PTAB

IPR2025-01181

Google LLC v. Secure Communication Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Communication Architecture
  • Brief Description: The ’918 patent is directed to a mobile communication architecture for exchanging information between wireless devices. The system uses a first device employing both short-range (e.g., Bluetooth) and long-range (e.g., cellular) communication to detect an identifier from a second nearby device, send that identifier to a remote server, and potentially receive an alert from the server regarding the second device's presence.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 8-20, 22-25, 27-28, and 31 are obvious over Eagle, Behrens, and Olkkonen.

  • Prior Art Relied Upon: Eagle (Application # 2005/0250552), Behrens (Application # 2010/0138481), and Olkkonen (Patent 7,590,086).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches all key limitations of the challenged claims. Eagle disclosed the foundational device-server architecture where a "Requester Device" detects a nearby "Identified Device" via a short-range protocol (Bluetooth), notifies a remote server via a long-range protocol (cellular), and receives alerts based on server-side profile matching. To address privacy concerns inherent in Eagle's use of static identifiers, Behrens taught using "multiple or changing" Unique Identifiers (UIDs), including MAC addresses, which meets the claim limitations of receiving different identifiers from the same device over time. To address system inefficiency, Olkkonen taught filtering short-range communications based on "service class information" before processing them, which corresponds to the claimed filtering based on a Proximity Beacon Service Identifier (PBSI).
    • Motivation to Combine: A POSITA would combine Behrens with Eagle to mitigate the well-known privacy and tracking risks associated with broadcasting static identifiers in wireless systems. The motivation to add Olkkonen was to improve the efficiency of Eagle's system; a POSITA would recognize that filtering beacon transmissions based on a service identifier before notifying the server would conserve battery life and reduce unnecessary network traffic, a common goal in mobile device design.
    • Expectation of Success: Petitioner asserted that combining these elements involved applying known techniques to a known system to achieve predictable results. Implementing changing UIDs from Behrens and service-based filtering from Olkkonen into Eagle's architecture would have required no more than ordinary skill in software development.

Ground 2: Claim 17 is obvious over Eagle, Behrens, Olkkonen, and Perttila.

  • Prior Art Relied Upon: Eagle, Behrens, Olkkonen, and Perttila (Application # 2004/0243519).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the primary combination to address claim 17, which requires receiving and using "access code information" to gain access to a nearby entity. Petitioner contended that the contact information disclosed in Eagle already functions as an access code. However, to the extent it does not, Perttila explicitly taught a method for wirelessly providing users access to services and products via electronic coupons in a Bluetooth beacon context. Perttila's e-coupons, which function as access codes to validate commercial transactions, directly teach the claimed limitation.
    • Motivation to Combine: Since Eagle suggested commercial applications for its system but did not detail their implementation, a POSITA would logically look to known e-commerce solutions like Perttila. A POSITA would combine Perttila's access code method to securely manage commercial transactions within the Eagle-Behrens-Olkkonen framework.

Ground 3: Claim 29 is obvious over Eagle, Behrens, Olkkonen, and Jones.

  • Prior Art Relied Upon: Eagle, Behrens, Olkkonen, and Jones (Application # 2007/0264991).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 29, which adds the limitation that beacon transmissions are received "without requiring the mobile device to first perform a step of transmitting." This describes a passive discovery method. While Eagle taught an active discovery method (transmitting an inquiry), Jones explicitly disclosed a "passive" discovery method where a device listens for advertised service messages from other local Bluetooth devices without first transmitting a request.
    • Motivation to Combine: Power conservation is a universal design consideration for mobile devices. Jones taught its passive discovery method as a specific, power-efficient alternative to active scanning. A POSITA would have been motivated to substitute Eagle's active discovery with Jones's well-known passive alternative to solve the exact problem of reducing battery consumption, a predictable and desirable improvement.

4. Key Claim Construction Positions

  • "determining...proximity": Petitioner argued that based on the prosecution history, this term should be construed broadly. It can be satisfied not only by an alert indicating a device is nearby but also by the act of filtering identifiers for server notification. For example, using a blacklist or "friends list" to decide whether to notify the server about a detected UID constitutes a determination of proximity, as it controls whether the system will permit disclosure of a user's presence.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 8-20, 22-25, 27-29, and 31 of the ’918 patent as unpatentable.