PTAB

IPR2016-00981

Apple Inc v. Evolved Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of Transmitting Data in a Mobile Communication System
  • Brief Description: The ’481 patent relates to a method for data transmission in a communication system. The invention focuses on a method for generating and transmitting a preamble sequence over a random access channel (RACH) to improve signal detection.

3. Grounds for Unpatentability

Ground 1A: Anticipation of Claims 1 and 15 by IEEE802.16-2004

  • Prior Art Relied Upon: IEEE802.16-2004 (an IEEE Standard for wireless access systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that IEEE802.16-2004 explicitly discloses every element of independent claim 1. The standard describes transmitting a "long preamble" for initial ranging that is generated by repeating a specific sequence N times to create a consecutive sequence, which is then preceded by a single cyclic prefix (CP). The standard further discloses transmitting this preamble on a random access channel to a receiving base station. For dependent claim 15, Petitioner asserted the standard teaches that the CP is a copy of the last few samples of the useful symbol period, making it identical to a rear part of the N-th repeated sequence.

Ground 1B: Claims 8 and 16 are obvious over IEEE802.16-2004 in view of Chou

  • Prior Art Relied Upon: IEEE802.16-2004, Chou (Patent 8,977,258).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that IEEE802.16-2004 teaches the preamble structure and transmission method, as established in Ground 1A. However, it does not explicitly disclose a "preamble generation unit" within a transmitter. Chou remedies this by disclosing stand-alone subscriber stations that operate according to the IEEE802.16-2004 standard and include internal, integrated PHY and MAC units for generating and transmitting signals. The combination therefore teaches the transmitter of claim 8 with the claimed preamble generation and transmission units. Claim 16 is obvious for the same reasons claim 15 was anticipated by IEEE802.16-2004.
    • Motivation to Combine: A POSITA would combine these references because it was a well-known and common practice to integrate signal generation hardware internally within a transmitter. Chou’s teaching of an integrated subscriber station based on the IEEE802.16-2004 standard provided an explicit reason to place the preamble generation functionality within the transmitter to create a compact, stand-alone device and avoid the cost, latency, and interference associated with external components.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved implementing a known function (preamble generation) within a standard component (a transmitter) for a predictable result.

Ground 1C: Claims 2-4 and 6 are obvious over IEEE802.16-2004 in view of Tan

  • Prior Art Relied Upon: IEEE802.16-2004, Tan (Provisional Application # 60/759,697).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that while IEEE802.16-2004 teaches the method of claim 1, Tan teaches the specific improvements recited in the dependent claims. Tan discloses generating preamble sequences from a Constant Amplitude Zero Auto-Correlation (CAZAC) sequence to improve detection performance (claim 2). Tan further teaches applying a cyclic shift to the CAZAC sequence (claim 3), where the shift value is an integer multiple of a predetermined unit (claim 4), to increase the number of available RACH opportunities. Finally, Tan shows that applying this cyclic shift is mathematically equivalent to multiplying the sequence by an exponential sequence (claim 6).
    • Motivation to Combine: A POSITA would be motivated to use a CAZAC sequence as taught by Tan in the IEEE802.16-2004 system because the ’481 patent itself acknowledges that CAZAC sequences provide "excellent transmission characteristics." Tan explicitly teaches using CAZAC sequences and cyclic shifts in 802.16 communication systems to improve detection and increase RACH capacity, providing a clear motivation to apply these known techniques to the system disclosed in IEEE802.16-2004 for their stated benefits.
    • Expectation of Success: Success would be expected because Tan’s teachings are directly applicable to the context of the primary reference and provide a predictable improvement in system performance.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the combination of IEEE802.16-2004, Chou, and Tan (Ground 1D). Petitioner also presented an entire alternative set of grounds (2A-2D) arguing that if the claim preambles were deemed limiting, the claims would be obvious over combinations including IEEE802.16e-2005, which explicitly updates the primary IEEE802.16-2004 standard to support mobile stations.

4. Key Claim Construction Positions

  • "in a mobile communication system" (preambles of claims 1 and 8): Petitioner argued this preamble phrase should be construed as non-limiting. The argument centered on the fact that the term "mobile" does not appear in the body of any challenged claim and provides no antecedent basis for any claim limitation. Petitioner asserted the claim bodies are structurally complete on their own and the preamble merely states a purpose or intended use for the invention, which is insufficient to limit claim scope. The petition’s grounds were bifurcated based on this construction, with one set of grounds (1A-1D) applying if the preamble is non-limiting and an alternative set (2A-2D) applying if it is limiting.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-4, 6, 8-11, 13, 15, and 16 of the ’481 patent as unpatentable.