Ex parte AULT et al.

Board of Patent Appeals and Interferences

Nov 26, 2001

08632251 (B.P.A.I. Nov. 26, 2001)

1–
The opinion in support of the decision being
entered today was not written for publication
and is not binding precedent of the Board.
Paper No. 23
UNITED STATES PATENT AND TRADEMARK OFFICE
________________
BEFORE THE BOARD OF PATENT APPEALS
AND INTERFERENCES
________________
Ex parte DONALD F. AULT, JOHN C. DAYKA,
ERIC C. FINKELSTEIN, and RICHARD H. GUSKI
________________
Appeal No. 2000-1360
Application No. 08/632,251
________________
ON BRIEF
________________
Before KRASS, FLEMING, and DIXON, Administrative Patent
Judges.
KRASS, Administrative Patent Judge.
DECISION ON APPEAL
This is a decision on appeal from the final rejection of
claims 1-12, all of the pending claims.
Appeal No. 2000-1360
Application No. 08/632,251
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The invention is directed to a method and apparatus for
controlling server access to a resource in a client/server
system. More particularly, the invention is directed to the
problem of “untrusted” servers which present a security risk
since the host system cannot assume that they have not
manipulated a client’s identity and are not accessing a
resource on their own behalf while purporting to act on behalf
of a client. Access rights of these servers acting as
principals are specified by the instant invention by allowing
such servers to access only those host resources that the
servers themselves can access as principals, even when the
servers purport to be acting on behalf of a client that has
access to those resources. Since untrusted servers access
rights are limited, untrusted servers are allowed to coexist
on a host system together with trusted servers.
Representative independent claim 1 is reproduced as
follows:
1. In a client/server system in which a server executing
on a host system performs application services for a client
that involve accessing a host resource, said client and said
server each having independently specified access rights to
said host resource, a method of controlling server access to
said host resource comprising the steps of:
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Application No. 08/632,251
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upon receiving a request from a client for a service from
a server, creating a client security context for said client,
said client security context indicating whether said client is
an authenticated client that is authenticated to said host
system or an unauthenticated client that is not authenticated
to said host system;
upon receiving a request for a specified access to a host
resource from a server purporting to act on behalf of a
client:
determining whether said client is allowed said access to
said resource;
determining whether said client is an authenticated
client or an unauthenticated client;
if said client is an authenticated client, granting said
access to said host resource if said client is allowed said
access to said host resource; and
if said client is an unauthenticated client, determining
whether said server is allowed said access to said resource
independently of said client and granting said access to said
host resource if both said client and said server are
independently allowed said access to said host resource,
otherwise, refusing said access to said host resource.
The examiner relies on the following references:
Baker et al. (Baker) 5,678,041 Oct. 14, 1997
[filed Aug. 25, 1995]
Teper et al. (Teper) 5,815,665 Sep. 29, 1998
[filed Apr. 03, 1996]
Claims 1-12 stand rejected under 35 U.S.C. 103 as
unpatentable over Baker in view of Teper.
Reference is made to the brief and answer for the
respective positions of appellants and the examiner.
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Application No. 08/632,251
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OPINION
At the outset, we note that, in accordance with
appellants’ grouping of the claims, at page 4 of the brief,
and lack of separate arguments directed to the patentability
of separate claims, claims 1-12 will stand or fall together.
It is the examiner’s position that Baker discloses the
claimed subject matter but for the claimed “creating a client
security context for said client” upon receiving a request
from a client for a service from a server. The examiner
relies on Teper for a teaching of creating this “client
security context,” pointing to various portions of Teper,
including the abstract, Figures 1-3, column 3, lines 5-53,
column 7, lines 30-65, column 9, line 25 through column 10,
line 29, column 10, line 44 through column 11, line 33, and
column 20, lines 6-48.
The examiner then concludes that it would have been
obvious to incorporate the teachings of Teper for creating a
client security context for each client with the method of
Baker for controlling server access to the host resource
because “it would decrease the client overhead and increase
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Application No. 08/632,251
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the security in order to helps [sic] server system to verify
that the user is valid user [sic] and helps user [sic] to
verify that the service received from the server is valid
service” [answer-page 6].
We reverse as the examiner has failed to establish a
prima facie case of obviousness with regard to the instant
claimed subject matter.
Each of the independent claims requires that the client
and the server each has “independently specified access
rights.”
Thus, taking claim 1 as an example, a client is determined to
be authenticated or unauthenticated when the client requests
service from a server. When a server requests service on
behalf of a client, it is determined whether that client is
allowed access to the resource and it is determined whether
that client is an authenticated or unauthenticated client.
Based on the results, access is granted to the resource if the
client is authenticated AND is allowed access to that
resource. If the client is unauthenticated, a determination
is made of whether the server is allowed access to the
resource independently of the client. Access is granted to
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the resource if both the client and the server are
independently allowed the access to the resource. If not,
access to the resource is denied.
Thus, access to a resource is granted only if both the
client and the server are independently allowed access to the
resource.
We do not find this limitation taught or suggested by the
applied references. The examiner contends otherwise, stating
that Baker’s proxy server 112 has independently specified
rights to the host resources 101-105. The examiner quotes,
“...retrieves rating and rational information from resource
categorization information listing 300, and provides a manager
with a page that facilitates editing of the rating,” citing
Figure 6 and column 7, lines 40-43, and concluding that this
“implies that the server having independently specified access
rights (user clearance and resource rating) to the host
resource (network resource)” [answer-pages 10-11].
We are at a loss to understand how the examiner is
interpreting Baker to arrive at the claimed limitation of the
independently allowed access to the resource by the client and
the server. Rather, we agree with appellants that Baker’s
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clients 107-109 and proxy server 112 do not have independently
specified access rights to the host resources because Baker’s
network is a public network which presumes access rights.
Therefore, Baker does not teach determining the access rights
of a server to a host resource independently of a client for
which it is acting, nor does it teach conditioning client
access to that resource based upon the combined access rights
of the client and server, depending on the authenticated
status of the client.
Moreover, we agree with appellants that it is the
untrustworthiness of the server that is at issue in
appellants’ invention. Therefore, it would be absurd, in the
instant claimed invention, for the server to be performing the
authenticating and access control steps, as it apparently does
in Baker. As stated
by appellants, at page 9 of the brief, the better analogy
would be if the internet sites 101-105 in Baker determined the
authenticated status of the users 107-109 and granted access
to unauthenticated users only if the proxy server 12 were also
authorized to access the Internet resources. But, since Baker
does not operate in this manner because the network therein is
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Application No. 08/632,251
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public, there is no teaching of the instant claimed subject
matter nor is there any suggestion in Baker that the proxy
server in Baker presents any security problem. Rather, Baker
is interested in restricting access to certain sites by
particular users and the determination of whether those users
are authenticated and able to gain access to the sites is made
before forwarding any request from a client to a server. The
determination is not made “upon receiving a request...from a
server,” as claimed.
Teper clearly does not provide for this deficiency in
Baker and the examiner does not rely on Teper for this
feature. Since the combination of references does not reach
the claimed limitation regarding the independently specified
access rights of the client and the server, we do not reach
the question of whether Teper provides a proper teaching of
the creating of “a client security context” for combining with
Baker.
The examiner’s decision rejecting claims 1-12 under
35 U.S.C. 103 is reversed.
REVERSED
Appeal No. 2000-1360
Application No. 08/632,251
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ERROL A. KRASS )
Administrative Patent Judge )
)
)
)
)
MICHAEL R. FLEMING ) BOARD OF PATENT
Administrative Patent Judge ) APPEALS AND
) INTERFERENCES
)
)
)
JOSEPH L. DIXON )
Administrative Patent Judge )
EK/RWK
WILLIAM A. KINNAMAN, JR.
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