PTAB

IPR2025-00483

Samsung Electronics Co Ltd v. Headwater Research LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automated Credential Porting for Mobile Devices
  • Brief Description: The ’510 patent describes techniques for a wireless device to automatically update its network access credentials. The process is initiated after a user requests a credential change, and it is triggered when the device detects a "network provisioning state change," such as a failure to access the network with its current credentials.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 6-7, 11, 14-25, 28-33, 35-39, 41-43, and 45-48 are obvious over Salmela in view of Rishy-Maharaj.

  • Prior Art Relied Upon: Salmela (Application # 2009/0217364) and Rishy-Maharaj (Application # 2013/0165075).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Salmela discloses the core automated process of updating credentials on a wireless device. Salmela’s system automatically triggers an update process upon detecting a "failure to gain network access," causing the device to revert to temporary credentials to contact a server and obtain new, permanent subscription credentials. However, Salmela does not explicitly describe how a user initiates the underlying request to change their subscription. Petitioner asserted that Rishy-Maharaj remedies this by teaching a wireless device with a user interface (including input controls and a display) that allows a user to select and activate new subscription plans directly on the device. The combination of Salmela’s automated backend process with Rishy-Maharaj’s user-facing initiation method renders the claimed invention obvious.
    • Motivation to Combine: A POSITA would combine Salmela and Rishy-Maharaj to improve user convenience by allowing subscription changes to be initiated directly on the wireless device, which is a more streamlined and efficient process than using other devices or contacting a call center. Rishy-Maharaj's user interface would provide a known, predictable way to implement the user request step that triggers Salmela's automated update process. This combination represents the application of a known technique (on-device user interface for service selection) to improve a known system (automated credential updating) to achieve predictable results.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing this combination. Wireless devices with user interfaces capable of executing software for selecting network services, as taught by Rishy-Maharaj, were well-known and conventional before the ’510 patent’s critical date.

4. Arguments Regarding Discretionary Denial

  • §325(d) Arguments: Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is not warranted because the asserted prior art combination is new and was not previously considered by the USPTO. While Salmela was cited in an Information Disclosure Statement (IDS) during prosecution, it was one of over 1,500 references and was never substantively addressed by the Examiner. Rishy-Maharaj was never cited at all, so the specific combination and arguments in the petition are being presented to the Office for the first time.
  • §314(a) / Fintiv Arguments: Petitioner contended that the Fintiv factors weigh against discretionary denial under 35 U.S.C. §314(a). The co-pending district court litigation is in its early stages, with fact and expert discovery ongoing and no Markman hearing scheduled. The scheduled trial date is speculative and occurs approximately six months after the statutory deadline for a Final Written Decision (FWD) in this IPR. Furthermore, Petitioner stipulated that it will not pursue the same grounds in the district court litigation if the IPR is instituted, which promotes efficiency and avoids duplicative efforts.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6-7, 11, 14-25, 28-33, 35-39, 41-43, and 45-48 of the ’510 patent as unpatentable.