US 9537900

Here's a concise summary of US patent 9537900:

US Patent 9537900

• Title: Systems and methods for serving application specific policies based on dynamic context
• Assignee: Avaya Inc.
• Inventors: Sunil Menon, Shailesh Patel
• Filing Date: 2014-05-24
• Issue Date: 2017-01-03
• Abstract: The patent describes methods, systems, and computer-readable media for serving application-specific policies based on dynamic context. This involves determining a dynamic authentication context for a user (including access credentials), authenticating those credentials, determining a need for a service-based policy, and generating a dynamic service-based policy based on the dynamic authentication context and an application. The policy is then provided to the application, and changes in the dynamic authentication context are monitored, leading to updates to the policy. The dynamic authentication context can include factors like device type, device capability, network, and access location. The updated policy can be pushed to the application without a specific request.

Plain-Language Overview of Independent Claims:

• Claim 1 (Method): This claim describes a method where an authentication system intercepts a user device's attempt to access a remote application. The system determines a dynamic authentication context for the user device, including its capabilities and access credentials, and authenticates these credentials. It then identifies a need for a service-based policy (e.g., because the user is trying to access the application). The authentication system generates a dynamic service-based policy, which includes an "application normalized view" of the device's capabilities, based on the dynamic context and the application. This policy is then provided to the application, allowing the application to determine which features to offer the user device during the session based on this context and the normalized capability view. The authentication system continuously monitors for changes in the dynamic authentication context (like a change in device capability) and, if detected, updates the service-based policy, proactively providing the updated policy to the application without an explicit request.
• Claim 4 (System): This claim defines a system with one or more processors and a computer-readable storage medium containing software instructions. When executed, these instructions cause the processors to perform actions similar to those in Claim 1. Specifically, the system intercepts access attempts, determines and authenticates a dynamic authentication context (which includes device capability, network, and access location), identifies a need for a service-based policy, and generates a dynamic service-based policy with an application normalized view of device capabilities. This policy is provided to the application, which uses it to determine features. The system also monitors for changes in the dynamic authentication context (such as device capability changes) and updates and provides the dynamic service-based policy to the application without a request.
• Claim 7 (Nontransitory Computer Readable Medium): This claim covers a nontransitory computer readable medium storing software instructions. When a processor of a wireless controller executes these instructions, it performs operations mirroring those of Claim 1 and Claim 4. These operations include intercepting user access, determining and authenticating a dynamic authentication context (with device capability, network, and access location), identifying a need for a service-based policy, generating a dynamic service-based policy including an application normalized view of device capability, providing this policy to the application for feature determination, monitoring for context changes (like device capability changes), and updating and proactively providing the updated policy to the application.

CAFC 2026 Dockets:
As of April 26, 2026, a search of CAFC 2026 dockets did not return any specific entries or cases directly mentioning US Patent 9537900. The search results provided general information about CAFC intellectual property cases and summaries of other patent cases, but no information pertaining to patent number 9537900.

The provided search results discuss patent litigation in general, mention the CAFC and Unified Patents, and explain how to use PACER. However, none of the search results directly show any litigation cases specifically involving US patent 9537900. The results for Unified Patents and CAFC are about their general functions or other patent numbers. To confirm there is no known litigation, I would need to search Unified Patents and PACER directly using the patent number. Since I cannot directly access or execute searches within those external databases, I must state that based on the provided search snippets, no specific litigation for US9537900B2 was found.As of April 26, 2026, no known litigation directly involving US patent 9537900 was found in the provided search results. While general information about patent litigation resources such as Unified Patents and the CAFC was retrieved, and the functionality of PACER was described, no specific case details for patent 9537900 appeared in the snippets.

Proceedings overview

As of the current date, no AIA trial proceedings (Inter Partes Review, Post-Grant Review, or Covered Business Method) have been filed against US patent 9537900. This indicates that the patent has not been challenged at the PTAB, which can be interpreted as a relatively strong defensive posture for the patent owner, as the claims remain untested by these administrative trial processes.

Strategic summary

There are no PTAB proceedings on file for US9537900, meaning all claims of the patent are currently UNTESTED in an AIA trial setting. This contrasts with patents that have undergone IPRs, PGRs, or CBMs, where claims might be canceled or sustained, thereby narrowing the patent's scope or hardening its validity.

Since no PTAB proceedings have occurred, the estoppel provisions of § 315(e)(2) are not applicable. Therefore, for a potential defendant facing assertion of this patent, all prior-art grounds (e.g., novelty under § 102 or obviousness under § 103) remain available for potential invalidity challenges in district court or for initiating a new PTAB proceeding, should one be deemed appropriate and timely.

The absence of PTAB activity can be a signal in itself. Well-asserted patents often attract IPR filings from defendants or third-party aggregators like Unified Patents, who actively challenge low-quality patents (though no record of Unified Patents specifically targeting US9537900 was found in the search results). The lack of such challenges suggests that either the patent has not been widely asserted in litigation, or potential challengers have not found sufficiently strong prior art to warrant a PTAB petition, or they have chosen alternative defense strategies.

Recommended next steps

As there are no PTAB proceedings currently on file or discovered through web search for US patent 9537900, a defendant facing assertion of this patent should consider the following:

• Conduct a thorough prior art search to assess the patent's validity.
• Evaluate the potential for filing an Inter Partes Review (IPR) against the patent, considering the one-year statutory bar for IPR petitions following service of a complaint for infringement.
• Consult with patent litigation counsel to weigh the pros and cons of challenging the patent's validity in district court versus initiating an IPR.

Inventors

• Sunil Menon (Avaya Inc.)
• Shailesh Patel (Avaya Inc.)

Original assignee

The original assignee of US Patent 9537900 is Avaya Inc.. Avaya Inc. offers digital communication solutions, including unified communications platforms and services, contact center operations, and devices such as video conferencing tools and phones. They primarily serve the telecom market, focusing on large enterprises (their "G1500 strategy").

Avaya Inc. emerged from its second Chapter 11 bankruptcy in May 2023 and currently operates as a private company owned by its former creditors. It is no longer publicly traded.

Assignment timeline

• 2014-05-21 to 2014-05-22 (executed) / recorded 2014-05-27 — Reel 032969/0595
  • Conveyance: Assignment
  • Assignor: Menon, Sunil; Patel, Shailesh
  • Assignee: AVAYA INC., NEW JERSEY
  • Correspondent: Not specified in the provided text.
  • Context: Original assignment from inventors to the filing company.
• 2017-01-24 (executed) / recorded 2017-01-27 — Reel 041576/0001
  • Conveyance: Security Interest
  • Assignor: AVAYA INC.; AVAYA INTEGRATED CABINET SOLUTIONS INC.; OCTEL COMMUNICATIONS CORPORATION; and OTHERS
  • Assignee: CITIBANK, N.A., AS ADMINISTRATIVE AGENT, NEW YORK
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest, likely due to a financing agreement.
• 2017-11-28 (executed) / recorded 2017-12-15 — Reel 044893/0531
  • Conveyance: Assignment (Release of Security Interest)
  • Assignor: CITIBANK, N.A.
  • Assignee: AVAYA INTEGRATED CABINET SOLUTIONS INC., CALIFORNIA; OCTEL COMMUNICATIONS LLC (FORMERLY KNOWN AS OCTEL COMMUNICATIONS CORPORATION), CALIFORNIA; VPNET TECHNOLOGIES, INC., CALIFORNIA; AVAYA INC., CALIFORNIA
  • Correspondent: Not specified in the provided text.
  • Context: Release of security interest due to a bankruptcy court order.
• 2017-12-15 (executed) / recorded 2018-01-10 — Reel 045034/0001
  • Conveyance: Security Interest
  • Assignor: AVAYA INC.; AVAYA INTEGRATED CABINET SOLUTIONS LLC; OCTEL COMMUNICATIONS LLC; and OTHERS
  • Assignee: GOLDMAN SACHS BANK USA, AS COLLATERAL AGENT, NEW YORK
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest, likely due to a new financing agreement.
• 2017-12-15 (executed) / recorded 2018-01-23 — Reel 045124/0026
  • Conveyance: Security Interest
  • Assignor: AVAYA INC.; AVAYA INTEGRATED CABINET SOLUTIONS LLC; OCTEL COMMUNICATIONS LLC; and OTHERS
  • Assignee: CITIBANK, N.A., AS COLLATERAL AGENT, NEW YORK
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest, likely due to a new financing agreement.
• 2020-09-25 (executed) / recorded 2020-09-25 — Reel 053955/0436
  • Conveyance: Security Interest
  • Assignor: AVAYA INC.; AVAYA MANAGEMENT L.P.; INTELLISIST, INC.; and OTHERS
  • Assignee: WILMINGTON TRUST, NATIONAL ASSOCIATION, MINNESOTA
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest.
• 2022-07-12 (executed) / recorded 2022-08-05 — Reel 061087/0386
  • Conveyance: Intellectual Property Security Agreement
  • Assignor: AVAYA INC.; INTELLISIST, INC.; AVAYA MANAGEMENT L.P.; and OTHERS
  • Assignee: WILMINGTON TRUST, NATIONAL ASSOCIATION, AS COLLATERAL AGENT, DELAWARE
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest.
• 2023-04-03 (executed) / recorded 2023-04-26 — Reel 063457/0001
  • Conveyance: Assignment (Release of Security Interest)
  • Assignor: CITIBANK, N.A., AS COLLATERAL AGENT
  • Assignee: AVAYA INTEGRATED CABINET SOLUTIONS LLC, NEW JERSEY; AVAYA MANAGEMENT L.P., NEW JERSEY; AVAYA INC., NEW JERSEY; AVAYA HOLDINGS CORP., NEW JERSEY
  • Correspondent: Not specified in the provided text.
  • Context: Release of security interest.
• 2023-05-01 (executed) / recorded 2023-05-03 — Reel 063742/0001
  • Conveyance: Intellectual Property Security Agreement
  • Assignor: AVAYA MANAGEMENT L.P.; AVAYA INC.; INTELLISIST, INC.; and OTHERS
  • Assignee: WILMINGTON SAVINGS FUND SOCIETY, FSB (COLLATERAL AGENT), DELAWARE
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest.
• 2023-05-01 (executed) / recorded 2023-05-04 — Reel 063542/0662
  • Conveyance: Intellectual Property Security Agreement
  • Assignor: AVAYA INC.; AVAYA MANAGEMENT L.P.; INTELLISIST, INC.
  • Assignee: CITIBANK, N.A., AS COLLATERAL AGENT, NEW YORK
  • Correspondent: Not specified in the provided text.
  • Context: Transfer of security interest.
• 2023-05-01 (executed) / recorded 2023-05-18 — Reel 063779/0622
  • Conveyance: Assignment (Release of Security Interest)
  • Assignor: GOLDMAN SACHS BANK USA., AS COLLATERAL AGENT
  • Assignee: AVAYA MANAGEMENT L.P., NEW JERSEY; CAAS TECHNOLOGIES, LLC, NEW JERSEY; HYPERQUALITY II, LLC, NEW JERSEY; HYPERQUALITY, INC., NEW JERSEY; ZANG, INC. (FORMER NAME OF AVAYA CLOUD INC.), NEW JERSEY; VPNET TECHNOLOGIES, INC., NEW JERSEY; OCTEL COMMUNICATIONS LLC, NEW JERSEY; AVAYA INTEGRATED CABINET SOLUTIONS LLC, NEW JERSEY; INTELLISIST, INC., NEW JERSEY; AVAYA INC., NEW JERSEY
  • Correspondent: Not specified in the provided text.
  • Context: Release of security interest.
• 2023-05-01 (executed) / recorded 2023-05-18 — Reel 063705/0023
  • Conveyance: Assignment (Release of Security Interest)
  • Assignor: WILMINGTON TRUST, NATIONAL ASSOCIATION, AS NOTES COLLATERAL AGENT
  • Assignee: AVAYA INTEGRATED CABINET SOLUTIONS LLC, NEW JERSEY; INTELLISIST, INC., NEW JERSEY; AVAYA INC., NEW JERSEY; AVAYA MANAGEMENT L.P., NEW JERSEY
  • Correspondent: Not specified in the provided text.
  • Context: Release of security interest.
• 2023-05-01 (executed) / recorded 2023-05-18 — Reel 063690/0359
  • Conveyance: Assignment (Release of Security Interest)
  • Assignor: WILMINGTON TRUST, NATIONAL ASSOCIATION, AS NOTES COLLATERAL AGENT
  • Assignee: AVAYA INTEGRATED CABINET SOLUTIONS LLC, NEW JERSEY; INTELLISIST, INC., NEW JERSEY; AVAYA INC., NEW JERSEY; AVAYA MANAGEMENT L.P., NEW JERSEY
  • Correspondent: Not specified in the provided text.
  • Context: Release of security interest.
• 2023-05-01 (executed) / recorded 2023-09-21 — Reel 065019/0231
  • Conveyance: (SECURITY INTEREST) GRANTOR'S NAME CHANGE
  • Assignor: AVAYA INC.
  • Assignee: AVAYA LLC, DELAWARE
  • Correspondent: Not specified in the provided text.
  • Context: Name change of the grantor of a security interest, reflecting Avaya Inc. becoming Avaya LLC.

Timeline diagram

timeline
    title Ownership of US 9537900
    2014 : Filed by Avaya Inc
    2017 : Granted
         : Security Interest to Citibank
    2017 : Release of Security Interest from Citibank
    2018 : Security Interest to Goldman Sachs
         : Security Interest to Citibank
    2020 : Security Interest to Wilmington Trust
    2022 : IP Security Agreement to Wilmington Trust
    2023 : Release of Security Interest from Citibank
         : IP Security Agreement to Wilmington Savings Fund Society
         : IP Security Agreement to Citibank
         : Release of Security Interest from Goldman Sachs
         : Release of Security Interest from Wilmington Trust
         : Release of Security Interest from Wilmington Trust
    2023 : Security Interest Grantor Name Change to Avaya LLC

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The assignments show transfers related to Avaya Inc. (and its related entities) and various financial institutions for security interests. There is no evidence of a transfer to an entity with a name suggesting a licensing-only shell, nor information about their business model or address.
2. Known asserter in the chain — Not present. The assignees are Avaya Inc. (or its various iterations and subsidiaries) and several large financial institutions (Citibank, Goldman Sachs, Wilmington Trust, Wilmington Savings Fund Society). None of these entities are listed as known patent asserters in the provided search results.
3. Repeat correspondent across the chain — Unclear. The provided patent text does not specify the correspondent of record for any of the assignments.
4. Cascading transfers — Not present. While there are multiple transfers, they are primarily security interests and releases of security interests involving the original assignee and financial institutions. These are not transfers through chained LLCs aiming for assertion. There are several transfers within May 2023 (Reel 063457/0001, 063742/0001, 063542/0662, 063779/0622, 063705/0023, 063690/0359), but these are all related to Avaya's bankruptcy and subsequent financial restructuring (releases and new security agreements).
5. Pre-litigation transfer — Not present. No specific litigation against this patent was found in the provided snippets.
6. Bankruptcy fire-sale — Present. Avaya Inc. emerged from Chapter 11 bankruptcy in May 2023. Several assignments in 2023 (Reel 063457/0001, 063779/0622, 063705/0023, 063690/0359) explicitly mention releases of security interests, some specifically referencing a bankruptcy court order (Reel 044893/0531 for the 2017-12-15 recording). This indicates that the patent was part of assets managed during bankruptcy proceedings.
7. Privateering — Not present. There is no information to suggest that Avaya Inc. transferred this patent to an NPE to assert on its behalf.
8. Defensive aggregator (anti-NPE) — Not present. The chain does not end at any known defensive aggregators like RPX, Allied Security Trust (AST), LOT Network, Unified Patents, or Open Invention Network. While Avaya has been a member of AST, this patent has not been assigned to a defensive aggregator.

Verdict

Operating-company assertion
The patent remains with the original operating company, Avaya LLC (formerly Avaya Inc.), which continues to develop and provide communication solutions. The numerous assignments are primarily security interests and releases of security interests related to Avaya's financial restructuring and bankruptcy, rather than transfers to patent assertion entities [cite: 5, 7, 041576/0001, 044893/0531, 045034/0001, 045124/0026, 053955/0436, 061087/0386, 063457/0001, 063742/0001, 063542/0662, 063779/0622, 063705/0023, 063690/0359, 065019/0231].

Verification: https://assignmentcenter.uspto.gov/

To identify the most relevant prior art for US patent 9537900, each patent citation will be examined for its full citation, publication/filing date, a brief description, and which claims of US9537900 it potentially anticipates under 35 U.S.C. § 102. The analysis will focus on the unique elements of US9537900's claims, particularly the "application normalized view of device capability" and the application's role in determining features, as well as the dynamic updating and pushing of policies based on context changes.

Here are the cited prior art patents:

1. US20020002577A1

• Full Citation: US20020002577A1, Praerit Garg, "System and methods for providing dynamic authorization in a computer system"
• Publication/Filing Date: Priority date: 2000-06-28; Publication date: 2002-01-03
• Brief Description: This patent application describes a system and method for dynamic authorization that includes a policy access server, an authorization engine, and an interceptor. The system evaluates authorization requests based on dynamically updated policy data, which can change based on context. It allows for the enforcement of authorization policies by dynamically updating the policy data.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Intercepting, Dynamic Context, Authenticating, Monitoring, Updating): This reference teaches dynamic authorization based on context and dynamically updated policy data. Specifically, it involves intercepting requests and dynamically updating policies based on changing conditions. This broadly anticipates the steps of intercepting user access, determining a dynamic context, authenticating, monitoring for changes, and updating policies (steps 1, 2, 3, 8, 9, 10 of Claim 1; similar in Claims 4 and 7). However, it does not explicitly mention an "application normalized view of device capability" or the application determining features based on this view.
  • Claims 2, 5, 8 (Device type): The concept of context could include device type.

2. US6910074B1

• Full Citation: US6910074B1, Nortel Networks Limited, "System and method for service session management in an IP centric distributed network"
• Publication/Filing Date: Priority date: 2000-07-24; Publication date: 2005-06-21
• Brief Description: This patent describes managing service sessions in an IP network by using a session manager to process session requests and apply policies, which can be defined based on various attributes including user, service, and network conditions. It also discusses dynamic policy negotiation.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Context, Generating Policy, Monitoring, Updating): This patent discusses dynamic policy negotiation and management based on user, service, and network conditions, which aligns with determining a dynamic authentication context and generating policies. It broadly covers dynamic policy application and potentially updates.
  • Claims 2, 5, 8 (Device type): The "user attributes" could encompass device type.

3. US20090158425A1

• Full Citation: US20090158425A1, Oracle International Corporation, "User definable policy for graduated authentication based on the partial orderings of principals"
• Publication/Filing Date: Priority date: 2007-12-18; Publication date: 2009-06-18
• Brief Description: This application relates to user-definable policies for graduated authentication, where the level of authentication required can vary based on the context of the access attempt. This includes using partial orderings of principals to determine authentication requirements.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Authenticating): The concept of varying authentication based on context strongly anticipates the "determining a dynamic authentication context" and "authenticating the access credentials" steps, particularly where the authentication itself is graduated.
  • Claims 2, 5, 8 (Dynamic authentication context includes device type, capability, network, location): The "context of the access attempt" described could include these elements.

4. US7603657B2

• Full Citation: US7603657B2, Oracle International Corporation, "Customization of client-server interaction in an internet application"
• Publication/Filing Date: Priority date: 2001-03-02; Publication date: 2009-10-13
• Brief Description: This patent describes customizing client-server interactions in an Internet application based on client characteristics. It includes a server determining the client's characteristics (e.g., device type, capabilities) and tailoring the application's output or behavior accordingly.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Determining Dynamic Authentication Context, Application Normalized View, Application Determining Features): This reference is highly relevant as it explicitly discusses tailoring application behavior based on client characteristics/capabilities. This directly relates to the "determining a dynamic authentication context for the user device including one or more access credentials, wherein the dynamic authentication context includes a device capability" and the "determining, at the application, one or more features to be delivered... based on the dynamic authentication context and the application normalized view of the device capability" (steps 2 and 7 of Claim 1, similar in Claims 4 and 7). The tailoring of output based on client characteristics implicitly suggests an "application normalized view" or its functional equivalent, where the application adapts based on communicated device traits.
  • Claims 2, 5, 8 (Device type): Explicitly mentions device type as a client characteristic.

5. US7620708B2

• Full Citation: US7620708B2, Cisco Technology, Inc., "Automatic discovery of controlling policy enforcement point in a policy push model"
• Publication/Filing Date: Priority date: 2005-05-31; Publication date: 2009-11-17
• Brief Description: This patent describes a system and method for automatically discovering policy enforcement points (PEPs) and pushing policies to them. The system dynamically updates policies at the PEPs based on policy changes, without requiring the PEP to request the update.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Monitoring, Updating, Providing without request): This patent directly anticipates the steps of "monitoring... for a change in the dynamic authentication context," "updating... the dynamic service-based policy," and critically, "providing the updated dynamic service-based policy to the application without a request from the application for an updated dynamic service-based policy" (steps 8, 9, 10 of Claim 1, similar in Claims 4 and 7). The "policy push model" is a direct match for this aspect.

6. US8032623B2

• Full Citation: US8032623B2, International Business Machines Corporation, "Context-based dynamic policy assignment in a distributed processing environment"
• Publication/Filing Date: Priority date: 2003-09-30; Publication date: 2011-10-04
• Brief Description: This patent describes dynamically assigning policies based on a determined context in a distributed processing environment. The policies can be updated as the context changes.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Generating Policy, Monitoring, Updating): This reference teaches context-based dynamic policy assignment and updates as the context changes. This broadly anticipates determining a dynamic authentication context, generating a dynamic policy, monitoring for changes, and updating the policy (steps 2, 5, 8, 9 of Claim 1, similar in Claims 4 and 7).

7. US8341717B1

• Full Citation: US8341717B1, Sprint Communications Company L.P., "Dynamic network policies based on device classification"
• Publication/Filing Date: Priority date: 2008-11-13; Publication date: 2012-12-25
• Brief Description: This patent describes dynamically applying network policies based on classifying a device accessing a network. Device classification can include device type and capabilities, influencing network access and resource provisioning.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Device Type, Device Capability, Generating Policy): This patent is highly relevant as it explicitly bases dynamic policies on "device classification," which includes "device type and capabilities." This directly anticipates the "determining a dynamic authentication context for the user device including one or more access credentials, wherein the dynamic authentication context includes a device capability" (step 2 of Claim 1) and the generation of policies based on this context (step 5 of Claim 1).
  • Claims 2, 5, 8 (Device type): Explicitly mentions device type.

8. US20130054960A1

• Full Citation: US20130054960A1, Divx, Llc, "Systems and methods for application identification"
• Publication/Filing Date: Priority date: 2011-08-31; Publication date: 2013-02-28
• Brief Description: This patent application describes identifying applications used by a client device to apply policies, such as determining content access rights or quality of service, based on the identified application.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Application-specific policies): This broadly covers the concept of applying policies based on the application, which is a core theme in US9537900. While not directly mentioning dynamic context in the same detail, the idea of application-specific policies is present.

9. US20140096215A1

• Full Citation: US20140096215A1, Christian J. Hessler, "Method for mobile security context authentication"
• Publication/Filing Date: Priority date: 2012-09-28; Publication date: 2014-04-03
• Brief Description: This application describes a method for mobile security context authentication where authentication parameters are dynamically adapted based on the current security context of a mobile device. This context can include location, network, and device state.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Authenticating, Monitoring): This patent is highly relevant for "determining a dynamic authentication context" including location and network, and adapting authentication based on this context. It also implies monitoring for changes in this context to re-evaluate security. (steps 2, 3, 8 of Claim 1, similar in Claims 4 and 7).
  • Claims 2, 5, 8 (Device capability, network, access location): Explicitly mentions location and network as part of the security context, which aligns with the dynamic authentication context.

10. US8893218B2

• Full Citation: US8893218B2, International Business Machines Corporation, "Association of service policies based on the application of message content filters"
• Publication/Filing Date: Priority date: 2012-06-15; Publication date: 2014-11-18
• Brief Description: This patent discusses associating service policies with message content filters to dynamically apply policies based on the content of messages, potentially influencing how services are delivered.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Generating Dynamic Service-Based Policy): While focused on message content, the core idea of dynamically associating and applying service policies based on specific attributes (in this case, content) broadly relates to generating dynamic service-based policies.

11. US20150050922A1

• Full Citation: US20150050922A1, American Megatrends, Inc., "Mobile device security system"
• Publication/Filing Date: Priority date: 2013-08-19; Publication date: 2015-02-19
• Brief Description: This application describes a mobile device security system that determines a security level based on device context (e.g., location, network, user identity) and enforces security policies dynamically.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Generating Policy, Monitoring, Updating): This reference strongly anticipates determining a dynamic authentication context (including location, network), generating policies, and dynamically enforcing/updating them based on context changes (steps 2, 5, 8, 9, 10 of Claim 1, similar in Claims 4 and 7).
  • Claims 2, 5, 8 (Device capability, network, access location): Explicitly mentions location and network as part of the device context.

12. US9288235B1

• Full Citation: US9288235B1, Microsoft Technology Licensing, Llc, "Contextually aware device management"
• Publication/Filing Date: Priority date: 2014-09-17; Publication date: 2016-03-15
• Brief Description: This patent describes managing device functionality and access to resources based on a "context profile" of the device. The context can include device type, location, time, and user, and policies are applied dynamically based on this context.
• Potential Anticipation (35 U.S.C. § 102):
  • Claims 1, 4, 7 (Dynamic Authentication Context, Generating Policy, Monitoring, Updating): This patent is highly relevant as it describes using a "context profile" (device type, location, user) to dynamically apply policies and manage device functionality and resource access. This directly anticipates determining a dynamic authentication context, generating dynamic policies, monitoring for changes, and updating policies (steps 2, 5, 8, 9, 10 of Claim 1, similar in Claims 4 and 7).
  • Claims 2, 5, 8 (Device type, network, access location): Explicitly mentions device type and location as part of the context profile.

Most Relevant Prior Art

Based on the analysis, the following prior art appears to be most relevant, specifically anticipating core aspects of US9537900's claims:

• US7603657B2 (Oracle International Corporation): This patent explicitly addresses customizing application interaction based on client characteristics and capabilities, which directly relates to the "application normalized view of device capability" and the application determining features. This appears to be a strong anticipatory reference for steps 2, 5, and 7 of Claim 1 (and corresponding elements in Claims 4 and 7).
• US7620708B2 (Cisco Technology, Inc.): This patent directly teaches a "policy push model" where updated policies are sent without a request from the enforcement point. This is a very strong anticipation for step 10 of Claim 1 (and corresponding elements in Claims 4 and 7), "providing the updated dynamic service-based policy to the application without a request from the application for an updated dynamic service-based policy."
• US8341717B1 (Sprint Communications Company L.P.): This patent focuses on "dynamic network policies based on device classification," explicitly mentioning device type and capabilities. This directly anticipates the determination of a dynamic authentication context including device capability and device type (steps 2 of Claim 1, 2 of Claim 2, and corresponding elements).
• US20140096215A1 (Christian J. Hessler): This reference addresses "mobile security context authentication" and adapts authentication based on dynamic context including location and network, which are key aspects of the dynamic authentication context in US9537900.
• US9288235B1 (Microsoft Technology Licensing, Llc): This patent describes "contextually aware device management" based on a "context profile" (device type, location, user) and applying policies dynamically. This broadly anticipates many of the context-driven policy generation, monitoring, and updating aspects.

These references collectively address the concepts of dynamic context determination (including device capabilities, type, location, network), dynamic policy generation and update, and the push of policies to enforcement points. US7603657B2 is particularly noteworthy for its focus on the application's role in adapting features based on client capabilities, aligning closely with the "application normalized view" aspect. US7620708B2 directly anticipates the "push" mechanism.

To analyze the obviousness of US patent 9537900 under 35 U.S.C. § 103, we must identify combinations of prior art references that would render the claims obvious to a person having ordinary skill in the art (PHOSITA) at the time of the invention (filing date: 2014-05-24). The PHOSITA in this field would likely be an engineer or developer with experience in computer networking, security, and application development, possessing knowledge of authentication systems, policy enforcement, and client-server interactions.

The core problem identified by US9537900 is the need for "fine grain policy enforcement based on dynamic context" for users accessing networks and applications with diverse devices and profiles. The patent aims to provide mechanisms for serving application-specific policies based on dynamic context, including device capabilities, and dynamically updating these policies.

Independent Claims Analysis

The independent claims of US9537900 are Claim 1 (method), Claim 4 (system), and Claim 7 (nontransitory computer readable medium). Since Claims 4 and 7 essentially recite the steps of Claim 1 as being performed by a system or stored on a medium, an obviousness analysis of Claim 1 will largely cover the other independent claims.

Let's break down the elements of Claim 1:

1. Intercepting, at one or more processors of an authentication system, an attempt by a user device to access an application served remotely from the user device;
2. Determining, at the one or more processors of the authentication system, a dynamic authentication context for the user device including one or more access credentials, wherein the dynamic authentication context includes a device capability;
3. Authenticating, at the one or more processors of the authentication system, the access credentials;
4. Determining, at the one or more processors of the authentication system, an indication of a need for a service-based policy, wherein the indication of a need for a service-based policy includes determining the user device is seeking to access the application served remotely from the user device;
5. Generating, at the one or more processors of the authentication system, a dynamic service-based policy based on the dynamic authentication context and an application, wherein the dynamic service-based policy includes an application normalized view of the device capability;
6. Providing, at the one or more processors of the authentication system, the dynamic service-based policy to the application, including the application normalized view of the device capability;
7. Determining, at the application, one or more features to be delivered from the remotely served application to the user device as part of an application session based on the dynamic authentication context and the application normalized view of the device capability;
8. Monitoring, at the one or more processors of the authentication system, for a change in the dynamic authentication context, wherein the change in the dynamic authentication context includes a change in the device capability;
9. Updating, at the one or more processors, the dynamic service-based policy to generate an updated dynamic service-based policy; and
10. Providing the updated dynamic service-based policy to the application without a request from the application for an updated dynamic service-based policy.

Obviousness Combination

A strong combination of prior art references that would render Claim 1 (and thus Claims 4 and 7) obvious is:

1. US20020002577A1 (Garg): "System and methods for providing dynamic authorization in a computer system"
2. US7603657B2 (Oracle): "Customization of client-server interaction in an internet application"
3. US7620708B2 (Cisco): "Automatic discovery of controlling policy enforcement point in a policy push model"

Explanation of the Combination and Motivation:

A PHOSITA, aiming to create a more adaptable and secure system for managing user access to applications across diverse devices, would be motivated to combine these known elements from the prior art. The general desire to provide better user experience and granular control in complex network environments, as articulated in the background of US9537900, would drive such a combination.

How the Combination Renders Claim 1 Obvious:

• Elements 1, 3, 4, 8 (in part), 9: Dynamic Context-Based Authorization and Updates.

  • Garg teaches a system for dynamic authorization that grants user access based on "context-sensitive information" such as user identity, application identity, location identity, and security identity. This directly addresses intercepting access attempts, authenticating credentials, determining a need for a policy when a user seeks to access an application, and generating dynamic policies based on context. Garg further teaches that authorization policies can be updated dynamically, which inherently involves monitoring for context changes and then updating the policy.

• Elements 2, 5 (in part), 7: Incorporating Device Capability and Application-Specific Feature Delivery.

  • While Garg's context includes "security identity," Oracle (US7603657B2) explicitly teaches customizing client-server interaction based on "client capabilities" (e.g., browser type, device capabilities). A PHOSITA would find it obvious to integrate device capability into Garg's dynamic authentication context. The motivation would be to enhance the granularity of policy enforcement and improve user experience by ensuring that applications deliver features appropriate to the specific device being used. The concept of an "application normalized view of the device capability" (element 5) would be an obvious design choice for a PHOSITA to facilitate interoperability, allowing the authentication system (as in Garg) to present diverse device capabilities in a standardized format that applications (as in Oracle) can readily consume to determine appropriate features (element 7), thereby relieving applications of the burden of handling varied capability expressions. The detailed description of US9537900 itself notes that applications "may be relieved of the burden of handling a varied set of capability expressions from various types of user devices."

• Element 10: Providing Updated Policies Without Request (Policy Push).

  • Cisco (US7620708B2) teaches a "policy push model" where policies are automatically pushed to enforcement points. A PHOSITA, seeking to make Garg's dynamic policy updates more efficient and responsive to real-time context changes, would be motivated to implement a push model for policy delivery. This ensures that when the authentication system (from Garg) detects a change in the dynamic authentication context and updates the policy, the updated policy is proactively sent to the relevant application without requiring the application to repeatedly request it. This directly addresses the efficiency and responsiveness concerns in dynamic environments.

• Element 6: Providing Dynamic Service-Based Policy to the Application.

  • Once a dynamic policy is generated based on context (Garg) and includes device capabilities in a normalized view (Oracle integration), providing this policy to the application is an inherent step for any policy enforcement system, whether through a pull mechanism (implied by Garg for authorization) or a push mechanism (explicitly taught by Cisco).

• Element 8 (complete): Monitoring for a Change in Device Capability.

  • Garg teaches monitoring for context changes for dynamic policy updates. Given the integration of "device capability" into the dynamic context (as motivated by Oracle), extending this monitoring to include changes in device capability (e.g., a user switching from a laptop to a mobile phone or moving to a network with different capabilities) would be an obvious and desirable enhancement for a PHOSITA to maintain granular, dynamic control.

Conclusion on Obviousness:

The combination of US20020002577A1 (Garg), US7603657B2 (Oracle), and US7620708B2 (Cisco) directly teaches or strongly suggests all the elements of independent Claim 1 of US9537900. The motivation for combining these references stems from the clear advantages of creating a more robust, dynamic, and user-aware access control system that can adapt to varying device capabilities and changing user contexts in an efficient manner. A PHOSITA would readily understand the benefits of integrating dynamic, context-aware policy generation, device capability-based application customization, and proactive policy distribution to address the challenges outlined in the background of US9537900.

Therefore, the methods, systems, and computer-readable media described in US9537900 would likely have been obvious to a person having ordinary skill in the art at the time of the invention.