PTAB

IPR2015-00578

Apple Inc v. Cellular Communications Equipment LLC

Key Events

Petition

petition Intelligence

Title: Apparatus, System, and Method for Designating a Buffer Status Reporting Format Based on Detected Pre-Selected Buffer Conditions
Brief Description: The ’820 patent discloses methods and systems for efficiently reporting the data status of buffers in a wireless User Equipment (UE) to a network. The invention reduces overhead by selecting between a "short" and a "long" buffer status reporting format based on detected conditions, such as the amount of data in the buffers and the available uplink bandwidth.

Prior Art Relied Upon: Malkamaki (Application # 2006/0143444).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Malkamaki discloses every limitation of the challenged claims. Malkamaki teaches a method for communicating scheduling information from a UE by sending variable-sized buffer status reports that conform to the amount of available padding bits in a protocol data unit (PDU). Petitioner asserted this system inherently performs the claimed steps of monitoring buffers, detecting a condition (e.g., data exceeding a threshold), and designating a reporting format. Critically, Malkamaki’s use of available padding to send a larger, more detailed report was argued to be equivalent to the claimed step of designating a "long buffer status reporting format when there is sufficient uplink bandwidth." Malkamaki discloses different report sizes (e.g., 6-bit short, 24-bit long) based on the number of data priorities to report, which is determined by the available space.
- Key Aspects: For the means-plus-function limitations of claim 23, Petitioner contended that Malkamaki discloses equivalent structures, namely a UE with a processor and memory executing conventional software to perform the monitoring, detecting, designating, and communicating functions.

Prior Art Relied Upon: Malkamaki (Application # 2006/0143444) and Pedersen (Application # 2007/0201369).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that even if Malkamaki does not explicitly disclose detecting a plurality of pre-selected conditions (e.g., multiple data thresholds), Pedersen remedied this. Pedersen teaches a threshold-based buffer status reporting scheme where multiple data thresholds are used to define different regions of buffer occupancy. Petitioner argued it would have been obvious to apply Pedersen’s more granular, multi-threshold detection method to Malkamaki’s system for sending variable-sized reports.
- Motivation to Combine: A POSITA would combine these references because both were directed to solving the same problem of reducing overhead and improving efficiency for buffer status reporting in HSUPA wireless networks. A POSITA would have been motivated to use Pedersen's precise multi-threshold detection to provide more accurate input for Malkamaki's flexible, variable-sized reporting mechanism, thereby improving uplink scheduling accuracy.
- Expectation of Success: Success was expected because it involved applying a known technique (multi-threshold detection from Pedersen) to a similar system (Malkamaki) to achieve the predictable benefit of more accurate buffer reporting.

Prior Art Relied Upon: Malkamaki (Application # 2006/0143444) and Ye (8,031,655).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed the key limitation of designating the long format "when there is sufficient uplink bandwidth." If Malkamaki’s use of padding was deemed insufficient to teach this limitation, Petitioner argued that Ye explicitly supplied it. Ye discloses a system where the base station allocates "uplink bandwidth resources" via a scheduling grant, which determines the "granularity level" of the buffer status report. A higher granularity level, permitted when sufficient bandwidth is granted, allows the UE to send a longer, more detailed report.
- Motivation to Combine: A POSITA would combine Malkamaki and Ye because both sought to achieve efficient uplink scheduling by varying the size or granularity of buffer status reports to reduce overhead. A POSITA would have been motivated to incorporate Ye's explicit teaching of conditioning the report length on the allocated uplink bandwidth into Malkamaki’s framework to create a more robust and efficient reporting system.
- Expectation of Success: Combining Ye’s bandwidth-dependent format selection with Malkamaki’s variable-sized reporting structure was a straightforward integration of complementary concepts to achieve the predictable result of optimized reporting.

"long buffer status reporting format" / "short buffer status reporting format": Petitioner proposed these terms be construed relatively, meaning a format that is simply longer or shorter than an alternative format, without requiring any specific bit length. This construction was central to arguing that the variable-sized reports in the prior art (e.g., Malkamaki's 6-bit vs. 24-bit formats) met the claim limitations.
"designate[s] the long buffer status reporting format when there is sufficient uplink bandwidth": Petitioner argued this phrase should encompass designating a long format when there is sufficient space available in a transport block's padding to accommodate it. This construction, supported by the patent’s prosecution history and the Patent Owner’s positions in co-pending litigation, was critical for mapping Malkamaki, which teaches using leftover padding bits for buffer status reports, onto the claims.

Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of the ’820 patent as unpatentable.