PTAB

IPR2015-01726

Samsung Electronics Co v. Mobile Telecommunications Technologies LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Multicarrier Techniques in Bandlimited Channels
  • Brief Description: The ’891 patent describes methods and systems for operating multiple paging carriers within a single, bandlimited channel. The technology uses co-located transmitters for multicarrier modulation to achieve higher transmission capacity while complying with FCC emission mask limits.

3. Grounds for Unpatentability

Ground 1: Anticipation over Petrovic - Claims 1-5 are anticipated by Petrovic under 35 U.S.C. §102.

  • Prior Art Relied Upon: Petrovic, et al., "Permutation Modulation for Advanced Radio Paging," IEEE Proceedings of Southeastcon '93 (Apr. 7, 1993) (“Petrovic”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Petrovic, co-authored by two inventors of the ’891 patent, describes a nearly identical multicarrier paging system. The petition asserted that Petrovic explicitly discloses the key limitation that led to the patent’s allowance: the frequency difference between the outermost carrier and the band edge being greater than half the frequency difference between adjacent carriers. Specifically, Petrovic taught a 7.5 kHz guard band (the distance from the outermost carrier to the band edge) and a 5 kHz spacing between adjacent carriers. Therefore, the first value (7.5 kHz) is greater than half the second value (2.5 kHz), satisfying the limitation of independent claims 1, 3, and 5. For dependent claims 2 and 4, Petitioner showed that figures in Petrovic illustrate overlapping adjacent carriers/subchannels. For claim 5, Petitioner argued Petrovic’s disclosure of combining outputs from four "subtransmitters" and sending them to a "common antenna" meets the limitation of co-locating a plurality of transmitters.
    • Motivation to Combine (for §103 grounds): Not applicable (Anticipation ground).
    • Expectation of Success (for §103 grounds): Not applicable (Anticipation ground).

Ground 2: Obviousness over Petrovic, Raith, and Alakija - Claim 5 is obvious over Petrovic in view of Raith and Alakija.

  • Prior Art Relied Upon: Petrovic, Raith et al. (WO 89/08355) (“Raith”), and Alakija et al., "A Mobile Base Station Phased Array Antenna," 1992 IEEE International Conference (“Alakija”).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1 for claim 5, premised on a construction where the transmitters in Petrovic’s simulcast experiment (located seven miles apart) are not considered "co-located." Petitioner asserted that Petrovic taught all elements of claim 5 except for co-location. Raith taught a cellular mobile radio system where it was common to co-locate base station transmitters to service contiguous cells. Alakija taught combining multiple feed networks into a single antenna structure using a cylindrical array to achieve hardware savings and lower costs.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would be motivated to modify Petrovic's experimental paging system to provide service over a larger geographic area. A POSITA would look to known cellular network designs like Raith and be motivated to adopt its technique of co-locating transmitters to service adjacent paging cells. To implement this efficiently, the POSITA would then be motivated by Alakija to combine the outputs of these co-located transmitters into a single antenna structure to realize the known benefits of reduced hardware, manufacturing, and installation costs.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in combining these known elements, as it involved applying conventional cellular network design principles (Raith) and well-understood antenna consolidation techniques (Alakija) to an existing paging system (Petrovic) to achieve predictable improvements in coverage and cost-efficiency.

4. Key Claim Construction Positions

  • "single mask-defined, bandlimited channel" (claims 1, 3, 5): Petitioner proposed the construction "a channel confined to a frequency range." This construction was noted as being consistent with the Board's finding in prior IPRs involving the ’891 patent and with district court rulings.
  • "plurality of transmitters" (claim 5): Petitioner proposed "at least two transmitters," which was also consistent with prior Board and court constructions.
  • "transmitter(s)" (claim 5): Petitioner proposed the construction "structural unit(s) for generating and modulating a signal to be transmitted." This construction was argued to be critical, as it distinguishes a system with multiple distinct structural units from a single unit that produces multiple outputs, a distinction relevant to the obviousness argument in Ground 2.
  • "operating a plurality of paging carriers" (claims 1, 3): Petitioner argued this phrase should be construed to require signals actively carrying "paging information," rather than merely being capable of carrying such information.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5 of the ’891 patent as unpatentable.