PTAB

IPR2026-00098

Google LLC v. Secure Communication Technologies LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Communication Architecture
  • Brief Description: The ’685 patent describes a system for exchanging information between wireless devices. A first device uses a short-range protocol (e.g., Bluetooth) to detect a beacon from a second device, then uses a long-range protocol (e.g., cellular) to send an identifier from that beacon to a remote server, which may facilitate further communication based on stored policies.

3. Grounds for Unpatentability

Ground 1: Claims 1-8, 10, 12-16, 19, 22-23, 26-27, 31-41, 44-48, 52-54, 57-58, 60-64, 67-71, 73, 76-77, 79-81, and 85-86 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:
    • Prior Art Mapping: Petitioner argued that Eagle taught the core architecture of the challenged claims: a "Requester Device" using Bluetooth to detect a nearby "Identified Device" and a cellular network to notify a remote server. The server then compares user profiles and, if a match occurs, sends an alert back to the devices. However, Eagle did not explicitly teach all claimed features. Petitioner asserted Behrens supplied the teaching of using multiple or "changing unique identifiers (UIDs)" over time to enhance user privacy and security. It further argued Olkkonen supplied the teaching of filtering beacon transmissions based on a "beacon service identifier" (e.g., service class information) so that the Requester Device only forwards information from devices participating in the relevant service, thereby increasing efficiency and conserving resources.
    • Motivation to Combine: A POSITA would combine Behrens with Eagle to address known privacy and tracking concerns associated with static identifiers in short-range wireless communications. A POSITA would combine Olkkonen with Eagle to improve the system's efficiency by preventing the server from being burdened with notifications from irrelevant devices, a simple optimization to conserve battery life and reduce network traffic.
    • Expectation of Success: Petitioner contended a POSITA would have a reasonable expectation of success because combining these elements involved applying known techniques (changing identifiers for privacy, service-based filtering for efficiency) to a known system architecture (Eagle's) to achieve predictable improvements.

Ground 2: Claims 25, 55, and 78 are obvious over Eagle in view of Behrens, Olkkonen, and Kallio.

  • Prior Art Relied Upon: Eagle (Application # 2005/0250552), Behrens (Application # 2010/0138481), Olkkonen (Patent 7,590,086), and Kallio (Application # 2003/0224756).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address claims reciting a MAC address that is a "randomly generated 48 bit number" and "not directly usable" to establish a connection. Petitioner argued that the combination of Eagle, Behrens, and Olkkonen taught all other limitations of these claims. The incremental contribution came from Kallio, which explicitly taught using a "randomly generated" MAC address (a 48-bit address similar in form to a hardware address but bearing no relation to it) to provide anonymity for a wireless device communicating with a server.
    • Motivation to Combine: A POSITA, already motivated by Behrens to use changing identifiers for privacy, would have looked to other known anonymizing techniques. Petitioner argued it would have been a simple substitution to use Kallio’s well-known technique of a randomly generated MAC address in place of or in combination with Behrens's UIDs to further enhance anonymity and security.
    • Expectation of Success: The modification was a simple substitution of one known type of identifier for another to achieve the predictable result of enhanced privacy.

Ground 3: Claims 53 and 59 are obvious over Eagle in view of Behrens, Olkkonen, and Jones.

  • Prior Art Relied Upon: Eagle (Application # 2005/0250552), Behrens (Application # 2010/0138481), Olkkonen (Patent 7,590,086), and Jones (Application # 2007/0264991).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring that stored information includes an "image of the entity in proximity," which is displayed on a screen, and that the user provides input "selecting the image" to control further communications. While Eagle taught displaying alerts with profile information (including photos), Petitioner argued Jones supplied the explicit teaching of using a graphical user interface where a user selects a service from a list by clicking an icon or image to initiate a connection.
    • Motivation to Combine: A POSITA designing the user interface for the Eagle system would be motivated to use Jones's simple and conventional method for allowing a user to act on the information presented. Providing a selectable image is an intuitive way to facilitate a connection with a discovered entity, simplifying the user experience.
    • Expectation of Success: Implementing image selection is a basic user interface design choice, and a POSITA would have reasonably expected success in applying this known technique to the Eagle system to yield the predictable result of a more user-friendly interface.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claim 87 based on the combination of Eagle, Behrens, Olkkonen, Kallio, and Jones, relying on the same rationales provided in the grounds above.

4. Key Claim Construction Positions

  • Petitioner argued that claim 59 contains an antecedent basis issue for the term "a user of the second wireless device," as no "second wireless device" is recited in the claim chain.
  • For the purposes of the petition, Petitioner interpreted "the second wireless device" to mean "the wireless device" to correct for an obvious typographical error, consistent with the patent's specification and analogous claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8, 10, 12-16, 19, 22-23, 25-27, 31-41, 44-48, 52-55, 57-64, 67-71, 73, 76-81, and 85-87 of the ’685 patent as unpatentable.