to enhance the privacy features of Havinis ’102 by adding a known type of restriction (spatial) to the existing temporal ones, achieving the predictable result of more robust privacy control.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying a known method of privacy management (location-based restrictions) to an existing privacy profile system.

Ground 3: Obviousness - Claims 25-29 are obvious over Havinis ’931 in view of Piccionelli under §103.

  • Prior Art Relied Upon: Havinis ’931 (Patent 6,104,931) and Piccionelli (Patent 6,154,172).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Havinis ’931, which describes a system for defining location services, discloses the core method of controlling access. It teaches that location applications must register a "location services profile" with associated privacy settings, which Petitioner argued functions as the claimed subscriber profile. If the Board were to find that Havinis ’931 does not explicitly teach a permission set including spatial limitations, Piccionelli’s system of using pre-stored lists with geographic restrictions supplies this missing element.
    • Motivation to Combine: A POSITA would combine Piccionelli's geographic restriction functionality with the privacy profiles of Havinis ’931 to enhance the system's privacy controls. This combination would incorporate a well-understood method for location-based access control into the existing framework of Havinis ’931 to provide more granular privacy options for the user.
    • Expectation of Success: Combining these known elements for their intended and established functions would have yielded predictable results and was well within the skill of a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Havinis ’102 in view of Leonhardt; Havinis ’931 in view of Havinis ’102; Landgren in view of Piccionelli; Zellner in view of Havinis ’102; and Thomas in view of Havinis ’102.

4. Key Claim Construction Positions

  • "spatial limitation on access to the location information": Petitioner proposed this term means "limitation on access to location information that depends on the mobile device's current location at the time the request for location information is made." This construction was based on the specification's description of a "spatial permission set" that enables or denies access based on the device being within specific geographic areas.
  • "temporal limitation on access to the location information": Petitioner proposed this term means "limitation on access to location information that depends on the time when the request for location information is made." This was supported by the specification's disclosure of a "temporal permission set" that identifies the time of day or day of week when access is permitted.
  • "at least one of": Petitioner argued for the plain and ordinary meaning of "one or more." This construction clarifies that the claimed permission set does not require both a spatial and a temporal limitation, but only one of the two.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 25-29 of the ’752 patent as unpatentable.