PTAB

IPR2025-01182

Google LLC v. Secure Communication Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Communication Architecture
  • Brief Description: The ’344 patent discloses a mobile communication architecture for exchanging information between wireless devices. The system uses short-range protocols (e.g., Bluetooth) for proximity detection and long-range protocols (e.g., cellular) for communicating with a remote server to facilitate interactions based on stored policies.

3. Grounds for Unpatentability

Ground 1: Claims 1-8, 10, 12-16, 18-19, 22-23, and 26-30 are obvious over Eagle in view of 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: Petitioner argued that the three core concepts of the challenged claims were well-known in the prior art. The fundamental short-range/long-range communication architecture was taught by Eagle. The concept of changing device identifiers over time for privacy was taught by Behrens. The novel feature added during prosecution—filtering beacon transmissions based on a "beacon service identifier"—was taught by Olkkonen. Petitioner asserted that combining these known elements to arrive at the claimed invention would have been obvious to a Person of Ordinary Skill in the Art (POSITA) to achieve predictable benefits of enhanced privacy and system efficiency.
    • Prior Art Mapping:
      • Eagle taught the foundational system: a "Requester Device" (e.g., a cellular phone) uses a short-range protocol like Bluetooth to detect a nearby "Identified Device." Upon detection, the Requester Device sends the Identified Device's unique identifier over a long-range cellular network to a remote server. The server then compares user profiles and, if a match exists, sends an alert back to facilitate communication. This mapped to the claims’ core architecture of receiving beacon transmissions via a short-range protocol and communicating with a server via a second, different protocol.
      • Behrens taught a system for establishing contact between users in proximity by exchanging unique identifiers (UIDs), which could include MAC addresses. Critically, Behrens disclosed that a user could have "multiple or changing UIDs" to protect privacy and manage different online identities. This mapped directly to claim limitations requiring a device to transmit a first beacon with one MAC address and unique identifier in a first time period, and a second beacon with a different MAC address and unique identifier in a second time period.
      • Olkkonen taught a system for discovering and connecting to nearby short-range ad hoc networks (e.g., for collaborative games or file sharing). It disclosed that devices respond to inquiries with information characterizing the network, including "service class information" or "service attributes" that identify the specific application running (e.g., "NETWORK BASEBALL"). Users could then filter the discovered devices based on these service identifiers to find services of interest. This mapped to the key limitation of using a "beacon service identifier" to identify a wireless service and filtering transmissions based on that identifier.
    • Motivation to Combine: A POSITA would combine Behrens with Eagle's social networking system to address the well-known privacy and security risks of broadcasting static identifiers. Using Behrens's teaching of changing UIDs over time was a known technique to prevent tracking. A POSITA would further combine Olkkonen with the Eagle/Behrens system for efficiency. Eagle's system, which could encounter numerous Bluetooth devices, would be inefficient if it notified the server of every device. A POSITA would have been motivated to use Olkkonen's service-based filtering to ensure the device only sends identifiers of other devices participating in the same specific service (e.g., Eagle's social introduction application), thereby conserving battery life and reducing unnecessary server communication.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success. The combination 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 required no more than ordinary software coding skills. The result would predictably be a more private and efficient social introduction system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8, 10, 12-16, 18-19, 22-23, and 26-30 of Patent 11,443,344 as unpatentable.