PTAB

IPR2026-00099

Google LLC v. Secure Communication Technologies LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Communication Architecture for Information Exchange
  • Brief Description: The ’749 patent discloses a system for exchanging information between two wireless devices with the aid of a central server. The system involves a first device detecting a second device via a short-range wireless link, sending identification information to the server over a long-range wireless link, and modifying the identification information based on a predetermined event coordinated with the server.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Bucuk - Claims 1-3, 13, and 17-20 are anticipated by, or in the alternative obvious over, Bucuk.

  • Prior Art Relied Upon: Bucuk (Application # 2010/0274859).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bucuk discloses all elements of the challenged method claims. In Bucuk's primary example, a first wireless device (a phone) collects initial identification information (a Bluetooth name containing a device ID) from a second wireless device (a car) over a short-range link. The phone provides this information to an authentication server over a long-range link (the Internet) to receive an unlocking key. Upon successful authentication, a predetermined event occurs, causing the car to provide modified identification information (a new Bluetooth name with a new device ID from a pre-arranged sequence) for subsequent interactions. This cycle of collecting, providing, and modifying identifiers was asserted to map directly onto the limitations of independent claim 1. Dependent claims were also allegedly taught, with the predetermined event being a "number of uses" (a single use) and a "step in a process."
    • Key Aspects: Petitioner presented the obviousness argument as an alternative, contending that even if not strictly anticipatory, it would have been obvious to a person of ordinary skill in the art (POSITA) to combine features described across Bucuk's different but closely related embodiments to arrive at the claimed invention.

Ground 2: Obviousness over Bucuk in view of Nordman - Claims 1-3, 7-9, 13, 15, and 17-26 are obvious over Bucuk in view of Nordman.

  • Prior Art Relied Upon: Bucuk (Application # 2010/0274859) and Nordman (Application # 2002/0174364).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Bucuk teaches the foundational short-range/long-range communication architecture. Nordman was introduced to supply explicit teachings for triggering the modification of identifiers based on specific "predetermined events" to enhance privacy. While Bucuk teaches periodically changing identifiers, Nordman explicitly describes using triggers such as elapsed time, use counts, and connections made, which directly correspond to the limitations recited in claims 2 and 8 of the ’749 patent. The combination therefore allegedly rendered the broader set of method claims (1-3, 13, 17-20) and server claims (7-9, 15, 21-26) obvious.
    • Motivation to Combine: A POSITA seeking to improve the privacy and security of the system in Bucuk, which already contemplated periodically changing identifiers, would have been motivated to consult Nordman. Nordman is in the same field and directly addresses the problem of user tracking by teaching various well-known techniques for changing identifiers. A POSITA would combine Nordman's specific event triggers with Bucuk's architecture to yield the predictable result of a more secure and private system.
    • Expectation of Success: Petitioner argued that implementing Nordman's teachings, such as using timers or counters to trigger identifier changes, would involve routine software coding skills and would have been straightforward to integrate into Bucuk's software-based system.

Ground 3: Obviousness over Bucuk, Nordman, and Kallio - Claims 4-6 and 10-12 are obvious over Bucuk in view of Nordman and Kallio.

  • Prior Art Relied Upon: Bucuk (Application # 2010/0274859), Nordman (Application # 2002/0174364), and Kallio (Application # 2003/0224756).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the Bucuk/Nordman combination to address dependent claims reciting specific server-side functionalities. Petitioner argued that Kallio teaches using a server that assigns identifiers to devices from a "bank" or "pool of identifiers" to avoid conflicts and ensure uniqueness. This server functionality was asserted to be equivalent to the "identity manager" recited in claims 5 and 11. The combination thus allegedly taught receiving an identifier taken from a pool determined by the central server, as required by claims 4 and 10.
    • Motivation to Combine: A POSITA implementing the Bucuk/Nordman system would need a method for generating and managing the periodically changing identifiers. To solve the known problem of generating duplicate identifiers, the POSITA would have been motivated to adopt Kallio's solution of using a centralized server to assign unique identifiers from a pre-generated pool.
    • Expectation of Success: Modifying the server software in the Bucuk/Nordman system to generate and assign identifiers from a list or "pool" as taught by Kallio was presented as a simple software design choice with a high expectation of success.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 14 and 16 based on Bucuk in view of Nordman and Perttila (Application # 2004/0243519), arguing Perttila's teachings on validating electronic coupons would make it obvious to use the changing identifiers to validate the legitimacy of devices or transactions.

4. Key Claim Construction Positions

  • Non-limiting Statements of Purpose: Petitioner argued that language in claims 13-14, 16, 19-20, and 24-25, such as "to protect the privacy" or "to verify the legitimacy," recites an intended purpose or result rather than a specific structure or step. Petitioner contended this language carries no patentable weight and should be disregarded in the unpatentability analysis.
  • Contingent Limitations: Petitioner argued that limitations in claims 18 and 23, which are conditioned on an event that is not required to occur (i.e., "if re-sent to the central server"), are contingent. As such, Petitioner asserted these limitations also carry no patentable weight because the result that follows the condition is not required to be performed.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-26 of the ’749 patent as unpatentable.