PTAB

IPR2019-00820

Apple Inc v. MPH Technologies Oy

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petition

1. Case Identification

2. Patent Overview

  • Title: Method and Network for Ensuring Secure Forwarding of Messages
  • Brief Description: The ’581 patent discloses a method for maintaining secure Internet Protocol Security (IPSec) connections for mobile devices. The purported invention addresses issues that arise when a mobile terminal changes its IP address by having the terminal send a request to a security gateway to update its address in the existing security association (SA), thereby avoiding a computationally expensive full renegotiation of the secure connection.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4, 6-7, and 9 are obvious over Ishiyama and Murakawa.

  • Prior Art Relied Upon: Ishiyama (Patent 6,904,466) and Murakawa (Patent 7,028,337).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ishiyama teaches the core concept of the challenged claims: a mobile computer maintaining a secure IPSec tunnel by sending an update message to a correspondent node (a security gateway) when its IP address changes. This update changes the endpoint address in the security association database, allowing the session to continue without interruption. Petitioner contended that while Ishiyama discloses the mobile terminal-to-gateway connection, it does not explicitly show the gateway forwarding messages to an "other terminal" on a protected network. Murakawa was introduced to supply this missing element, as it explicitly describes a well-known prior art configuration where a mobile terminal uses an IPSec tunnel to communicate through a security gateway to other terminals on a private Local Area Network (LAN).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to implement Ishiyama’s dynamic address-updating functionality within the conventional and well-understood network architecture described by Murakawa. Since Ishiyama’s system operates in IPSec tunnel mode, a POSITA would naturally look to references like Murakawa that detail the standard use of such tunnels, which is to securely access terminals behind a gateway. The combination would have been a predictable implementation of known technologies to achieve the desired result of uninterrupted mobile VPN access.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination merely applies Ishiyama's address management technique to a standard network environment for which IPSec tunneling was designed. No technical hurdles would prevent the successful integration of these known elements.

Ground 2: Claims 3 and 5 are obvious over Ishiyama, Murakawa, and Ahonen.

  • Prior Art Relied Upon: Ishiyama (Patent 6,904,466), Murakawa (Patent 7,028,337), and Ahonen (Patent 6,976,177).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Ishiyama and Murakawa to further address the limitations of dependent claims 3 and 5, which require the security gateway to send a reply message back to the mobile terminal confirming the address change. Petitioner asserted that the primary combination does not explicitly teach this reply message. Ahonen was introduced because it solves the same mobile IPSec problem and explicitly teaches a firewall (security gateway) sending an acknowledgment ("ACK") message back to the mobile host after successfully updating its database with the new address. This ACK confirms the update and signals that the mobile host can begin sending traffic from its new location.
    • Motivation to Combine: A POSITA implementing the Ishiyama/Murakawa system would be motivated to include a confirmation mechanism to ensure reliable communication. It is a fundamental principle of network protocols (like TCP/IP) to use acknowledgments to confirm receipt and processing of critical messages. Ahonen provides a known method for adding this reliability to the specific context of a mobile host updating its address with a security gateway. This would have been a simple and desirable addition to prevent data loss or session interruption if the update request failed.
    • Expectation of Success: The integration of an acknowledgment message as taught by Ahonen into the combined Ishiyama/Murakawa system would be straightforward and predictable, as it represents a common feature in secure and reliable network communications.

Ground 3: Claim 8 is obvious over Ishiyama, Murakawa, and Forslöw.

  • Prior Art Relied Upon: Ishiyama (Patent 6,904,466), Murakawa (Patent 7,028,337), and Forslöw (Patent 6,954,790).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenges claim 8, which specifies that the "other terminal" behind the security gateway is also a mobile terminal. The base combination of Ishiyama and Murakawa teaches a mobile terminal communicating with a stationary terminal on a LAN. Forslöw was added to teach a system for secure mobile-to-mobile communication. Forslöw describes a mobile workgroup system where multiple mobile clients communicate with each other through a mobile service router (acting as a gateway) using shared security associations.
    • Motivation to Combine: A POSITA would be motivated to combine Forslöw's teachings to enhance the capabilities of the Ishiyama/Murakawa system. Enabling secure communication between two mobile users, rather than just one mobile user and a fixed network, would have been a logical and desirable extension to broaden the system's applicability. This would be seen as a simple design choice to increase the number and type of devices capable of communicating securely.
    • Expectation of Success: Incorporating mobile-to-mobile capabilities into the base system would be a predictable modification. The underlying IPSec principles are the same, and a POSITA would have reasonably expected to successfully configure the system to allow the "other terminal" to be mobile, just as Forslöw demonstrates.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-9 of the ’581 patent as unpatentable.