PTAB

IPR2018-00995

Shanghai LUnion Information Technologies Ltd v. Telefonaktiebolaget LM Ericsson

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Access Controller for Controlling Access to Software Services
  • Brief Description: The ’510 patent discloses a system for managing how non-native applications, installed by a user after manufacturing, can access the underlying native software and hardware resources of a computer system, particularly a mobile terminal. The core of the invention is an "access controller" that intercepts requests from these applications and determines whether to grant or deny access based on security policies.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 5-10 are anticipated by Elson.

  • Prior Art Relied Upon: Elson (Patent 7,207,041)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Elson discloses every element of the challenged claims. Elson describes an open platform architecture for managing access to shared resources in a mobile telematics system, addressing the same portability and security problems as the ’510 patent. Petitioner mapped the claimed "platform" having a "software services component" and an "interface component" to Elson’s telematics platform, which includes an OSGi framework, Java platform, and various drivers that provide services to applications via APIs and system call interfaces. The claimed "access controller" was mapped to Elson's combination of a "Management and Registry Bundle" and a redirection module (FUSD), which together control application access to system resources.
    • The claimed "interception module" corresponds to Elson's redirection module that receives system calls from applications. The "decision entity" and "security access manager" were argued to be disclosed in Elson's "Resource Managers" (e.g., UAX/UAC) and "Secure Bundle Manager and Registry," which consult stored policies and permissions to grant or deny resource requests based on an application's certified ID (UID).

Ground 2: Claims 4 and 5 are obvious over Elson in view of Hunnicutt.

  • Prior Art Relied Upon: Elson (Patent 7,207,041), Hunnicutt (Patent 5,889,952)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Elson reference for the limitations of the base claims. Claim 4 adds a "decision cache" for storing previous permission decisions to avoid re-evaluating every request. While Elson discloses an access control system with a registry, Petitioner argued it does not explicitly disclose caching these decisions. Hunnicutt was introduced because it teaches an "access-permission caching system" that stores recently granted permissions to increase system efficiency by avoiding the need to check a full access control list (ACL) for every subsequent request.
    • Motivation to Combine: A POSITA would combine Hunnicutt’s caching system with Elson’s access control architecture for the predictable benefit of improving performance and efficiency. Elson’s system, which manages requests from multiple applications, would face contention for resources, and implementing a well-known technique like caching from Hunnicutt would be a simple and logical way to speed up permission checks.
    • Expectation of Success: A POSITA would have a high expectation of success because caching is a standard and well-understood computer science technique for improving performance, and its application to an access control system like Elson's would be straightforward.

Ground 3: Claims 1, 7, 9, and 10 are obvious over Zimmer.

  • Prior Art Relied Upon: Zimmer (Application # 2003/0061497)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Zimmer discloses a system for controlling access by unverified or legacy applications to a hardware platform, thus teaching all elements of the independent claims. Zimmer’s system uses a virtual machine monitor (VMM) to create a secure environment on a platform with an extensible firmware interface (EFI). The claimed "platform" with a "software services component" was mapped to Zimmer's EFI platform, including the EFI core and drivers which provide basic services. The "interface component" and "access controller" were mapped to Zimmer’s VMM, which acts as an intermediary that traps requests from non-native legacy applications, inspects them, and decides whether to grant access to the underlying EFI services based on security and integrity policies.
    • Motivation to Combine: This ground primarily addresses claim 9, which recites a "mobile terminal." Petitioner argued that Zimmer teaches its invention is advantageous for "cost-sensitive, flash memory based systems," a description a POSITA would recognize as characteristic of mobile terminals at the time. Therefore, a POSITA would have been motivated to apply Zimmer’s security architecture to improve mobile terminal technology.
    • Expectation of Success: The combination would have been successful because applying Zimmer's VMM-based security model to a mobile platform would be a predictable application of the technology to a suitable environment explicitly contemplated by the reference.

4. Key Claim Construction Positions

  • "software services component" (claims 1, 10): Petitioner adopted the construction from a related district court case: "a software component for providing services." This construction is broad and supports mapping this element to the OS/driver layers in Elson and the EFI core/drivers in Zimmer.
  • "the security access manager holding access and permission policies" (claim 1): Petitioner proposed the construction "the security access manager storing or having access to access and permission policies." This interpretation is based on the specification and allows the policies to be stored in a registry that the manager consults, aligning with the architectures disclosed in Elson and Zimmer.
  • "mobile terminal" (claim 9): Petitioner proposed the construction "an electronic terminal capable of communicating while moving in a cellular network." This construction anchors the claim to the specific technical context described in the ’510 patent’s background.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 of the ’510 patent as unpatentable.