PTAB

IPR2025-01307

Samsung Electronic Co Ltd v. Maxell Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless LAN Communication System and Communication Device
  • Brief Description: The ’088 patent relates to a wireless LAN communication system that allows a primary terminal (e.g., an internal user) to grant temporary, secure permission for a secondary terminal (e.g., an external guest) to connect to and use a shared communication device, such as a projector. The system aims to provide convenience while managing security risks associated with guest access.

3. Grounds for Unpatentability

Ground 1: Claims 1, 5, 13-15 are obvious over Iwami in view of Kim.

  • Prior Art Relied Upon: Iwami (Application # 2019/0053149) and Kim (Application # 2007/0005788).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Iwami teaches a communication system with a control device (the first terminal), multiple source devices (the second terminals), and a sink/display device (the communication device). The control device generally manages permissions for the source devices to connect and display images on the sink device. Kim discloses a specific message-based system where a control point sends explicit commands to grant/revoke permission and remotely control media renderers (e.g., start/stop video playback). Petitioner argued that Iwami’s control device 740, source devices 710/720, and sink device 730 correspond to the claimed first terminal, second terminal, and communication device, respectively.
    • Motivation to Combine: A POSITA would combine Kim’s specific message-based permission and remote-control techniques with Iwami's broader system. This combination would improve Iwami’s generalized permission scheme with a well-defined, message-based protocol for connection management and display control, which was a known technique to achieve predictable results.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Kim provides a detailed description of a compatible permission and command protocol for a similar networked media environment, and implementing these known messaging techniques in Iwami's system would involve only ordinary skill.

Ground 2: Claims 2 and 12 are obvious over Iwami and Kim in further view of Liansky.

  • Prior Art Relied Upon: Iwami (Application # 2019/0053149), Kim (’788 application), and Liansky (Patent 9,323,713).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Iwami-Kim combination by adding Liansky to teach the specific limitations of claims 2 and 12, which relate to using short-range communication to transmit connection information. Liansky teaches a system where a device displays a QR code (a type of bar code) containing connection parameters (e.g., SSID, encryption key), and a second device captures an image of the code with its camera to establish a secure wireless connection.
    • Motivation to Combine: A POSITA would incorporate Liansky’s QR code-based method into the Iwami-Kim system to enhance security and simplify the process of granting permission and sharing connection details. Using a scannable code is a known and convenient method to securely transmit complex connection information, solving the problem of how the first terminal provides permission details to the second terminal.
    • Expectation of Success: The combination was predictable because Liansky provides a complete method for sharing connection credentials via scannable codes, a technique readily applicable to the permission-granting context of the Iwami-Kim system.

Ground 3: Claims 7, 8, and 10 are obvious over Iwami and Kim in further view of Liansky and Weiser.

  • Prior Art Relied Upon: Iwami (Application # 2019/0053149), Kim (’788 application), Liansky (’713 patent), and Weiser (Application # 2013/0147900).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Weiser to teach managing connections using permission lists, as required by claims 7, 8, and 10. Weiser discloses managing network security by registering device addresses in whitelists (permission lists) or blacklists. A device's address is checked against the list to determine if a connection is permitted, and addresses can be deleted from a whitelist to terminate permission.
    • Motivation to Combine: A POSITA would be motivated to add Weiser’s whitelist/blacklist functionality to provide a more robust and straightforward method for the control device in the Iwami-Kim-Liansky system to manage and enforce permissions. Maintaining a permission list is a well-known security technique for controlling access in a network environment, allowing the system to easily terminate a guest's connection by removing their registered address from the list.
    • Expectation of Success: Success would be expected as managing access via whitelists is a fundamental network security concept, and Weiser provides a clear model for its implementation that is compatible with the proposed system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining the Iwami-Kim-Liansky system with Kato (Application # 2015/0007302) to teach using a one-time password for added security (Ground 4), and combining the Iwami-Kim system with Dowling (Patent 6,636,499) to teach using heartbeat signals to detect inactive devices and terminate connections (Ground 5).

4. Key Claim Construction Positions

  • "access point device" (claims 1, 14, 15): Petitioner argued this term should be construed to mean "in a wireless LAN (local area network), a transceiver that connects the LAN to a wired network." This construction is based on dictionary definitions and is consistent with the patent’s disclosure.
  • Limitation [6b] ("in a case that the communication device is unable to receive information from the first communication terminal..."): Petitioner contended this limitation is met if the communication device terminates a connection during any period when it cannot receive any information from the first terminal, such as during a network malfunction or power loss to an access point. It does not require the termination to be in response to being unable to receive information.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 5-15 of the ’088 patent as unpatentable.