Amazon Web Services Inc v. Headwater Research LLC

1. Case Identification

• Case #: IPR2025-01571
• Patent #: 8,667,571
• Filed: October 13, 2025
• Petitioner(s): Apple Inc., Amazon.com Services LLC, and Amazon Web Services, Inc.
• Patent Owner(s): Headwater Research LLC
• Challenged Claims: 1-30

2. Patent Overview

• Title: Secure Provisioning, Activating, and Managing End-User Devices
• Brief Description: The ’571 patent is directed to methods and systems for securely provisioning, activating, and managing end-user devices over wireless networks. The technology establishes a secure "service control link" for control-plane communications between a network system and an end-user device, which uses "device agents" to perform service policy and management functions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chia and Cunningham - Claims 1-3, 5-19, 21, 23-24, and 26-30 are obvious over Chia in view of Cunningham.

• Prior Art Relied Upon: Chia (Patent 8,555,273) and Cunningham (Application # US2007/0185975).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chia disclosed the core elements of the challenged claims. Specifically, Chia taught a network system (an update management system) that provides a secure HTTPS communication link (a "first service control link") to a mobile device (a "first end-user device"). This end-user device comprised multiple software agents (e.g., update agent, download agent), satisfying the "device agents" limitation. Chia’s system was scalable to millions of devices, thereby teaching providing a second service control link to a second device. Petitioner further asserted that Chia taught receiving an update package (a "server message") from a workstation ("particular server") and that this message contained a payload for delivery to the device.
  • Motivation to Combine: Petitioner contended that while Chia described "on-the-fly" encryption of update packages and using a "unique device value" to target a specific device, it lacked implementation details. Cunningham allegedly supplied these details, teaching a system for asynchronous hypertext messaging that uses a second layer of "on-the-fly" encryption and appends a "Consumer ID" (cID) to messages to identify the target consumer object. A POSITA would combine Cunningham's teachings with Chia to improve the security and targeting of Chia’s update delivery system, a known technique for a known problem.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because the systems were similar, the required components were common, and compounding encryption layers was a well-known method to increase security in network communications.

Ground 2: Obviousness over Chia, Cunningham, and Clontz - Claims 4 and 22 are obvious over Chia and Cunningham in view of Clontz.

• Prior Art Relied Upon: Chia (Patent 8,555,273), Cunningham (Application # US2007/0185975), and Clontz (WO 2005/094011).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Chia and Cunningham combination from Ground 1. It addressed claim 4, which required the message payload to comprise a "service usage value," and claim 22, which required the control link to be within an "ambient service." Petitioner argued Clontz taught both. Clontz disclosed transmitting "service usage" data to compile accurate bills in a pay-per-use system. Clontz also described providing an "initial free trial access" (an ambient service) to users over a wireless network, which used an HTTPS link for notifications.
  • Motivation to Combine: A POSITA would combine Clontz's teachings to implement a more robust billing system for the "For Fee" updates described in Chia. Adding service usage values was a known way to improve auditing and enable usage-based pricing. Similarly, offering a free, time-limited trial, as taught by Clontz, was a known business method to attract paying customers for a service like that disclosed by Chia.

Ground 3: Obviousness over Chia, Cunningham, and Han - Claim 20 is obvious over Chia and Cunningham in view of Han.

• Prior Art Relied Upon: Chia (Patent 8,555,273), Cunningham (Application # US2007/0185975), and Han (WO 2008/060300).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Han to the primary combination to address claim 20, which required the particular server to be a "content transaction server." Petitioner asserted that while Chia mentioned "For Fee" updates and exporting billing information, it did not detail the transaction processing. Han allegedly disclosed a "payment processing server" capable of handling micropayments, online payments, and collecting revenue for "purchases of access to a media file."
  • Motivation to Combine: A POSITA would be motivated to incorporate Han's detailed payment processing server into Chia's system as a guide for implementing the "For Fee" update functionality. Because payment processing servers were commonplace, a POSITA would have looked to a reference like Han to provide a well-known solution for the functionality contemplated by Chia.

Ground 4: Obviousness over Chia, Cunningham, and Qumei - Claim 25 is obvious over Chia and Cunningham in view of Qumei.

• Prior Art Relied Upon: Chia (Patent 8,555,273), Cunningham (Application # US2007/0185975), and Qumei (Patent 7,975,147).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Qumei to the primary combination to address claim 25, which required generating a "second encrypted message" at the end-user device. Petitioner argued that Qumei taught a fault-tolerant update process where a secure update is received, decrypted on the device, combined with original firmware components, and then re-encrypted for storage as a backup. This re-encryption on the device constituted the claimed "second encrypted message."
  • Motivation to Combine: A POSITA would apply Qumei's fault-tolerant process to Chia's system to ensure continued operation in case of update failures. This was a known technique to improve system reliability and security, and Petitioner noted that Chia’s own disclosure stated its update agent may support "fault-tolerant updates," providing an express reason to incorporate Qumei's teachings.

4. Key Claim Construction Positions

• Petitioner argued that several terms in claims 26 and 29 should be construed under 35 U.S.C. §112(6) as means-plus-function limitations. Key proposed constructions included:
  • "means for providing a first service control link" (Claim 26): Petitioner identified the corresponding structure as a "processor and network hardware executing software including a transport services stack."
  • "means for generating an encrypted message" (Claim 26): Petitioner identified the structure as a "processor executing an encryption protocol."
  • "means for sending a credential...or obtaining the credential..." (Claim 29): Petitioner identified the structure as a "processor and network hardware executing software including a transport services stack."

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of Patent 8,667,571 as unpatentable.