PTAB

IPR2026-00114

Samsung Electronics America Inc v. Network 1 Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Techniques for provisioning an embedded universal integrated circuit card (eUICC)
  • Brief Description: The ’780 patent relates to techniques for securely provisioning an eUICC with a profile containing network access credentials. The disclosed method addresses security concerns by splitting control between a subscription manager (SM), which delivers the encrypted profile, and a mobile network operator (MNO), which transmits a separate symmetric key required to decrypt a secret key within the profile.

3. Grounds for Unpatentability

Ground 1: Claims 1-15 and 17-20 are obvious over Park in view of GlobalPlatform and AbiChar.

  • Prior Art Relied Upon: Park (a 2013 conference paper on secure eUICC architecture), GlobalPlatform (a 2011 smart card specification), and AbiChar (a 2007 conference paper on elliptic curve key agreement).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Park disclosed a high-level secure profile provisioning architecture (SPA) for eUICCs but left specific implementation details to a person of ordinary skill in the art (POSITA). Park’s architecture involves a Subscription Manager-Data Preparation (SM-DP) entity that securely delivers profiles to an eUICC. GlobalPlatform, which Park cited as a de facto standard, was alleged to provide the necessary implementation details for Park’s security requirements. Specifically, GlobalPlatform taught mutual authentication using public key infrastructure (PKI) and a layered encryption scheme where sensitive data (like a secret key K) is first encrypted with a data encryption key (DEK), and the entire message is then encrypted with a secure channel session key. This combination allegedly taught the claimed encrypted profile containing a ciphertext (key K encrypted with a symmetric DEK) received from a subscription manager.
    • Motivation to Combine: A POSITA would combine Park and GlobalPlatform because Park presented its architecture as an extension of the GlobalPlatform standard and its security requirements were derived directly from it. To implement Park’s "asymmetric algorithm-based key agreement protocol," a POSITA would turn to a known efficient protocol like the elliptic-curve Diffie-Hellman (ECDH) key exchange taught by AbiChar, as it was well-suited for resource-constrained devices like eUICCs.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these references, as it involved implementing a known architectural framework (Park) with established, industry-standard protocols for authentication, encryption (GlobalPlatform), and key exchange (AbiChar).

Ground 2: Claims 1-15 and 17-20 are obvious over Park in view of GlobalPlatform and X9.63-Overview.

  • Prior Art Relied Upon: Park (a 2013 conference paper), GlobalPlatform (a 2011 specification), and X9.63-Overview (a 2000 ANSI standard on elliptic curve cryptography).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument to Ground 1, substituting AbiChar with X9.63-Overview as the source for the key exchange protocol. The teachings of Park and GlobalPlatform were applied in the same manner. X9.63-Overview was argued to teach a standardized one-pass Diffie-Hellman key agreement protocol, which provided an alternative method for establishing the claimed "profile key" between the eUICC and the SM-DP.
    • Motivation to Combine: The motivation to combine Park and GlobalPlatform remained the same as in Ground 1. A POSITA would be motivated to use the standardized key agreement protocol from X9.63-Overview to implement Park’s asymmetric key exchange because it was a well-known, efficient method that offered forward secrecy for the eUICC, a desirable security feature.

Ground 5: Claims 1-20 are obvious over Nix175 in view of Park and GlobalPlatform.

  • Prior Art Relied Upon: Nix175 (Patent 9,100,175), Park (a 2013 conference paper), and GlobalPlatform (a 2011 specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was predicated on the argument that the ’780 patent is not entitled to its claimed 2013 priority date and is instead limited to its 2019 filing date, making Nix175 (filed in 2013) prior art. Petitioner contended Nix175, which shares a specification with the ’780 patent, taught all claim elements except for the subscription manager sending the symmetric key; Nix175 required the MNO to send this key to maintain security. The petition argued a POSITA would modify Nix175’s system by incorporating Park’s split SM architecture, which distinguishes between a trusted SM-DP (for data preparation) and a potentially untrusted SM-SR (for secure routing). This modification would allow the trusted SM-DP to send the symmetric key, thereby removing the operational burden from the MNO as required by Nix175, while still preventing the untrusted transport layer (SM-SR) from accessing the key.
    • Motivation to Combine: A POSITA would be motivated to combine Nix175 and Park to improve operational efficiency. While Nix175’s MNO-based key delivery solved a security problem, it created a logistical burden on the MNO. Park’s split architecture provided a known solution to securely delegate tasks to different SM entities, which would have motivated a POSITA to apply it to Nix175’s framework to offload key delivery from the MNO to the trusted SM-DP.
    • Expectation of Success: Success would be expected because the combination involved integrating a known architectural model for delegating trust (Park) into an existing provisioning system (Nix175) to solve a known efficiency problem.
  • Additional Grounds: Petitioner asserted that claim 16 is obvious over the combinations in Grounds 1 and 2 with the additional disclosure of Weiss (Application # 2015/0350881), which taught the use of eUICCs in various networked devices like security cameras and computers.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’780 patent as unpatentable.