PTAB

IPR2016-00765

ARRIS Group Inc v. Mobile Telecommunications Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Providing Multicarrier Simulcast Transmission
  • Brief Description: The ’210 patent discloses a two-way communication system that combines multi-carrier modulation with simulcast broadcasting techniques. The system uses a network of base transmitters to broadcast information simultaneously to mobile units, aiming to maximize information throughput across different geographic zones.

3. Grounds for Unpatentability

Ground 1: Anticipation by Saalfrank - Claims 1, 7, 10, 16-17, and 19 are anticipated under 35 U.S.C. §102 by Saalfrank.

  • Prior Art Relied Upon: Saalfrank (German Publication No. DE4102408).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Saalfrank discloses every limitation of the challenged claims. Saalfrank describes a "common-wave radio" network where multiple "transmitter stations simultaneously emit transmission signals with the same modulation content on the very same transmission frequency," which Petitioner contended is a multi-carrier simulcast system. The use of a Coded Orthogonal Frequency Division Multiplex (COFDM) method with "a plurality of individual carriers" (e.g., 448 carriers) using 4-DPSK modulation was argued to meet the multi-carrier limitations. Petitioner asserted that Saalfrank’s teaching that "individual carriers are each modulated with one part of the digital data" satisfies the claim requirement that each carrier represents a unique portion of an information signal. The requirement for a first and a second, spatially separated transmitter was allegedly met by Saalfrank's disclosure of a "nationwide" network composed of multiple discrete transmission regions, each containing multiple transmitters. For means-plus-function claims 7 and 19, Petitioner asserted that the necessary structures, such as modulators, are inherently disclosed because they are required to perform Saalfrank's described 4-DPSK modulation and transmission functions.

Ground 2: Obviousness over Saalfrank and Nakamura - Claims 8, 15, and 19 are obvious over Saalfrank in view of Nakamura.

  • Prior Art Relied Upon: Saalfrank (German Publication No. DE4102408) and Nakamura (a 1987 IEEE journal article on 256 QAM modems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Saalfrank teaches the overall multi-carrier simulcast system but does not specify a detailed transmitter structure. Nakamura discloses a high-performance 256 Quadrature Amplitude Modulation (QAM) based transmitter capable of modulating multiple carrier signals. Petitioner asserted that Nakamura's explicit disclosure of a QAM transmitter renders claims 8 and 15 obvious, as they recite QAM as a possible modulation scheme. For claim 19, Petitioner contended that Nakamura provides the specific transmitter structure (including modulators, combiners, and amplifiers) that corresponds to the "means for transmitting" limitation. The structure disclosed in Nakamura was argued to be nearly identical to the embodiment depicted in Figure 14 of the ’210 patent.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Saalfrank's system with Nakamura's transmitter to implement a robust, high-bandwidth network. Saalfrank's nationwide system required capable transmitters, and Nakamura taught a high-performance transmitter with known benefits, including high throughput (up to 400 Mbit/s), "good phase jitter performance," and no "false lock phenomenon." These characteristics made Nakamura’s transmitter a well-known and suitable component for realizing the system described by Saalfrank.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references. Nakamura's transmitter was a well-understood component designed for high-data-rate digital radio systems, making its integration into the network architecture of Saalfrank a predictable and straightforward implementation of known technologies to achieve a desired result.

4. Key Claim Construction Positions

  • "a ... transmitter": Petitioner proposed construing this term as "a structural unit for generating and modulating a signal to be transmitted." This construction was argued to be consistent with the patent's specification and extrinsic evidence, emphasizing that a transmitter is a distinct structural unit. This interpretation supported the argument that Saalfrank's multiple "transmitter stations" satisfy the claim requirement for at least a first and a second transmitter.
  • "means for transmitting...": For the means-plus-function terms in claim 19, Petitioner identified the corresponding structure as the base transmitter embodiments shown in Figures 13 and 14 of the ’210 patent, or their equivalents. Petitioner argued this construction requires the transmitters to be "geographically separated," a feature they contended was essential for the patent’s disclosed zone-based simulcast system and was disclosed in the prior art.
  • "in simulcast": Petitioner proposed construing this term to mean "at the same time." This construction was presented as consistent with prior constructions of the same term for the ’210 patent in both district court litigation and previous IPR proceedings.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1, 7-8, 10, 15-17, and 19 of Patent 5,915,210 as unpatentable.