PTAB

IPR2023-00923

Meta Platforms Inc v. VL Collective IP LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Transmitting Data
  • Brief Description: The ’682 patent discloses a method and system for secure data transmission over a network using the Real Time Transport Protocol (RTP). The invention provides transmitter-to-receiver authentication by inserting authentication data at the end of the entire RTP packet payload, allowing a receiver to verify the transmitter’s identity and reject unwanted data packets.

3. Grounds for Unpatentability

Ground 1: Claims 1-21, 23, and 25-28 are obvious over Handley in combination with Basturk

  • Prior Art Relied Upon: Handley (a 1999 paper on internet multimedia conferencing architecture) and Basturk (a 1995 paper on secure transport protocols for high-speed networks).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Handley discloses using RTP for real-time multimedia conferencing and recognizes the need for security measures to authenticate contributors and enforce communication policies. Basturk teaches secure transport protocols that provide data integrity by attaching a signature, computed "on-the-fly," to each data packet. Petitioner contended that combining these references discloses all limitations of the independent claims, including providing authentication at the RTP packet level (Handley), inserting authentication data at the end of the packet payload (a predictable implementation of Basturk’s signature trailer), and having the receiver ascertain the transmitter’s identity to accept or reject the packet (taught by both references’ security goals).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Basturk's efficient security methods with Handley’s established conferencing architecture to solve the very authentication problems Handley identifies, such as preventing unauthorized broadcasts in a multicast environment. Basturk’s "on-the-fly" signature computation offered known benefits like faster data transmission and reduced jitter, which would have been desirable improvements for the real-time applications described in Handley.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references operate in the same field of internet data transmission, use compatible protocols, and address the common problem of securing communications. Applying a known authentication technique to a known conferencing architecture was presented as a predictable implementation.

Ground 2: Claims 1-28 are obvious over PacketCable in combination with Handley

  • Prior Art Relied Upon: PacketCable (a 1999 technical report defining an architecture for packet-based voice and multimedia services) and Handley.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that PacketCable discloses a comprehensive architecture for high-speed multimedia data transport using RTP, including provisions for end-to-end encryption and the use of a Message Authentication Code (MAC) for message integrity at the RTP packet level. Handley supplements this by explicitly teaching the need to discard unauthenticated or unsigned packets to enforce security policies. Petitioner argued this combination teaches accepting a packet only if the receiver "knows" the transmitter and otherwise rejecting it.
    • Motivation to Combine: A POSITA would combine the references to implement a complete and robust security solution. While PacketCable provides the mechanism for authentication (MACs), Handley provides the explicit, common-sense rule for handling packets that fail authentication—discarding them. Both references are directed at standardizing multimedia transport over IP networks, making their teachings highly relevant to one another.
    • Expectation of Success: The combination involves applying a known security policy (discarding bad packets, from Handley) to a system designed for security (PacketCable), which would have been a straightforward and predictable design choice for a POSITA.

Ground 3: Claims 1-28 are obvious over PacketCable in combination with Basturk

  • Prior Art Relied Upon: PacketCable and Basturk.

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground is similar to Ground 2, with PacketCable providing the foundational RTP-based multimedia architecture. However, Petitioner argued Basturk provides a more specific and advantageous teaching for implementing the authentication. Basturk’s disclosure of computing signatures "on-the-fly" and appending them as a trailer to the packet is an efficient method for implementing the MAC functionality generally described in PacketCable. This directly addresses the claimed limitation of inserting authentication data at the end of the whole RTP packet payload.
    • Motivation to Combine: A POSITA would have been motivated to implement the security features of the PacketCable architecture using the efficient methods taught by Basturk. The primary motivation was performance; Basturk’s method of appending a signature avoids the latency inherent in pre-computing an entire packet’s authentication data before transmission, which is critical for the real-time communications targeted by PacketCable.
    • Expectation of Success: A POSITA would have reasonably expected success in implementing Basturk’s well-defined, performance-oriented security protocol within the standardized PacketCable framework, as both were designed for high-speed network environments.

  • Additional Grounds: Petitioner asserted that claims 22 and 24 are obvious over Handley in combination with Basturk and PacketCable, adding PacketCable’s disclosure of media gateways for connecting to the Public Switched Telephone Network (PSTN).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. First, under 35 U.S.C. §325(d), the primary references (Handley, Basturk, and PacketCable) were never applied against the claims during prosecution and are substantially different from the previously considered art.
  • Second, regarding the Fintiv factors under 35 U.S.C. §314(a), Petitioner asserted that the parallel district court litigation is in its infancy. No trial date has been set, no claim construction has occurred, and discovery has not commenced, meaning institution would be efficient. Petitioner further stipulated that it would not pursue the same invalidity grounds in the district court if the IPR is instituted.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-28 of the ’682 patent as unpatentable.