PTAB

IPR2026-00106

Amazon Web Services Inc v. Headwater Research LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Networked System for Buffered Message Delivery
  • Brief Description: The ’320 patent describes a networked system that uses a buffer to store messages from network elements. It delivers these messages to end-user devices upon the occurrence of a triggering event over a secure link established between the system and a "device link agent" on the user's device.

3. Grounds for Unpatentability

Ground 1A: Obviousness over TS-23.140 - Claims 1-3, 5-7, 10-11, 15, and 18 are obvious over TS-23.140.

  • Prior Art Relied Upon: TS-23.140 (3GPP Technical Specification 23.140 v6.9.0 (2005-03)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that TS-23.140, which defines the architecture for Multimedia Messaging Service (MMS), discloses every element of the challenged claims. The MMS "Relay/Server" was mapped to the claimed "network server system," and the "User Agent" on a mobile device was mapped to the "device link agent." The specification's description of storing messages in a "Persistent Network-Based Storage" or "MMBox" before delivery was argued to teach the claimed "message buffer system." The MMS protocol's use of TLS for secure communication over TCP/IP was asserted to meet the "secure Internet data message link" limitation. Various message delivery conditions in the MMS standard, such as manual retrieval requests, automatic delivery notifications, or device availability, were argued to constitute the claimed "message delivery triggers."
    • Motivation to Combine (for §103 grounds): This ground relies on a single reference, arguing it anticipates or renders obvious all limitations without combination.
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Ground 2A: Obviousness over Houghton and Munson - Claims 1-7, 10-11, 15, and 18 are obvious over Houghton in view of Munson.

  • Prior Art Relied Upon: Houghton (WO 2006/077283) and Munson (Application # 2009/0240807).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Houghton taught a push messaging system with a push server (the "network server system") that sends messages to a push client (the "device link agent") on a mobile terminal using secure protocols like HTTPS or IP-Sec. However, Petitioner argued Houghton lacks a detailed disclosure of store-and-forward functionality. Munson was introduced to supply this teaching, as it explicitly discloses buffering push content in a "series buffer" before sending it to multiple client devices simultaneously ("group pushes") or in a series. The combination of Houghton's secure push architecture with Munson's buffering and triggered delivery logic was alleged to meet all limitations of the independent claims.
    • Motivation to Combine: A POSITA would combine Houghton and Munson to improve the reliability and flexibility of Houghton's push system. Incorporating Munson's store-and-forward (buffering) functionality would prevent message loss if a device is offline and provide users with greater control over message delivery timing, which are well-known objectives in messaging systems.
    • Expectation of Success: A POSITA would have a high expectation of success because Munson provides detailed implementation guidance for adding buffering to push messaging systems like Houghton's. The required modifications, such as adding memory and logic to Houghton's server, were described as routine programming within the skill of a POSITA.

Ground 1D: Obviousness over TS-23.140 and Shen - Claims 6, 12-13, and 16 are obvious over TS-23.140 in view of Shen.

  • Prior Art Relied Upon: TS-23.140 (3GPP Technical Specification 23.140 v6.9.0 (2005-03)) and Shen (Application # 2005/0207379).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds upon the MMS system of TS-23.140. Petitioner argued that while TS-23.140 teaches secure connections (TLS), it does not explicitly disclose encrypting the messages themselves, a limitation of claim 12. Shen was introduced because it addresses security vulnerabilities in store-and-forward systems like MMS by teaching an authentication/key-management module to encrypt messages. For claim 6, Shen was cited for its disclosure of a device generating a "heartbeat message" to indicate its availability, which serves as a message delivery trigger. This heartbeat mechanism was presented as a known method for implementing the device reachability checks described more generally in TS-23.140.
    • Motivation to Combine: A POSITA would combine Shen with TS-23.140 to enhance the security and efficiency of the standard MMS system. Adding Shen’s message encryption would protect stored content from unauthorized access, a known vulnerability. Incorporating Shen’s heartbeat mechanism would provide a low-bandwidth, reliable method for determining device reachability before attempting message delivery, improving network efficiency.
    • Expectation of Success: Success was expected because Shen explicitly designed its system to work within a standard MMS architecture like that of TS-23.140. Combining the references would involve implementing known security and networking techniques (encryption, heartbeats) into a compatible, existing framework.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, primarily building on the foundational systems of TS-23.140 or Houghton-Munson. These grounds added further references—such as Adamczyk, Herzog, Pazhyannur, Ellison, and Fok—to teach specific features like periodic timer triggers, secure execution environments, authorization lists, and secure inter-process communication, primarily to address limitations in various dependent claims.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 10,321,320 as unpatentable.