PTAB

IPR2026-00117

Samsung Electronics America Inc v. Network 1 Technologies Inc

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petition

1. Case Identification

2. Patent Overview

  • Title: Method for a mobile device with an embedded universal integrated circuit card (eUICC) to securely communicate with a wireless network
  • Brief Description: The ’869 patent discloses methods for a mobile device with an eUICC to securely communicate with servers and a wireless network. The methods involve two primary phases: first, downloading and decrypting an encrypted eUICC profile from a server using a first Elliptic Curve Diffie-Hellman (ECDH) key exchange, and second, performing an authentication process with another server using a second ECDH key exchange.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 7, 9-14, and 16-20 are obvious over Nakhjiri, Bradley, and Jeong.

  • Prior Art Relied Upon: Nakhjiri (Patent 9,210,138), Bradley (Application # 2014/0024343), and Jeong (Journal of Korea Multimedia Society, Nov. 2010).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination teaches all elements of the challenged claims. Nakhjiri taught a secure eUICC profile provisioning process using an ECDH-derived symmetric key to encrypt and deliver a profile from a subscription manager server to a mobile device. While Nakhjiri did not specify the profile's contents, Bradley taught that such encrypted profiles for eUICCs predictably included known parameters like a module identity (IMSI) and a key (K). This combination allegedly rendered claims 1(a)-(d) obvious. For the authentication phase in claims 1(e)-(i), Petitioner asserted that Jeong addressed the known security risk of sending an IMSI in the clear by teaching a method to authenticate a mobile station by encrypting its IMSI using a second ECDH-derived symmetric key before sending it to a network authentication server.
    • Motivation to Combine: A POSITA would combine these references to create a unified and predictable eUICC workflow. The combination addressed two complementary phases of a single problem: securely provisioning a device with subscriber credentials (Nakhjiri and Bradley) and then securely authenticating that device to the network (Jeong). Petitioner argued that a POSITA would logically combine a known secure provisioning method with a known secure authentication method, especially since both employed the same underlying ECDH technology for key exchange in the same mobile environment.
    • Expectation of Success: A POSITA would have a high expectation of success because all three references described methods for securing wireless communications using well-understood authentication and key agreement mechanisms (ECDH), and their teachings were analogous and amenable to combination without any change in their principles of operation.

Ground 2: Claims 1-4, 7, 9-14, and 16-20 are obvious over Nakhjiri, Bradley, and Ala-Laurila.

  • Prior Art Relied Upon: Nakhjiri (Patent 9,210,138), Bradley (Application # 2014/0024343), and Ala-Laurila (Application # 2012/0300934).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative to Jeong for the authentication phase. Petitioner contended that the combination of Nakhjiri and Bradley taught the secure profile provisioning steps of claims 1(a)-(d), as detailed in Ground 1. For the authentication steps of claims 1(e)-(i), Petitioner argued that Ala-Laurila taught an authentication flow that also addressed the security problem of sending an IMSI in the clear. Ala-Laurila disclosed a mobile terminal obtaining its IMSI from a SIM and sending an authentication request, including the IMSI, in a ciphered form to a network access controller using a Diffie-Hellman algorithm. This directly taught encrypting the module identity using a key derived from an ECDH exchange for network authentication.
    • Motivation to Combine: The motivation was similar to Ground 1. A POSITA seeking to implement a comprehensive and secure eUICC system would be motivated to combine Nakhjiri/Bradley’s established method for secure profile delivery with Ala-Laurila’s method for secure network authentication. This combination would create a complete, end-to-end secure communication flow, from initial provisioning to subsequent network access, using consistent cryptographic principles.
    • Expectation of Success: Success was expected because the references' teachings were analogous. Nakhjiri’s ECDH mechanism for provisioning could be readily applied to implement Ala-Laurila’s Diffie-Hellman-based authentication, as both involved generating and exchanging key pairs to derive a shared symmetric key for encryption in a mobile network context.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including X9.63-Overview (an ANSI standard for key derivation), Pierce (for random number generation using a sensor), and GlobalPlatform (for storing server connection parameters). These references were added to the primary combinations of Nakhjiri, Bradley, and either Jeong or Ala-Laurila to argue the obviousness of dependent claims 5-6, 8, and 15, respectively, by teaching specific, well-known implementation details for key derivation functions and key generation.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’869 patent as unpatentable.