PTAB

IPR2019-00258

Apple Inc v. Uniloc 2017 LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Security-Focused Object-Oriented Authentication System
  • Brief Description: The ’298 patent discloses a system for authenticating access to a computer resource using security objects. These objects encapsulate security data (e.g., passwords, fingerprints), attributes defining the object's characteristics, and methods for operating on that data into a single, self-sufficient module to control access to secured items.

3. Grounds for Unpatentability

Ground 1: Obviousness over Morogan and Chapman - Claims 1-51 are obvious over Morogan in view of Chapman.

  • Prior Art Relied Upon: Morogan ("A Local Authentication Module for Mobile Devices," a 2001 symposium publication) and Chapman ("Java for Engineers and Scientists," a 1999 book).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Morogan discloses all major elements of the challenged claims. Morogan teaches a flexible, Java-based security system for mobile devices that uses "generic security objects" for user authentication. Its AuthenticationObject is an independent module that receives security data (e.g., PIN, password, biometrics), has attributes (e.g., authentication type), and includes methods to verify a user's identity to control access to sensitive data. Petitioner contended that while Morogan describes objects with bundled data and methods, it does not explicitly use the term "encapsulation." Chapman, a well-known Java programming manual, was argued to supply this element by expressly teaching encapsulation as a fundamental concept of object-oriented programming. Chapman explains that encapsulation bundles data and methods into discrete, self-sufficient objects to improve modularity, hide internal data, and reduce bugs. The combination of Morogan’s system and Chapman’s foundational programming techniques allegedly renders the claimed invention obvious. For dependent claims, Petitioner mapped limitations to specific disclosures, such as Morogan’s teaching of smart cards for a hardware-based security system (claim 7) and Chapman’s teaching of object classes as blueprints for creating objects with inherited methods (claim 2).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) implementing the Java-based security system described in Morogan would combine its teachings with Chapman, a standard reference manual for Java development. The motivation would be to apply Chapman's well-established encapsulation techniques to construct Morogan's security objects. This would achieve the widely recognized benefits of encapsulation—such as improved program modularity, increased security through information hiding, and easier maintenance—which would have been desirable for any security system. The combination was presented as a predictable implementation of a conceptual system using a standard programming guide.
    • Expectation of Success: Petitioner asserted a high expectation of success because the combination involves applying fundamental Java programming techniques, as taught by the Chapman manual, to a system that Morogan explicitly designed to be implemented in Java. The result was argued to be nothing more than the predictable application of known principles.

4. Key Claim Construction Positions

  • "the security object may be retrieved": Petitioner proposed this phrase, found in claims 7, 24, and 44, should be construed to mean "the security object may be accessed from storage." This construction was argued as critical because it does not require the object itself to be transmitted from its storage location (e.g., a server or smart card). Instead, it allows for a system, like that in Morogan, where messages are sent to the object to invoke its methods locally, rather than sending the entire object to a different device for processing.
  • "means for encapsulating...": For this means-plus-function term in claim 38, Petitioner identified the corresponding structure disclosed in the ’298 patent’s specification as being limited to "software written in Java for generating 'self-sufficient' security object modules." This construction reinforces the relevance of the Chapman reference, which is a guide to Java programming.
  • Other Means-Plus-Function Terms: Petitioner proposed constructions for several other means-plus-function terms based on structures disclosed in the specification, such as identifying graphical user interfaces (GUIs) as the structure for "means for receiving security object data" and a computer capable of programming a smart card as the structure for "means for providing the security object to a security system."

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-51 of the ’298 patent as unpatentable under 35 U.S.C. §103.