PTAB

IPR2016-01493

Apple Inc v. Cellular Communications Equipment LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Reporting of Power Control Headroom
  • Brief Description: The ’676 patent discloses methods for a mobile station in a wireless network to report its transmission power headroom to a base station. The invention proposes using a set of triggering criteria, such as an elapsed time threshold, to control the frequency of these reports to reduce uplink signaling overhead while ensuring the base station has sufficiently current information for resource management.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 19 are obvious over Fong in view of Ericsson Contribution

  • Prior Art Relied Upon: Fong (Application # 2004/0223455) and Ericsson Contribution (3GPP document R2-052744).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fong taught the core concept of the ’676 patent: using a time-based trigger to prevent a mobile station from sending power headroom reports too frequently. Fong disclosed a "MIN_DURATION" threshold that must be met before a new report is sent. However, Fong did not specify the units for this duration. Ericsson Contribution, a 3GPP standards document, taught that the periodicity of power headroom reports is defined in integer units of Transmission Time Intervals (TTIs), a standard unit of time in wireless communications.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) implementing Fong’s system, which required a time threshold, would have been motivated to consult well-known industry standards documents like the Ericsson Contribution to determine an appropriate and standard unit of measurement. Since both references address the same problem of efficient power headroom reporting in similar wireless systems (UMTS/3GPP), the combination was a logical step to implement a practical system.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success. The combination was merely applying a known unit of time (TTIs) from Ericsson Contribution to the time threshold concept in Fong. Because Fong's system already operated using uniform time periods, it was readily compatible with a system that counts an integer number of TTIs, making the modification predictable and straightforward.

Ground 2: Claims 3 and 21 are obvious over Fong in view of Ericsson Contribution and further in view of Bark

  • Prior Art Relied Upon: Fong (Application # 2004/0223455), Ericsson Contribution (R2-052744), and Bark (Patent 6,445,917).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Fong and Ericsson Contribution, which established a time-based trigger measured in TTIs. Dependent claims 3 and 21 add a second triggering criterion: sending a report only if the "absolute difference between current and most recent path-loss measurements has reached a threshold." Petitioner argued that Bark explicitly taught this concept. Bark disclosed using trigger events to make measurement reporting more efficient, and one of its primary examples was triggering a report when the rate of change of a parameter, such as path loss, exceeded a predefined threshold.
    • Motivation to Combine: A POSITA seeking to improve the efficiency of the Fong/Ericsson system would be motivated to add other known trigger conditions to further reduce unnecessary signaling. Bark provided a well-known path-loss trigger that directly addressed this goal. Combining the time-based trigger with a path-loss trigger ensures that reports are sent only when a sufficient amount of time has passed and a material change in channel conditions has actually occurred, which is more efficient than relying on time alone.
    • Expectation of Success: The combination was predictable. Both Fong and Bark taught that using multiple trigger criteria was a beneficial and known technique to manage signaling overhead. Adding Bark’s path-loss trigger to the Fong/Ericsson system was an obvious way to enhance its performance using a known technique to solve a known problem, yielding predictable results.

4. Key Claim Construction Positions

  • "power control headroom report": Petitioner argued this term, under the broadest reasonable interpretation, should be construed to mean "a report containing power headroom or some equivalent information." This position was based on the specification's interchangeable use of "power headroom" and "power control headroom."
  • "absolute difference": Petitioner contended this term required no special construction and should be given its plain and ordinary mathematical meaning: "absolute value of a difference."
  • Means-Plus-Function Limitations (Claim 19): For the "memory including software..." limitations recited in claim 19, Petitioner acknowledged they were potentially governed by §112, ¶ 6. For the purposes of the IPR, Petitioner argued the corresponding structure was the "memory including software and at least one processor" disclosed in the specification, a structure Petitioner contended was fully disclosed in the prior art.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 3, 19, and 21 of the ’676 patent as unpatentable.