PTAB

IPR2025-01051

Samsung Electronics Co Ltd v. Secure Communication Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Proximity-Based Information Exchange Using Multiple Wireless Protocols
  • Brief Description: The ’971 patent describes techniques for mobile wireless devices to exchange information when in proximity. The system uses a short-range wireless protocol (e.g., Bluetooth) for initial "beacon service" transmissions to facilitate communications before establishing a link over a long-range, second wireless protocol (e.g., cellular) to a central server.

3. Grounds for Unpatentability

Ground 1: Claims 1, 12-13, 15, 29-31, 34, 36, 50, 56, 61, 64-65, 67, and 80 are obvious over Watanabe in view of Ribaudo.

  • Prior Art Relied Upon: Watanabe (JP Patent Publication No. 2005/12973) and Ribaudo (Application # 2007/0030824).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Watanabe and Ribaudo taught all limitations of independent claims 1 and 50. Watanabe allegedly disclosed a wireless system where a mobile device receives beacon transmissions (e.g., continuously or periodically) via a short-range protocol like Bluetooth from an access point (AP). These beacons contained a "unique code" (the claimed unique identifier) and a "service code" (the claimed beacon service identifier). The mobile device filters these beacons based on the service code to determine if a service contract exists and, if so, takes a further action like initiating data communication with a server via a second, different protocol (e.g., cellular). Petitioner contended Ribaudo taught including a MAC address in such beacon transmissions, which was missing from Watanabe's beacon structure.
    • Motivation to Combine: A POSITA would combine these references to improve Watanabe's system. Ribaudo expressly taught that beaconing a device's MAC address was common practice for Bluetooth interfaces. A POSITA would have been motivated to include a MAC address in Watanabe's beacon, as taught by Ribaudo, to comply with Bluetooth standards, leverage a well-known identifier for network communications, and achieve the privacy benefits (e.g., shielding user identity) described by Ribaudo.
    • Expectation of Success: Petitioner asserted a high expectation of success because both references described similar systems for proximity-based communication using Bluetooth for beacons and the internet/cellular for server communication. Combining them involved the predictable inclusion of a standard data field (a MAC address) into an existing beacon message structure.

Ground 2: Claims 2-10, 14, 16, 18-19, 22-28, 35, 37-44, 46, 48-49, 51-55, 57-60, 62, 66, 68, 72, 75-79, and 81-83 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 built upon the Watanabe-Ribaudo combination to meet the limitations of independent claim 37 and its dependents. Claim 37 recited receiving a first plurality of beacons with a first unique identifier and MAC address during a first time period, and then receiving a second plurality of beacons from the same device with a second, different unique identifier and MAC address during a second time period, while the beacon service identifier remains the same. Petitioner argued that while the Watanabe-Ribaudo combination taught the system's core functionality, Behrens and Ribaudo supplied the missing element: a single beacon transmitter using different unique identifiers and MAC addresses over time. Behrens taught that a single device could use multiple or changing unique identifiers (UIDs), including MAC addresses, to allow a user to have different "online identities." Ribaudo similarly taught using multiple client IDs and "time-slicing" to bounce between networks or modes.
    • Motivation to Combine: A POSITA would combine Behrens' teaching with the Watanabe-Ribaudo system for several reasons. First, it offered a way to simplify the system by using one physical AP to provide services from multiple providers (e.g., AT&T and Verizon offering the same underlying Netflix service), which was more efficient than Watanabe's multiple, dedicated APs. Second, as taught by Behrens and Ribaudo, using different identifiers for the same service shielded the underlying hardware infrastructure and protected brand identities, which was a known business motivation. The modification was presented as a routine design choice to improve efficiency and flexibility.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success as all three references operated in the same technical field of proximity-based wireless communication. The combination involved modifying the beacon content of a known system (Watanabe-Ribaudo) based on the express teachings of Behrens and Ribaudo for using time-varying identifiers, which was a well-understood technique.

7. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-10, 12-16, 18-19, 22-31, 34-44, 46, 48-62, 64-68, 72, and 75-83 of the ’971 patent as unpatentable.