PTAB

IPR2025-00484

Samsung Electronics Co Ltd v. Headwater Research LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automated Credential Porting for Mobile Devices
  • Brief Description: The ’510 patent describes a wireless device that automatically updates its network access credentials. The process is initiated after a user requests to replace a current credential with a target credential, and the device then detects a "network-provisioning state change" which triggers an automated programming session to obtain and store the updated credential.

3. Grounds for Unpatentability

Ground 1: Obviousness over Salmela, Rishy-Maharaj, and Bennett - Claims 21, 23, and 25 are obvious over Salmela in view of Rishy-Maharaj and further in view of Bennett.

  • Prior Art Relied Upon: Salmela (Application # 2009/0217364), Rishy-Maharaj (Application # 2013/0165075), and Bennett (Application # 2010/0029273).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Salmela teaches a process for automatically updating a wireless device’s subscription credentials, which is triggered when the device detects a network access failure. This failure serves as the "network-provisioning state change." However, Salmela does not detail how a user initiates the subscription change. Rishy-Maharaj was argued to supply this missing element by disclosing a user interface on a wireless device that allows a user to select and change subscription plans. Petitioner asserted the combination of Salmela and Rishy-Maharaj teaches the core functionality of claim 1. Bennett was argued to further teach that network credentials can be dialable phone numbers, and it describes processes for retaining or obtaining a new phone number when switching service providers.
    • Motivation to Combine: A POSITA would combine Salmela and Rishy-Maharaj to provide a more convenient, user-friendly method for changing subscription plans directly on the device, which is a predictable solution. A POSITA would have been further motivated to incorporate Bennett's teachings to apply Salmela's automated update process to dialable phone numbers—a common type of credential—allowing a user to seamlessly port a number to a new subscription plan.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in making these combinations, as implementing a user interface for subscription management and using phone numbers as network credentials were well-known, conventional techniques for wireless devices before the patent's critical date.

Ground 2: Obviousness over Salmela, Rishy-Maharaj, Bennett, and FCCReg - Claims 26 and 27 are obvious over Salmela in view of Rishy-Maharaj and Bennett, and further in view of FCCReg.

  • Prior Art Relied Upon: Salmela, Rishy-Maharaj, Bennett, and FCCReg (Federal Communications Commission Regulation (2010)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Building on the previous combination, Petitioner argued that FCCReg provides the specific teachings for claims 26 and 27. FCCReg describes federal regulations that mandate telecommunications carriers support "intermodal" phone number porting, including porting a number from a second wireless device to a first wireless device (claim 26) and from a landline to a wireless device (claim 27).
    • Motivation to Combine: A POSITA would have been motivated to incorporate the porting capabilities described in FCCReg into the base combination to comply with legal requirements and meet consumer demand for maintaining existing phone numbers when switching devices or services.
    • Expectation of Success: Success would be expected as number portability was a common and legally mandated feature in the U.S. telecommunications industry.

Ground 3: Obviousness over Salmela, Rishy-Maharaj, and Ionescu - Claims 12 and 13 are obvious over Salmela in view of Rishy-Maharaj and further in view of Ionescu.

  • Prior Art Relied Upon: Salmela, Rishy-Maharaj, and Ionescu (Application # 2012/0236760).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that while the primary combination teaches detecting a "network-provisioning state change," Ionescu provides specific and obvious methods for this detection. Ionescu discloses a wireless device that identifies a network access failure by determining that an attempt to place a voice call (claim 12) or send a text message (claim 13) has failed.
    • Motivation to Combine: A POSITA would combine Ionescu's teachings with the Salmela/Rishy-Maharaj system because a failed call or text is a common and practical indicator that a device's credentials are no longer valid. This provides a simple and reliable trigger for the automated credential update process.
    • Expectation of Success: A POSITA would expect success, as using failed communication attempts to diagnose network connectivity issues was a fundamental and well-understood principle in wireless communications.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the core Salmela and Rishy-Maharaj combination in view of Sigmund (for notifications), Slavov (for using a website), Johansson (for obtaining temporary credentials from the network), and Gupta (for initiating the programming session with a voice call).

4. Arguments Regarding Discretionary Denial

  • §325(d) Arguments: Petitioner argued denial under §325(d) is not warranted because the primary references and all combinations are new and non-cumulative. While Salmela was cited in an IDS during prosecution, it was never substantively addressed by the Examiner, and Rishy-Maharaj and the other secondary references were never considered at all.
  • §314(a) Fintiv Arguments: Petitioner argued against discretionary denial under Fintiv, stating that the petition was filed diligently, months ahead of the one-year bar, and that the co-pending district court litigation is in its very early stages. Petitioner further noted it has stipulated to not pursue the IPR grounds in the litigation, which promotes efficiency and avoids duplicative efforts.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 4-5, 8-10, 12-13, 21, 23, 25-27, 34, 40, and 44 as unpatentable.