PTAB

IPR2014-01032

Apple Inc v. Mobile Telecommunications Technologies LLC

Key Events

Petition

petition Intelligence

Title: Method and System for Efficiently Providing Two Way Communication Between a Central Network and Mobile Unit
Brief Description: The ’403 patent describes methods for managing information transmission in a wireless communication system. The system uses a plurality of transmitters divided into at least two sets, which can transmit different blocks of information during different time periods, including simulcasting information to mobile receivers.

Prior Art Relied Upon: Linquist (Patent 5,423,056).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Linquist discloses every limitation of the challenged claims. Linquist describes a paging system with multiple hubs, each containing multiple antenna towers or "sticks." These sticks can be grouped into sets of overlapping cells ("first and second set of transmitters"). The system operates in both a simulcast mode, where messages are broadcast to all sticks in a hub, and a cellular mode, where different messages are directed to particular cells or hubs. Petitioner contended this maps directly to claim 1’s requirement of transmitting a first block of information via simulcast during a first time period, and then transmitting second and third blocks of information from the first and second sets of transmitters, respectively, during a second time period. For claim 10, Petitioner argued that Linquist’s system of routing messages only to the specific hub where a mobile receiver is known to be located, and updating this information as the receiver moves between hubs, anticipates the limitation of "dynamically reassigning" base transmitters.

Prior Art Relied Upon: Uddenfeldt (Patent 5,109,528).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Uddenfeldt’s disclosure of a mobile radio system with an area divided into cells anticipates the claims. Some cells in Uddenfeldt contain two or more base station transmitters, which constitute the "first and second sets of transmitters." Petitioner argued that Uddenfeldt teaches transmitting a "first block of information" (e.g., cell identity signals) in simulcast during a "first time period." Subsequently, during a "second time period," the sets of transmitters in different cells transmit distinct message information (a "second block" and "third block") to mobiles within their respective coverage areas. For claim 10, Petitioner contended that Uddenfeldt’s mobile handoff mechanism, where base transmitters in an adjacent cell are assigned to handle a mobile's communication based on traffic conditions, meets the "dynamically reassigning" limitation.

Prior Art Relied Upon: Gilhousen (Patent 5,109,390).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Gilhousen’s CDMA cellular system, which uses cell-site diversity, anticipates the claims. When a call is initiated, all cell-sites in an area transmit the same paging message to the intended mobile unit, which Petitioner mapped to the "first and second sets of transmitters" transmitting a "first block of information in simulcast" during a "first time period." After the mobile responds, the call is routed through a specific group of at least two cell-sites ("first set of transmitters") which then transmit the call ("second block of information") during a "second time period." Petitioner also argued that other cell-sites could simultaneously handle other calls, meeting the requirements for the "second set of transmitters" and "third block of information." For claim 10, Petitioner asserted that Gilhousen’s diversity mode, where the system can dynamically add a new cell-site with a stronger signal to service an ongoing call, anticipates the "dynamically reassigning" limitation.

"Transmitter" and "Base Transmitter": Petitioner argued these terms should be construed by their plain and ordinary meaning, with the understanding that they refer to a distinct structural unit. Transmitting multiple signals or outputs from a single structural unit cannot suffice as multiple transmitters. This construction was noted as consistent with orders in co-pending litigation.
"Set[s] of transmitters" and "Set of base transmitters": Petitioner proposed construing these terms to mean "a set of at least two [base] transmitters." This construction aligns with the plural form of "transmitters" in the claims and is consistent with constructions adopted by the PTAB and district courts in related matters.
"Transmit...in simulcast," "Transmitted...in simulcast," and "Transmitting...in simulcast": Petitioner argued these phrases should be construed to mean "transmitting the same information at the same time." This construction also mimics those resolved in co-pending litigation and adopted by the PTAB in a related IPR.

Petitioner requested institution of an inter partes review and cancellation of claims 1 and 10 of the ’403 patent as unpatentable.