PTAB

IPR2016-01177

Apple Inc v. Evolved Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Transmitting and Receiving Signals Based on Segmented Access Scheme and Method for Allocating Sequence for the Same
  • Brief Description: The ’965 patent discloses a method for a user equipment (UE) in a wireless communication system to perform a random access procedure. The method involves dividing a set of available preamble signatures into subsets and selecting a subset based on criteria such as path loss, from which a specific preamble is then randomly chosen for transmission.

3. Grounds for Unpatentability

Ground 1: Anticipation over Schulist - Claims 1, 3, and 8 are anticipated by Schulist under 35 U.S.C. §102.

  • Prior Art Relied Upon: Schulist (International Publication No. WO 2004/030392).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schulist discloses every limitation of claims 1, 3, and 8. Schulist describes improving the WCDMA random access procedure by dividing the complete set of sixteen preamble signatures into individual "path loss classes." A UE first estimates the downlink path loss and then, based on this estimate, selects the corresponding subset of preambles. The UE then randomly selects one signature from that subset to transmit on the Physical Random Access Channel (PRACH). Petitioner asserted this directly maps to the claimed method of selecting a preamble sequence set based on a degree of path loss, randomly selecting a sequence from that set, and transmitting it. This argument relied on the Petitioner's proposed claim construction that "considering at least one of... A and... B" means considering A or B.
    • Key Aspects: The core of this ground rested on Schulist's explicit teaching of partitioning preamble signatures based on path loss to reduce collisions and optimize power control, which Petitioner contended was identical to the method claimed in the ’965 patent.

Ground 2: Obviousness over Schulist and Popovic - Claims 2 and 9 are obvious over Schulist in view of Popovic under 35 U.S.C. §103.

  • Prior Art Relied Upon: Schulist (WO 2004/030392) and Popovic (International Publication No. WO 2007/082409).
  • Core Argument for this Ground:
    • Prior Art Mapping: Dependent claims 2 and 9 require the specific random access sequence to be a Constant Amplitude Zero Auto-Correlation (CAZAC) sequence. While Schulist taught using orthogonal Walsh sequences for its preambles, Popovic addressed improving preamble detection probability at low signal-to-interference ratios. Popovic specifically proposed replacing the then-common Hadamard sequences (which Petitioner noted are mathematically related and often used interchangeably with Walsh sequences) with superior zero-correlation zone sequences, such as CAZAC sequences. Petitioner argued that Schulist provided the base random access method, and Popovic provided the specific type of sequence recited in claims 2 and 9.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Schulist with Popovic to improve the performance of the random access system. Popovic explicitly identified a problem with existing sequences (like those in Schulist) and provided a solution—using CAZAC sequences—to achieve better detection properties. A POSITA would have recognized this benefit and applied Popovic's improved sequences to Schulist’s random access framework.
    • Expectation of Success: The combination would have been a straightforward substitution of one known type of sequence for another to achieve a predictable improvement in signal detection, leading to a high expectation of success.

Ground 3: Obviousness over Schulist and Rao - Claims 1-3 and 8-9 are obvious over Schulist in view of Rao under §103.

  • Prior Art Relied Upon: Schulist (WO 2004/030392) and Rao (Application # 2007/0291708).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground was presented as an alternative, particularly if the claim term "considering at least one of a size of information... and a degree of a path loss" were construed conjunctively (requiring both). Schulist taught partitioning preambles based on path loss. Rao taught a similar method of partitioning preambles into classes but based the selection on the "initial data packet size." Petitioner argued that combining the teachings would result in a system where preamble sets are selected based on both path loss (from Schulist) and information size (from Rao).
    • Motivation to Combine: Petitioner argued that both Schulist and Rao aimed to improve random access efficiency by implicitly conveying information to the base station through preamble selection, thereby reducing latency. A POSITA would have been motivated to combine the two approaches to convey even more information implicitly (both path loss and packet size), further reducing latency and improving resource allocation. Both references suggested that their primary criteria could be combined with other parameters, motivating a POSITA to integrate them.
    • Expectation of Success: Combining the selection criteria was presented as a predictable design choice. A POSITA could create a larger matrix of preamble subsets (e.g., four path loss classes x two packet size classes) and map the available preambles accordingly, which would have been a well-understood and achievable task.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 2 and 9 based on the combination of Schulist, Rao, and Popovic, arguing that a POSITA would have been motivated to build the system taught by Schulist and Rao and further improve it by incorporating the CAZAC sequences taught by Popovic.

4. Key Claim Construction Positions

  • Petitioner argued that the phrase “considering at least one of a size of information to be transmitted by the specific UE and a degree of a path loss” should be construed disjunctively to mean “considering at least one of a size of information to be transmitted by the specific UE or a degree of a path loss.”
  • This construction was critical for Petitioner's anticipation argument in Ground 1, as Schulist disclosed considering path loss alone. Petitioner supported this construction by citing specification examples in the ’965 patent that described allocating sequence sets based only on path loss, arguing this showed an intent to treat the choices alternatively.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 8, and 9 of the ’965 patent as unpatentable.