PTAB

IPR2018-01150

Unified Patents LLC v. Mobility Workx LLC

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1. Case Identification

2. Patent Overview

  • Title: Proactive Network Resource Allocation for Mobile Devices
  • Brief Description: The ’417 patent discloses a system for preemptively allocating network resources for mobile devices traveling between networks. It utilizes proxy entities, a "ghost-mobile node" and a "ghost-foreign agent," to predict a mobile node's future location and proactively establish communication links before the mobile node arrives in a new network, thereby reducing handover delays.

3. Grounds for Unpatentability

Ground 1: Claims 1, 5, and 6 are obvious over Liu in view of Gwon

  • Prior Art Relied Upon: Liu (Patent 5,825,759) and Gwon (Application # 2002/0131386).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Liu discloses the core elements of independent claim 1, including a system with proxy entities ("M-agent" and "MF-agent") that function as the claimed ghost-mobile and ghost-foreign agents to pre-connect services for a mobile user. However, Liu’s system requires a request to initiate this process. Petitioner asserted that Gwon remedies this deficiency by teaching a "Neighbor Discovery" process where a router (a foreign agent) sends an unsolicited "Router Advertisement" message to announce its presence. This unsolicited message from Gwon, when applied to Liu's framework, allegedly meets the "advertises messages" limitation. For dependent claim 5, Gwon teaches using GPS and triangulation to determine location information, which could trigger Liu's resource allocation. For claim 6, Gwon teaches that advertisement messages can indicate the presence of "other local routers," fulfilling the limitation of populating messages with the care-of-addresses of neighboring foreign agents.
    • Motivation to Combine: A POSITA would combine Gwon’s well-known, unsolicited "Neighbor Discovery" protocol with Liu’s predictive handoff system to improve efficiency. This combination would decrease handover latency and reduce the computational burden on the mobile device by removing the need for it to initiate a request, representing a natural and predictable evolution of the technology.
    • Expectation of Success: Applying a standard network discovery protocol from Gwon to a mobile handoff system like Liu was presented as combining known elements to achieve the predictable result of a more efficient handover process.

Ground 2: Claims 2 and 3 are obvious over Liu in view of Gwon and Lau

  • Prior Art Relied Upon: Liu (Patent 5,825,759), Gwon (Application # 2002/0131386), and Lau (Patent 7,536,482).
  • Core Argument for this Ground:
    • Prior Art Mapping: Building on Ground 1, Petitioner argued that Liu discloses a "replica of the mobile node" (an "AM-agent" that acts on behalf of the home M-agent in a foreign network) and the required registration signaling. Lau, which was not cited during prosecution of the ’417 patent, was cited to explicitly teach the "tunneling" of encapsulated messages from a home agent to a foreign agent to maintain routing information, as required by claim 2. For claim 3, Gwon provides the teaching of triggering signaling based on a "threshold distance" to a network node, with the distance determined using GPS data such as trajectory and speed.
    • Motivation to Combine: A POSITA would add Lau’s well-known tunneling technique to the Liu/Gwon combination to gain the known benefits of encapsulated packet forwarding, such as secure and efficient data delivery between different networks. Adding Gwon’s threshold-based triggering mechanism would be a simple substitution of one known location-prediction method for another to achieve more reliable and automated handoffs.
    • Expectation of Success: Petitioner contended that implementing standard tunneling (Lau) and threshold-based triggers (Gwon) into Liu's architecture were routine design choices for improving mobile network performance, with predictable and beneficial outcomes.

Ground 3: Claim 4 is obvious over Liu in view of Gwon and IETF RFC 2402

  • Prior Art Relied Upon: Liu (Patent 5,825,759), Gwon (Application # 2002/0131386), and IETF RFC 2402 (Nov. 1998).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground also builds on the base combination of Liu and Gwon. Petitioner argued that Gwon teaches triggering pre-hand-off processing of "authentication and security measures" based on a mobile node's distance to a foreign agent. To supply the specific details for this, Petitioner pointed to IETF RFC 2402, which is incorporated by reference in Gwon. RFC 2402 discloses standard security protocols for Mobile IP, including the use of MD5 authentication algorithms to create "keyed Message Authentication Codes," which meets the claim limitation of "relaying security and shared secrets."
    • Motivation to Combine: Gwon explicitly incorporates RFC 2402 by reference, providing a direct motivation to combine. A POSITA would have found it obvious and necessary to implement these standard security protocols within the Liu/Gwon framework to ensure data integrity during the pre-registration process, a commonplace practice in the field.
    • Expectation of Success: Adding standardized and widely adopted security protocols from RFC 2402 to a Mobile IP system was a well-understood and predictable step to enhance security without introducing undue complexity.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 7 based on the combination of Liu and Lau, relying on similar theories for combining predictive mobility management with methods for determining distance to the closest foreign agent.

4. Key Claim Construction Positions

  • Petitioner argued that the term "advertisement" should be construed to mean "a notification of the presence of a foreign agent in the foreign network." This construction is critical to Petitioner's argument that Gwon's unsolicited Router Advertisement messages satisfy the "advertises" limitation of claim 1 when combined with Liu's request-based system.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-7 of Patent 8,213,417 as unpatentable.