PTAB

IPR2018-01104

Google LLC v. Seven Networks LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Mobile Network Services
  • Brief Description: The ’433 patent relates to a system for providing wireless mobile device network services. The disclosed technology operates within a mobile virtual network (MVNO) architecture, where a first server provides content to a mobile device and a second server monitors usage for services branded by an entity other than the underlying mobile network operator.

3. Grounds for Unpatentability

Ground 1: Obviousness over Vu and Kumar - Claims 1, 9, 10, 12, 13, 15-18, 24, 25, 27, and 29 are obvious over Vu in view of Kumar.

  • Prior Art Relied Upon: Vu (Application # 2008/0133569) and Kumar (Patent 8,971,846).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Vu, which describes a content delivery system for an MVNO (“Amp’d Mobile”), disclosed most limitations of independent claims 1 and 16. Vu’s system included a “first server” (a combination of its handset content server and content server) that provided a service branded by an entity (Amp’d Mobile) other than the underlying network operator (e.g., Verizon or Telus). Vu also taught transmitting a list of available digital content to a mobile device and transferring selected content. Petitioner contended that Kumar, which relates to services in a mobile network, supplied the missing limitation of receiving a “unique authentication token” from the mobile device. Kumar disclosed authenticating a subscriber using a unique identifier like an IMSI or user ID. Petitioner asserted that Kumar also taught monitoring network usage (e.g., bandwidth), which rendered obvious the ’433 patent’s claimed second server for monitoring usage.
    • Motivation to Combine: A POSITA would combine Kumar with Vu to implement a necessary and well-known feature—user authentication—into Vu's content delivery system. Petitioner argued this was a simple combination of known elements to improve security. A POSITA would also have been motivated to incorporate Kumar's usage monitoring to enable accurate billing for the services provided in Vu, a desirable commercial feature.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references because it involved applying a standard authentication method and a known usage monitoring technique to a content delivery system to achieve the predictable results of a secure and commercially viable service.

Ground 2: Obviousness over Vu, Kumar, and Mehta - Claims 2 and 14 are obvious over Vu in view of Kumar and Mehta.

  • Prior Art Relied Upon: Vu (Application # 2008/0133569), Kumar (Patent 8,971,846), and Mehta (Application # 2002/0131404).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Vu and Kumar combination by adding Mehta to address limitations in dependent claims 2 and 14. Claim 2 required configuring downloaded content to be removed after a period of time. Petitioner asserted Mehta taught this by disclosing the deactivation of applications after a time limit has expired, such as for a trial period. Claim 14 required enforcing a service policy that includes optimizing file size. Petitioner argued Mehta disclosed this by teaching an “Optimize Application routine” that shortens file sizes by removing unused code and shortening variable names.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Mehta’s teachings into the Vu/Kumar system to add desirable features. The ability to remove content after a set time would enhance the system by enabling trial versions and managing device storage. Optimizing file size would predictably reduce network load and improve transmission efficiency.
    • Expectation of Success: Integrating these known content management and optimization techniques from Mehta into the base system would have been a straightforward modification with predictable benefits.

Ground 3: Obviousness over Vu, Kumar, Knight, and Morse - Claims 5, 20, 26, 28, and 30 are obvious over Vu in view of Kumar, Knight, and Morse.

  • Prior Art Relied Upon: Vu (Application # 2008/0133569), Kumar (Patent 8,971,846), Knight (WO 2006/061587), and Morse (Application # 2006/0274869).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Knight and Morse to address limitations related to formatting content based on device and network characteristics. Petitioner argued that Knight taught selecting an application format based on device-specific attributes like screen size, resolution, processing power, and memory size. Morse was cited for teaching the formatting of content based on the available mobile network connection bandwidth. Morse disclosed dynamically generating content optimized for a device based on its "current network connection," which may include bandwidth information.
    • Motivation to Combine: A POSITA would combine Knight and Morse to improve the user experience and efficiency of the Vu/Kumar system. Incorporating Knight's teachings would ensure that content is formatted appropriately for a user's specific device. Adding Morse's bandwidth-based formatting would enable the system to optimize data delivery, such as by reducing resolution in low-bandwidth conditions, thereby improving performance.
    • Expectation of Success: These modifications represented the application of well-known optimization strategies to a content delivery network, which would have predictably resulted in a more robust and user-friendly system.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Vu, Kumar, and Knight with Rafey (for user-selectable and preset formatting preferences), Ray (for screen resolution formatting based on content type), Mehta (for pre-provisioning formatted content), Baldursson (for receiving user-uploaded content), and Kasriel (for pre-downloading anticipated content).

4. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-30 of the ’433 patent as unpatentable.