PTAB

IPR2026-00203

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petition

1. Case Identification

2. Patent Overview

  • Title: Mobile End-User Device with Secure Messaging
  • Brief Description: The ’403 patent describes a mobile device featuring a "device messaging agent" that communicates securely with a network message server over a wireless wide-area network (WWAN). The agent receives secure messages containing application-specific data, uses an identifier within the message to determine the correct destination software application on the device, and forwards the data to that application via a "secure interprocess communication service."

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Messaging and Security References - Claims 1, 3-6, and 11-21 are obvious over TS-23.140 in view of Ogawa.

  • Prior Art Relied Upon: TS-23.140 (a 3GPP technical specification for Multimedia Messaging Service (MMS)) and Ogawa (Patent 8,195,961).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of TS-23.140 and Ogawa (termed "MMS-Ogawa") renders the claims obvious. TS-23.140 was asserted to disclose the fundamental architecture: a mobile device (UE) with an MMS User Agent ("device messaging agent") that communicates with an MMS Relay/Server ("network message server") to receive application-specific data and route it to other applications on the device using an application identifier. Ogawa was asserted to teach the security aspects, including using SSL/TLS for secure network communication and a separate shared-key encryption layer for messages, as well as an "inherent key" for securing internal device communications. Petitioner argued that implementing TS-23.140's system with Ogawa’s security methods would result in the claimed invention.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references to add a robust security layer to the MMS system of TS-23.140. Petitioner noted that TS-23.140 contemplates end-to-end encryption but does not specify an implementation, and Ogawa provides a well-documented and predictable method for achieving this enhanced security.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references describe compatible client-server architectures. The combination simply applies known encryption techniques from Ogawa to the known messaging framework of TS-23.140 to achieve the predictable result of secure messaging. Petitioner further noted that the Board previously endorsed this combination in a decision for a related patent (IPR2024-00341).

Ground 2: Obviousness over MMS-Ogawa in view of Cole - Claim 2 is obvious over TS-23.140, Ogawa, and Cole.

  • Prior Art Relied Upon: TS-23.140, Ogawa (Patent 8,195,961), and Cole (Application # 2008/0080458).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targets claim 2, which adds a wireless local area network (WLAN) modem. Petitioner argued that the base MMS-Ogawa combination provides all other limitations. Cole was introduced as it explicitly discloses a mobile device equipped with both a WWAN modem and a WLAN modem, and teaches selecting a communication interface based on factors like network availability.
    • Motivation to Combine: A POSITA would be motivated to add Cole’s WLAN modem to the MMS-Ogawa device to provide greater network flexibility and improve accessibility, particularly in areas with poor cellular coverage. TS-23.140's contemplation of "many different network types" was cited as supporting this motivation.
    • Expectation of Success: The combination was presented as a predictable integration of a standard component (a WLAN modem) to add a known capability (alternative network access) to a mobile device.

Ground 3: Obviousness over MMS-Ogawa in view of Papineau - Claims 7-9 are obvious over TS-23.140, Ogawa, and Papineau.

  • Prior Art Relied Upon: TS-23.140, Ogawa (Patent 8,195,961), and Papineau (Patent 7,779,408).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets claims 7-9, which recite a "service downloader" for authenticating and installing downloaded applications. Papineau was asserted to teach a Java Application Manager (JAM) that functions as this service downloader. Papineau’s JAM uses a descriptor file (JAD) containing a signature to authenticate a software application (MIDlet) before downloading the full application file (JAR), mapping directly to the claim limitations.
    • Motivation to Combine: While TS-23.140 discloses "downloadable applications," it does not detail how they are managed. A POSITA would be motivated to incorporate Papineau’s established JAM system into the MMS-Ogawa device to securely and efficiently manage the download and installation of such applications.
    • Expectation of Success: Petitioner argued success would be expected, as this involves implementing a known application management system (from Papineau) into a mobile device platform (MMS-Ogawa) to achieve the predictable result of secure software downloading and updating.

Ground 4: Obviousness over MMS-Ogawa in view of Ellison - Claim 10 is obvious over TS-23.140, Ogawa, and Ellison.

  • Prior Art Relied Upon: TS-23.140, Ogawa (Patent 8,195,961), and Ellison (Patent 7,082,615).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets claim 10, which requires the "device messaging agent" to run in a "secure execution environment" while at least one other application runs outside of it. Ellison was asserted to teach a processor architecture with an "isolated execution mode" (a secure, tamper-resistant environment) and a "normal execution mode."
    • Motivation to Combine: A POSITA would be motivated to implement Ellison's architecture to protect the trusted MMS User Agent (the messaging agent) from potentially untrusted, third-party applications that the MMS-Ogawa system is designed to support.
    • Expectation of Success: A POSITA would reasonably expect success in organizing the MMS-Ogawa system according to Ellison’s architecture by placing the trusted messaging agent in the "isolated execution mode" and other applications in the "normal execution mode," thereby achieving a predictable enhancement in device security.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations substituting Sathish (Application # 2011/0208889) for its teaching of a D-Bus as an interprocess communication bus, as well as various multi-reference combinations (e.g., MMS-Ogawa-Cole-Sathish), but relied on similar design modification theories.

4. Key Claim Construction Positions

  • Petitioner argued that several key terms central to the claims—including "device messaging agent," "network message server," and "secure interprocess communication service"—are not explicitly defined in the ’403 patent's specification. Petitioner contended that, in the absence of a clear definition, the meaning of these terms should be informed by statements made by the Patent Owner during prosecution. Petitioner relied on these prosecution history statements to argue that the terms should be interpreted broadly enough to read on components of the prior art, such as the "MMS User Agent" and "MMS Relay/Server" from the TS-23.140 standard.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of Patent 9,232,403 as unpatentable.