Samsung Electronics Co Ltd v. Secure Communication Technologies LLC

1. Case Identification

• Case #: IPR2025-01049
• Patent #: 11,334,918
• Filed: May 30, 2025 (inferred from service date)
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Secure Communication Technologies, LLC
• Challenged Claims: 1-20, 22-31

2. Patent Overview

• Title: Facilitating the Use of Proximity Beacons
• Brief Description: The ’918 patent describes mobile wireless devices that use both long-range (e.g., cellular) and short-range (e.g., Wi-Fi, Bluetooth) wireless capabilities. The system allows for peer-to-peer communication for proximity detection using identifiers, with a central server brokering the exchange of information between devices.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4-6, 9, 14, 16-20, 22, and 24-30 are obvious over Ribaudo.

• Prior Art Relied Upon: Ribaudo (Application # 2007/0030824).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Ribaudo discloses all elements of the challenged claims. Ribaudo teaches a social networking system where mobile devices determine proximity to other users. Petitioner asserted that Ribaudo’s mobile devices include a first radio (cellular/WWAN) for communicating with a central server and a second radio (Wi-Fi/Bluetooth) for ad-hoc communication with other devices. The devices receive "pre-processed match data" (the claimed "identifier related information") from the server via the first radio. Subsequently, using the second radio, a device receives short-range beacon transmissions from other mobile devices. Petitioner contended these beacons inherently include a MAC address, a "client ID" (the claimed "unique identifier"), and an SSID of the system proprietor (e.g., ‘proprietor_name.net’), which satisfies the "Proximity Beacon Service Identifier" (PBSI) limitation. The receiving device then processes these identifiers to determine if a potential match is nearby, thus determining proximity by utilizing the server-provided information and the beacon-provided unique identifier.

Ground 2: Claims 1, 4-6, 9, 14, 16-20, 22, and 24-30 are obvious over Ribaudo in view of Watanabe.

• Prior Art Relied Upon: Ribaudo (Application # 2007/0030824) and Watanabe (JP Publication No. 2005/12973).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground is identical to Ground 1 for all limitations except for the PBSI. While Petitioner maintained that Ribaudo’s SSID teaches the PBSI, this ground asserted that Watanabe’s disclosure of a "service code 202" provides an explicit teaching of this element. Watanabe discloses beacons that include a "service code" indicating the type of service available from a beacon transmitter.
  • Motivation to Combine: A POSITA would combine Ribaudo’s proximity detection system with Watanabe’s use of a service code to more clearly and efficiently identify the specific service associated with a detected beacon. Incorporating Watanabe's explicit service code into Ribaudo's beacon structure was presented as a predictable design choice to improve communication efficiency in Ribaudo’s ad-hoc network.
  • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success, as both references describe beacon-based proximity systems, and the combination merely involves adding a known type of data field (a service code) to a beacon message.

Ground 3 & 4: Claims 2-3, 7-8, 10-13, 15, and 31 are obvious over Ribaudo (or Ribaudo and Watanabe) in view of Behrens.

• Prior Art Relied Upon: Ribaudo (Application # 2007/0030824), Watanabe (JP Publication No. 2005/12973), and Behrens (WO 2008/132241).

• Core Argument for this Ground:

  • Prior Art Mapping: These grounds addressed claims requiring the use of multiple, different unique identifiers and MAC addresses from a single beacon transmitter over time (e.g., claims 3 and 10). Behrens teaches a system where mobile devices use "multiple or changing UIDs" and associated MAC addresses to create different online identities and enhance user privacy. Petitioner asserted that the combination of Ribaudo/Watanabe with Behrens teaches a system where a single device transmits a first beacon with a first MAC address and first unique identifier at a first time, and a second beacon with a different second MAC address and second unique identifier at a second time.
  • Motivation to Combine: A POSITA would be motivated to incorporate Behrens's privacy-enhancing feature of changing identifiers into the Ribaudo/Watanabe system. Ribaudo already acknowledged privacy as a concern and contemplated the use of multiple client IDs. Behrens provided a known, advantageous method for implementing this feature to allow users to manage their online identities and privacy when interacting with different services.
  • Expectation of Success: Success would be expected because the combination involved applying a known privacy technique (changing identifiers) to a similar beacon-based proximity detection system, which would yield predictable results.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claim 23 (multiuser game application) based on Ribaudo, or Ribaudo and Watanabe, in view of Mgrdechian (Application # 2005/0174975).

4. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-20 and 22-31 of the ’918 patent as unpatentable.