PTAB

IPR2025-00963

Samsung Electronics Co Ltd v. Headwater Research LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Security Techniques for Device Assisted Services
  • Brief Description: The ’144 patent discloses security techniques for a wireless end-user device, such as a mobile phone. The device uses a wireless wide area network (WWAN) modem and features multiple partitioned execution environments—a kernel partition, an application partition, and a protected execution partition—to securely manage and apply policies to Internet data traffic.

3. Grounds for Unpatentability

Ground 1: Claims 1-11, 13, 15, and 18 are obvious over Wright

  • Prior Art Relied Upon: Wright (Application # 2008/0052395).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wright disclosed a mobile device with partitioned kernel and user/application spaces for administering data protection policies received from a server. Wright’s kernel space included components like a TDI filter and packet filter engine that perform application-specific packet filtering based on policies. Petitioner contended these kernel components correspond to the claimed application identification agent, service measurement agent, and policy control agent. Wright’s user space components, such as a Layered Service Provider (LSP) and a policy engine, were mapped to the claimed device agents.
    • Motivation to Combine (N/A - Single Reference): Petitioner argued a person of ordinary skill in the art (POSITA) would find it obvious to further partition Wright’s user space into a separate application execution partition and a protected execution partition. This modification was presented as a predictable and conventional technique to enhance security for sensitive policy management functions (performed by the LSP and policy engine), separating them from general applications.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in partitioning the user space, as it was a well-known technique for securing computing environments and Wright’s system already contemplated a partitioned architecture.

Ground 2: Claims 12, 16, and 17 are obvious over Wright in view of Tzannes

  • Prior Art Relied Upon: Wright (Application # 2008/0052395) and Tzannes (Application # 2009/0300450).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring a service usage measurement calculated separately from other traffic information. Petitioner asserted Wright provided the base system of a policy-driven mobile device. Tzannes was introduced for its teachings on using packet counters to manage Quality of Service (QoS) and facilitate retransmission of lost packets in a communication system. This packet count was argued to be a form of service usage measurement. Petitioner contended that Tzannes teaches this counting can be implemented in the modem or at higher software layers.
    • Motivation to Combine: A POSITA would combine Tzannes’s QoS and packet counting techniques with Wright’s policy enforcement system to create a more resilient network communication system. The motivation was to improve reliability by managing network congestion and ensuring delivery of critical packets, which was a known problem solved by such techniques. This would involve calculating packet counts (the service usage measure) separately from the general traffic data measurement taught by Wright.
    • Expectation of Success: Success was expected because implementing QoS-based packet counting was a known method for improving network performance. A POSITA would have found it straightforward to integrate Tzannes's counting module into Wright's WWAN modem or its higher-level software agents (like the LSP) to achieve the predictable result of enhanced data transmission reliability.

Ground 3: Claim 14 is obvious over Wright in view of Smith

  • Prior Art Relied Upon: Wright (Application # 2008/0052395) and Smith (a 2005 publication on virtual machines).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claim 14, which requires the protected execution partition to comprise a secure virtual execution environment. Petitioner argued that while Wright taught partitioning execution environments, it did not explicitly disclose a virtual environment. Smith was introduced for its detailed teachings on using virtual machines (VMs) to provide a "secure way of partitioning major software systems" and isolating software for enhanced security and robustness.
    • Motivation to Combine: A POSITA would have been motivated to implement Wright’s protected execution partition using the VM technology described by Smith. The primary motivation was to improve the overall security and robustness of Wright’s device by running the sensitive policy-related agents in a strongly isolated VM, separate from user applications. This would prevent erratic application behavior from affecting the security system and reduce the risk of malicious attacks, directly aligning with the security goals of Wright.
    • Expectation of Success: A POSITA would have expected success because using VMs to create secure, isolated environments was a well-established and known technique. Applying this known technique to improve the operation of Wright’s known system would predictably result in a more secure and robust device.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted and noted its intent to use a bifurcated briefing process, per the Stewart Memorandum, to rebut any arguments from the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’144 patent as unpatentable.