PTAB

IPR2018-00995

Shanghai Lunion Information Technologies, Ltd. v. Telefonaktiebolaget LM Ericsson

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1. Case Identification

2. Patent Overview

  • Title: System for Controlling Access to a Mobile Platform
  • Brief Description: The ’510 patent discloses a system to address the inflexibility of traditional mobile devices where manufacturers pre-install all hardware and software. The invention provides a "platform system" that allows later-developed, non-native applications to be installed and run by using an access controller to verify that the requesting application has the required permissions to utilize the platform's underlying native code and resources.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3 and 5-10 by Elson

  • Prior Art Relied Upon: Elson (Patent 7,207,041).
  • Core Argument for this Ground: Petitioner argued that Elson discloses an open platform architecture for managing shared resource access for non-native applications in a mobile telematics system, addressing the same portability and security problems as the ’510 patent.
    • Prior Art Mapping: Petitioner asserted that Elson discloses every element of the challenged independent claims. Elson’s “telematics platform” is the claimed “platform,” which includes a “software services component” (e.g., Elson’s OSGi Framework, Java platform, device drivers) and an “interface component” (e.g., Elson’s system call interface, OSGi Application Framework). The core of the argument is that Elson’s combination of a “Management and Registry Bundle” and a “Framework for User-Space Devices (FUSD)” module constitutes the claimed “access controller.” This controller includes an “interception module” that receives application requests (system calls) and a “decision entity” (Elson’s Resource Managers) that consults policies stored in a registry to grant or deny access, thus mapping to all limitations of claims 1 and 10. The dependent claims are allegedly met by Elson’s disclosure of using application IDs and maintaining collections of records (registries) with permissions.

Ground 2: Obviousness of Claims 4 and 5 over Elson in view of Hunnicutt

  • Prior Art Relied Upon: Elson (Patent 7,207,041) and Hunnicutt (Patent 5,889,952).
  • Core Argument for this Ground: This ground asserted that it would have been obvious to modify Elson's system to include the "decision cache" recited in claim 4.
    • Prior Art Mapping: Petitioner argued Elson provides the base system for managing application access as described in Ground 1. Hunnicutt was cited for its disclosure of an “access-permission caching system” that stores recently generated access permissions. This "access-cache" allows a system to efficiently check permissions for subsequent requests without re-reading a full Access Control List (ACL), directly teaching the functionality of the claimed decision cache.
    • Motivation to Combine: A POSITA would have been motivated to combine Hunnicutt’s well-known caching technique with Elson’s access control system to increase system efficiency. This is a common and predictable design choice, particularly in a system like Elson’s that anticipates resource contention from multiple applications, where reducing redundant processing is a primary goal.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success in implementing Hunnicutt's caching into Elson's software-based access control architecture, as it involved applying a known optimization to a known type of system.

Ground 3: Obviousness of Claims 1, 7, 9, and 10 over Zimmer

  • Prior Art Relied Upon: Zimmer (Application # 2003/0061497).
  • Core Argument for this Ground: Petitioner contended that Zimmer, which discloses using a virtual machine monitor (VMM) to provide pre-boot security and support legacy software on systems with an extensible firmware interface (EFI), renders the key claims obvious.
    • Prior Art Mapping: Zimmer’s VMM-based system was argued to be a “system for controlling access to a platform.” The platform itself consists of an EFI core and drivers (the “software services component”) and the VMM (the “interface component”), which allows non-native legacy applications to run. The VMM functions as the “access controller” by trapping instructions from untrusted programs (the “interception module”) and determining whether to grant access based on pre-boot security and integrity policies (the “decision entity”). For claim 9, Petitioner argued that Zimmer's teaching that its technique benefits "cost-sensitive, flash memory based systems" would have made its application to mobile terminals obvious to a POSITA.
    • Motivation to Combine (Implicit): The motivation was presented as inherent to Zimmer, which itself teaches the benefits of using its VMM architecture to securely run untrusted or legacy code on a modern platform.
    • Expectation of Success: Petitioner asserted that Zimmer explicitly describes a functioning system, providing a POSITA with a clear path and a high expectation of success for implementing a similar system for mobile applications.

4. Key Claim Construction Positions

  • "software services component" (claims 1, 10): Petitioner adopted a construction from prior litigation, defining the term as "a software component for providing services." This construction is broad and supported by Petitioner’s assertion that software like device drivers and operating systems in the prior art meet the limitation.
  • "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 allows the policies to be stored in a separate registry that the manager consults, aligning with the architectures described in both Elson and the ’510 patent.
  • "mobile terminal" (claim 9): Petitioner proposed the construction "an electronic terminal capable of communicating while moving in a cellular network." This definition was used to connect the teachings of prior art related to automotive telematics (Elson) and general cost-sensitive systems (Zimmer) to the mobile context of the patent.

5. Relief Requested

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