PTAB

IPR2025-01050

Samsung Electronics Co Ltd v. Secure Communication Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Wireless Device Information Exchange
  • Brief Description: The ’344 patent discloses techniques for mobile devices to exchange information by utilizing a short-range, first wireless capability (e.g., Bluetooth) for proximity-based communication and a second wireless capability (e.g., cellular) that allows the devices to communicate with a central server over the Internet.

3. Grounds for Unpatentability

Ground 1: Obviousness over Watanabe/Ribaudo - Claims 1, 13, 15, and 30 are obvious over Watanabe in view of Ribaudo.

  • Prior Art Relied Upon: Watanabe (JP Patent Publication No. 2005/12973), Ribaudo (Application # 2007/0030824).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Watanabe and Ribaudo teaches all limitations of the challenged independent claims. Watanabe disclosed a wireless system where a mobile device uses a first, short-range communication means (e.g., Bluetooth) to receive "induction beacons" from an access point and a second communication means to connect to a server via the internet. These beacons contain a "service code" identifying the type of service available and a "unique code" for the transmitter. Ribaudo taught beaconing a device’s unique MAC address over Bluetooth for proximity detection and identification. Petitioner asserted that the combined teachings disclose a beacon transmission comprising the three required fields: a MAC address (from Ribaudo), a unique identifier (from Watanabe’s unique code), and a beacon service identifier (from Watanabe’s service code). The combination also allegedly taught receiving stored information from a server via a second, different protocol (e.g., cellular), filtering beacons based on the service identifier, and performing a further action if a unique identifier is present.
    • Motivation to Combine: A POSITA would combine these references as both address systems for detecting nearby devices using a combination of ad-hoc and cellular networks. Petitioner argued a POSITA would have been motivated to modify Watanabe’s beacon to include a MAC address as taught by Ribaudo to comply with the Bluetooth standard, which uses MAC addresses for device identification, and to leverage the known benefits of using MAC addresses for identification and privacy.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references disclose interrelated teachings based on well-understood technologies. Combining them would involve the predictable and routine modification of adding a standard identifier (MAC address) to a known beacon structure.

Ground 2: Obviousness over Watanabe/Ribaudo/Behrens - Claims 2-10, 12, 14, 16, 18-19, 22-28, and 29 are obvious over Watanabe in view of Ribaudo and Behrens.

  • Prior Art Relied Upon: Watanabe (JP Patent Publication No. 2005/12973), Ribaudo (Application # 2007/0030824), and Behrens (WO 2008/132241).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Watanabe-Ribaudo combination to address claims requiring transmissions during first and second time periods from the same transmitter but with different identifiers. Specifically, independent claim 29 recites receiving a second plurality of beacon transmissions during a second time period from the same device, which have the same service identifier but a different unique identifier and MAC address than the first plurality. Petitioner contended that Behrens taught a single device can "continuously/repeatedly transmit" multiple or changing unique identifiers (UIDs), including MAC addresses, to enable "different online identities." Ribaudo similarly taught that a device may be associated with "one or more client IDs" and use "time-slicing" to bounce between networks or identities.
    • Motivation to Combine: A POSITA would combine the teachings of Behrens and Ribaudo with the Watanabe system to enable a single physical access point to provide the same service on behalf of different service providers at different times. This modification would simplify the system by reducing the number of physical access points, an established motivation for combination. It would also allow different companies (e.g., AT&T and Verizon) to use the same hardware to provide an identical underlying service (e.g., Netflix streaming) while shielding their brand identities and enhancing user privacy by changing the broadcasted unique identifier and MAC address over time, a benefit explicitly taught by Behrens and Ribaudo.
    • Expectation of Success: A POSITA would have expected success in this combination because it involved implementing a known technique (time-slicing identifiers, as taught by Ribaudo and Behrens) into the established beaconing system of Watanabe. The combination simply replaces multiple physical transmitters with a single, more efficient one, which is a predictable design choice within the routine skill of a POSITA.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-10, 12-16, 18-19, and 22-30 of the ’344 patent as unpatentable.