PTAB

IPR2016-01160

ARRIS Group Inc v. TQ Delta LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multicarrier Transmission System with a Low Power Sleep Mode
  • Brief Description: The ’404 patent describes systems and methods for establishing a power management sleep state in a multicarrier communication system, such as an Asymmetric Digital Subscriber Line (ADSL) system. The invention involves a transceiver storing line parameters ("state memory") before entering a low-power mode, enabling a rapid resumption of full-power transmissions without a full reinitialization.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bowie and Vanzieleghem - Claims 1-20 are obvious over Bowie in view of Vanzieleghem and the 1995 ADSL Standard.

  • Prior Art Relied Upon: Bowie (Patent 5,956,323), Vanzieleghem (Patent 6,246,725), and the 1995 ADSL Standard (ANSI T1.413-1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary references disclosed the key elements of the ’404 patent's claims within the established framework of the 1995 ADSL Standard. Bowie taught a low-power mode for terminal units that involved storing "loop characteristic parameters" to enable a rapid recovery to normal operation. Vanzieleghem separately taught a method for reducing power consumption in a multicarrier transmitter by using only a single carrier (a "pilot tone") to maintain synchronization during idle periods. The 1995 ADSL Standard provided the foundational context, defining the superframe structure, initialization parameters (like gain and bit allocation), and operational environment for ADSL transceivers that both Bowie and Vanzieleghem sought to improve.
    • Motivation to Combine: A POSITA would combine Bowie and Vanzieleghem because they offered complementary solutions to the well-known problem of high power consumption in ADSL systems. Bowie provided a macro-level framework for entering and exiting a low-power state by storing parameters, while Vanzieleghem provided a specific, micro-level technique for maintaining synchronization efficiently during that state. Combining these teachings was a predictable way to create a robust power-saving feature for a standard ADSL transceiver.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The integration involved applying Vanzieleghem’s synchronization method within Bowie’s power state management protocol, all within the clearly defined operational parameters of the 1995 ADSL Standard, presenting no significant technical hurdles.

Ground 2: Obviousness over T1E1.4 Contributions - Claims 1-20 are obvious over the combination of T1E1.4/97-161R1 and T1E1.4/97-319 in view of the 1995 ADSL Standard.

  • Prior Art Relied Upon: 97-161R1 (T1E1.4 Contribution, "Warm Re-Start for ADSL"), 97-319 (T1E1.4 Contribution, "Power Down in Multicarrier Transmission"), and the 1995 ADSL Standard (ANSI T1.413-1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted these two standards-body contributions, presented at the same September 1997 T1E1.4 Working Group meeting, disclosed all claimed elements. 97-161R1 explicitly proposed a method for a "warm restart" by storing key modem parameters, including "bit and gain allocations," to avoid a lengthy re-initialization sequence. 97-319 proposed a "power down" mode where a single carrier is used to maintain synchronization and provide a signaling channel for coordinating power states between transceivers. It also suggested periodically testing line conditions. The 1995 ADSL Standard provided the technical backdrop, defining the lengthy initialization that 97-161R1 sought to bypass.
    • Motivation to Combine: A POSITA would combine these contributions because they were presented to the same standards body as complementary solutions to the recognized drawback of slow recovery from power-down in the 1995 ADSL Standard. The meeting minutes and context showed a collective effort to improve the standard. A designer looking to implement an efficient power-down mode would have naturally looked to these contemporaneous, publicly discussed proposals and combined 97-161R1’s parameter-storage concept with 97-319’s synchronization-maintenance technique.
    • Expectation of Success: The combination was a straightforward engineering choice. The proposals were designed to work within the ADSL framework and were discussed by experts in the field for that purpose. Integrating the parameter storage from one proposal with the low-power synchronization from the other would have been a predictable implementation of a complete power-saving solution.

4. Key Claim Construction Positions

  • "Synchronization Signal" (Claims 1, 6, 11, 16): Petitioner argued this term, which is not explicitly defined in the ’404 patent specification, should be construed as "a signal allowing frame synchronization between the transmitter of the signal and the receiver of the signal." Petitioner contended that the only related mechanism disclosed in the specification is a "timing reference signal" used to synchronize frame counters between transceivers, making this the representative embodiment for the claim limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’404 patent as unpatentable.