PTAB

IPR2017-00461

Sony Corp v. Broadcom Corp

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petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Adaptive Transmission of Information Over a Plurality of Channels
  • Brief Description: The ’955 patent relates to wireless networking systems, specifically methods for adapting the transmission of information over multiple channels. The technology addresses assigning data bits for transmission based on feedback information received from a receiving device to improve transfer rates and reduce packet error rates.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-27, 29, and 30 by Ling under 35 U.S.C. § 102

  • Prior Art Relied Upon: Ling (Application # 2003/0043928).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ling, which discloses a flexible coding scheme for multiple-input multiple-output (MIMO) wireless systems, teaches every limitation of the challenged claims. Independent claim 1’s method of concurrently transmitting data via multiple RF channels and antennas, receiving feedback related to those channels (e.g., Signal-to-Noise Ratio or SNR), assigning bits for transmission based on that feedback, and transmitting subsequent data at a coding rate determined by that bit assignment are all explicitly disclosed in Ling. Similarly, Petitioner asserted that independent claims 11 (a corresponding method from the receiver’s perspective) and 21 (a corresponding system) are fully taught by Ling’s disclosure of a complete MIMO communication system.

Ground 2: Obviousness of Claims 23, 27-29 over Ling in view of Walton

  • Prior Art Relied Upon: Ling (Application # 2003/0043928) and Walton (Application # 2003/0035491).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that to the extent Ling is found not to explicitly disclose the "processor" limitations of claims 23, 27, and 29, Walton provides the missing element. Ling describes the functional steps of computing coding rates based on feedback, while Walton expressly discloses a "TX data processor" that receives channel state information (CSI) feedback and uses it to compute and select coding and modulation schemes. The combination of Ling's overall system with Walton's explicit processor disclosure renders these claims obvious.
    • Motivation to Combine: A POSITA would combine Ling and Walton because they describe nearly identical MIMO systems developed by the same assignee (Qualcomm) in the same timeframe, and they share two inventors. Both references address the same problem of adaptive transmission based on feedback. A POSITA implementing Ling’s system would have naturally looked to the closely related Walton reference for details on a processor architecture to perform the required computations.
    • Expectation of Success: A POSITA would have a high expectation of success in combining the references, as it involved applying Walton’s specific processor implementation to the functionally equivalent and highly compatible system described in Ling. No technical hurdles or incompatibilities would prevent the combination.

Ground 3: Obviousness of Claims 1-30 over Ling in view of Walton and Kim

  • Prior Art Relied Upon: Ling (Application # 2003/0043928), Walton (Application # 2003/0035491), and Kim (Application # 2004/0141566).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative, arguing that if the "assigning bits" limitation is construed to require assigning bits from a pre-determined, fixed total, Kim teaches this feature. While Ling and Walton teach assigning bits based on channel quality, Kim discloses a refined method for improving system performance by assigning bits using a "greedy algorithm" where the total number of bits for an OFDM symbol is fixed. This algorithm specifically allocates a fixed bit pool among various transmission antennas based on feedback.
    • Motivation to Combine: All three references are directed to solving performance issues in MIMO systems by using feedback to adapt transmission. A POSITA seeking to optimize the Ling/Walton system would be motivated to incorporate Kim's teachings to address scenarios where a fixed number of bits must be allocated. Kim’s greedy algorithm provides a known, complementary technique for improving bit allocation efficiency, making it an obvious modification to the base system.
    • Expectation of Success: The combination would be a straightforward integration of a known bit-allocation algorithm (Kim) into a standard MIMO system architecture (Ling/Walton), presenting predictable results and a clear path to successful implementation.

4. Key Claim Construction Positions

  • "tone" (claims 6, 16, 26): Petitioner argued that in the context of Orthogonal Frequency-Division Multiplexing (OFDM) systems, as described in the ’955 patent and understood in the art, the term "tone" should be construed to mean "frequency subchannel." This construction was asserted to be critical because prior art, including Ling, explicitly discloses computing SNR and other metrics based on "frequency sub-channels" (or pilot signals transmitted thereon), directly mapping onto the claim language under this proposed construction.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-30 of Patent 7,616,955 as unpatentable.