PTAB

IPR2015-01245

MobileIron Inc v. Good Technology Software Inc

Key Events

Petition

petition Intelligence

Title: GLOBAL SERVER FOR AUTHENTICATING ACCESS TO REMOTE SERVICES
Brief Description: The ’344 patent discloses a system where a "global server" acts as an intermediary to provide a remote user with authenticated access to a service on a separate "service server." The global server performs two distinct authentications—one for itself and one for the service server—before establishing authenticated communications between the remote terminal and the service.

Prior Art Relied Upon: Hu (Patent 5,586,260).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Hu discloses a system structurally and functionally identical to that claimed in the ’344 patent. Hu’s "gateway system" performs the role of the claimed "global server," its "client system" is the "remote user terminal," and its "server system" is the "service server." Petitioner asserted that Hu’s gateway performs a first authentication to verify the client’s identity with respect to itself (within the "client security domain") and then performs a second authentication with respect to the service server by obtaining and using server-specific credentials to impersonate the client. This two-step authentication process, conducted by an intermediary gateway, allegedly maps to all limitations of independent claims 1 and 21.
- Motivation to Combine (for §103 grounds): To the extent any features were considered part of different embodiments within Hu, Petitioner argued a POSITA would combine them. The explicit teachings of Hu allegedly provided the motivation to integrate its various disclosed features into a single, functional system.
- Expectation of Success (for §103 grounds): Success was expected because combining features from within a single reference to achieve the system’s stated purpose was a straightforward design choice for a POSITA.

Prior Art Relied Upon: Hu (Patent 5,586,260) and Rossmann (Patent 5,809,415).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended this combination renders obvious dependent claims related to mobile devices, internet communication, and retrieving service addresses. While Hu provides the core two-step authentication architecture, Rossmann supplies the missing elements. Rossmann teaches using a mobile terminal (a cellular telephone analogous to a smartphone) to access remote services over the Internet via a web browser. Rossmann’s "AirNet Network Translator" acts as an intermediary that retrieves the IP address of the appropriate service server from a database, teaching the limitations of retrieving a service address to establish a communication link.
- Motivation to Combine: A POSITA would combine Hu and Rossmann to apply Hu’s robust authentication solution to the growing field of mobile computing described in Rossmann. Rossmann identified the need to merge computing with wireless communications for low-cost devices, and Hu provided a known solution for allowing such clients to securely access services without conforming to complex server-side protocols.
- Expectation of Success: The combination was expected to be successful and predictable, as it amounted to using a known authentication architecture (Hu) with a different, but common, type of client device (Rossmann's mobile terminal).

Prior Art Relied Upon: Hu (Patent 5,586,260), Rossmann (Patent 5,809,415), and Liu (Patent 5,953,005).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed claims requiring the remote terminal to be configured using a "downloadable executable" that authenticates the user. Petitioner argued that Liu teaches the use of downloaded applets to perform user authentication before granting access to encrypted online multimedia content. This directly teaches the claimed concept of using a downloadable program to manage authentication on the client side.
- Motivation to Combine: A POSITA would be motivated to incorporate Liu’s applet-based authentication into the Hu/Rossmann framework to enhance flexibility. Using downloadable applets for authentication was a well-known technique that allowed security mechanisms to be updated on the server side without requiring permanent software changes on the vast number of client devices.
- Expectation of Success: There was a high expectation of success because using applets for authentication in conjunction with web browsers was a common and well-understood practice at the time for providing secure access to remote services.
Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) based on combining Hu with McNair (Patent 5,276,444) to teach providing authenticated access to services on the basis of different authentication levels associated with respective services.

"Remote User Terminal": Petitioner proposed the construction "a network-connected computing device capable of retrieving web content." This broad construction was important for mapping Hu’s general "client system" and Rossmann's mobile telephone to the claimed terminal.
"authenticate" / "authentication": Petitioner proposed this term means "a process, consisting of one or more factors, used to identify an individual." This construction supported the argument that Hu's use of passwords and security contexts met the claim limitation.
"authentication level[s]": Petitioner proposed the construction "strengths of identifying an individual." This was used to argue that prior art references teaching different security requirements for different services met the limitations of certain dependent claims.

Priority Date Challenge: A central contention was that the ’344 patent was not entitled to its earliest claimed priority date of December 13, 1996 (from the ’116 patent). Petitioner argued that the ’116 patent fails to disclose the core limitation of performing two distinct authentications (one to the global server and one to the service server). Therefore, the patent’s effective priority date should be no earlier than April 8, 1997, which allows references like Rossmann to qualify as prior art under §102(e).

Petitioner requested institution of inter partes review and cancellation of claims 1-40 of the ’344 patent as unpatentable.