PTAB

IPR2026-00050

Google LLC v. Headwater Research LLC

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1. Case Identification

2. Patent Overview

  • Title: End-User Device with Configurable Forwarding Service
  • Brief Description: The ’102 patent relates to an end-user device, such as a smartphone, that can provide a "forwarding service" (i.e., act as a mobile hotspot) to other devices. The invention focuses on using stored service policy settings to authorize and manage this service, where the settings can be modified based on configuration information from a network and user input via a user interface.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 5, 7, 8, and 10-15 are anticipated by Thomas under 35 U.S.C. §102.

  • Prior Art Relied Upon: Thomas (Application # 2009/0017789).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thomas, which discloses a wireless device functioning as an ad hoc point-of-presence for other computing devices to access the internet, teaches every limitation of independent claim 1. Petitioner mapped Thomas's disclosure of a wireless device with a radio-frequency front-end and a DSP that "modulates and demodulates data" to the claimed "one or more modems." Thomas's memory was shown to store a "plurality of service policy settings," including an initial "unauthorized" setting that is changed to "authorized" after the device obtains configuration parameters from a network server. Petitioner asserted this satisfies the limitation of modifying a "first service policy setting." Further, Thomas's user interface allows a user to enable or disable the service (e.g., turn it "ON" or "off"), which Petitioner mapped to modifying a "second service policy setting" based on user input.

Ground 2: Claims 1, 2, 4-8, and 10-19 are obvious over Thomas in view of Sewall under 35 U.S.C. §103.

  • Prior Art Relied Upon: Thomas (Application # 2009/0017789) and Sewall (Application # 2008/0039102).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Thomas provides the foundational mobile hotspot system and Sewall provides complementary and well-known features for managing such a hotspot. Sewall discloses a cellular phone acting as a "personal hotspot" that implements profile-based access rules (e.g., for owner, authorized users, anonymous users), which map to the claimed "plurality of service policy settings." Sewall also teaches billing engines and limiting access based on a subscription plan, which Petitioner used to challenge dependent claims related to service plans and usage costs.
    • Motivation to Combine: A POSITA would combine Thomas and Sewall to improve the flexibility and customizability of hotspot access control. Integrating Sewall's user profiles with Thomas's user interface would enable "on-the-fly" access decisions, improving upon a static set of rules. A second motivation was to combine the references’ complementary billing and reward systems (Thomas's carrier "reward" plan and Sewall's direct compensation from users) to better incentivize hotspot owners and provide flexible monetization.
    • Expectation of Success: Petitioner argued success was highly probable because both references describe the same type of device (internet-enabled phones) for the same purpose (providing hotspot service) and use compatible WLAN technologies. Combining them would involve applying known techniques for access control and billing to a conventional mobile device.

Ground 3: Claim 3 is obvious over Thomas and Sewall in view of Boudreau.

  • Prior Art Relied Upon: Thomas (Application # 2009/0017789), Sewall (Application # 2008/0039102), and Boudreau (Application # 2009/0028049).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the Thomas/Sewall combination to specifically address claim 3's limitation of obtaining configuration information "over a secure control link." Petitioner argued that Boudreau, which discloses securing communications between a server and a mobile wireless client using, for example, data encryption, supplies this missing element.
    • Motivation to Combine: A POSITA implementing the Thomas/Sewall hotspot system would recognize that the device sends and receives sensitive information (e.g., user identifiers, profiles, authorization data) to and from the network. To protect this data from interception, a POSITA would be motivated to incorporate Boudreau's teachings to establish a secure communication channel, which Thomas itself describes as a goal ("provide a... secure... networking environment").
    • Expectation of Success: Petitioner contended that applying known security techniques like data encryption to conventional client-server communications was well within the skill of a POSITA and would predictably result in a secure hotspot system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Burnett (for notifications about service plans and offers), Pandya (for applying distinct traffic controls to different data flows), Sewall '327 (for individualized usage accounting for multiple connected devices), and Trossen (for cost-based notifications and user control) but relied on similar design modification theories to add known, complementary features to the primary Thomas/Sewall hotspot system.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-30 of Patent 8,631,102 as unpatentable.