PTAB

IPR2026-00153

Target Corp v. Headwater Research LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: WIRELESS NETWORK BUFFERED MESSAGE SYSTEM
  • Brief Description: The ’320 patent describes a networked system that uses a buffer to store messages from various network elements and delivers them to wireless end-user devices upon the occurrence of a triggering event.

3. Grounds for Unpatentability

Ground 1A: 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 for Multimedia Messaging Service (MMS), 2005).
  • Core Argument for this Ground: Petitioner argued that TS-23.140, a well-known standard for MMS, discloses every element of the challenged claims. As a single-reference ground, the argument was that the claimed invention was merely the implementation of this existing public standard.
    • Prior Art Mapping: Petitioner asserted that the MMS architecture in TS-23.140 corresponds directly to the claimed system. The "MMS Relay/Server" functions as the claimed "network server system," and the "MMS User Agents" on mobile devices are the "device link agents." This system establishes a secure data link (using protocols like TLS over TCP/IP) between the server and agents. TS-23.140 explicitly described storing messages in a network-based message store (a "message buffer system") and delivering them based on various "triggers." These triggers included a user agent request after receiving a notification (claim 5), the expiration of a delivery timer (claim 3), and the receipt of a message indicating the device is now reachable (claim 2). Messages contained application-specific data and identifiers for routing to the correct software components on the end-user device (claim 18).

Ground 1D: 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) and Shen (Application # 2005/0207379).
  • Core Argument for this Ground: Petitioner argued that a person of ordinary skill in the art (POSITA) would have been motivated to supplement the standard MMS system of TS-23.140 with the specific improvements for device reachability and message security taught by Shen.
    • Prior Art Mapping: Shen addressed known security and connectivity issues in store-and-forward messaging systems like MMS. For claim 6, Shen taught using periodic "heartbeat signals" from a device to its gateway to indicate reachability, which Petitioner argued was a well-known implementation for the claimed "heartbeat message" trigger. For claims 12-13, while TS-23.140 secured the communication channel, Shen taught encrypting the message content itself using an authentication and key management module, directly mapping to the claims’ requirements for encrypting messages and decrypting them on the device. For claim 16, Shen's heartbeat mechanism provided a logical trigger for a device to transmit its buffered upload messages.
    • Motivation to Combine: A POSITA would combine Shen's teachings with the TS-23.140 framework to solve known problems. The motivation was to improve the reliability of message delivery by using Shen's well-known heartbeat method to implement the "device availability" trigger in TS-23.140, and to enhance security by adding Shen's message-level encryption to prevent unauthorized access to stored messages on the Relay/Server.
    • Expectation of Success: Petitioner asserted a high expectation of success, as Shen was designed to work with and improve the exact type of MMS architecture described in TS-23.140.

Ground 2A: 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: This ground contended that the claimed invention was an obvious combination of a standard push-messaging system (Houghton) with well-known store-and-forward functionality (Munson).

    • Prior Art Mapping: Houghton disclosed a "push server" ("network server system") that establishes a secure link with a "push client" ("device link agent") on a mobile terminal to deliver messages to specific applications. Houghton's system delivered messages based on various "trigger events," such as alarms or client-side user actions. Petitioner argued that Houghton taught most claim elements except for a robust message buffer system. Munson remedied this by teaching a method for "pushing contents to client devices" that explicitly included buffering received content before forwarding it to one or more devices based on scheduling or other triggers. The combination of Houghton's push architecture with Munson's buffering logic allegedly disclosed the complete claimed system.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Munson's store-and-forward (buffering) functionality into Houghton's push system to improve system reliability and flexibility. This combination would prevent message loss if a device was temporarily offline and would provide more sophisticated options for controlling message delivery, which were known benefits of such systems.
    • Expectation of Success: Success would be expected because the combination involved applying a known technique (message buffering) to a standard push-messaging system to achieve the predictable result of a more robust and reliable store-and-forward messaging platform.

  • Additional Grounds: Petitioner asserted additional obviousness challenges that primarily relied on adding a single, well-known teaching to the core combinations of TS-23.140 or Houghton-Munson. These grounds used references such as Adamczyk (for periodic scheduling), Pazhyannur (for secure authorization lists), Ellison (for secure execution environments), and Fok (for secure inter-process communication) to meet the limitations of specific dependent claims.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’320 patent as unpatentable.