PTAB

IPR2017-00736

Broadcom Ltd v. Tessera Advanced Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Arrangement for Setting the Transmission of a Mobile Communication Device
  • Brief Description: The ’393 patent discloses methods and systems for setting the transmitted power of a mobile communication device. The technology involves a signal processing chain that includes a controllable digital amplifier and one or more controllable analog amplifiers, where a control circuit matches the digital and analog gains to produce a desired overall transmitted power.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-7, 9, 10, 15, 16, 19, and 20 by Ichihara

  • Prior Art Relied Upon: Ichihara (Patent RE40,553).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ichihara, a reference for adjusting transmission power in a CDMA terminal, discloses every element of the challenged claims. Independent claims 1 and 15 recite a method and apparatus for setting transmitted power by matching digital and analog gains based on a comparison of measured and desired power values. A key limitation, added during prosecution to overcome prior art, requires "controlling the digital gain to minimize a contribution of the analog gain to the overall gain." Petitioner asserted Ichihara teaches this by describing a power control scheme where the analog gain amplifier is only employed to provide a gain increase after the digital gain amplifier for a specific code channel has reached its maximum capacity. By prioritizing the use of the digital amplifier, Ichihara’s system inherently minimizes the analog gain's contribution.
    • Key Aspects: Petitioner emphasized that Ichihara was not applied by the Examiner during prosecution, although its parent patent was cited.

Ground 2: Obviousness of Claims 5, 6, 8, 10-14, 17, and 18 over Ichihara in view of Xiong

  • Prior Art Relied Upon: Ichihara (Patent RE40,553) and Xiong (Application # 2004/0198261).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ichihara by adding Xiong to teach limitations related to self-calibration and power sensing not explicitly disclosed in Ichihara. For claim 5, which requires a "self-calibration process," Petitioner argued Xiong explicitly teaches inexpensive and accurate self-calibration for wireless devices to compensate for power gain variations. For claims requiring storing parameters in a microcontroller (claims 6 and 10) and calculating a table of corrections (claim 11), Petitioner pointed to Xiong's disclosure of using a baseband processor to store error values or linearizer characteristics in a lookup table to offset gain control. For claim 8, which adds measuring transmitted power with a power sensor, Petitioner mapped this to Xiong’s disclosure of a power detector coupled to an antenna input node.
    • Motivation to Combine: A POSITA would combine Ichihara and Xiong because both address the common problem of monitoring and adjusting transmitted power in a wireless device. A POSITA would have been motivated to incorporate Xiong’s teachings on inexpensive and accurate self-calibration and power measurement into Ichihara's power control system to improve its performance, reliability, and cost-effectiveness.
    • Expectation of Success: A POSITA would have reasonably expected success in combining the references, as implementing a known self-calibration technique (Xiong) into a standard power control architecture (Ichihara) involves applying predictable electrical engineering principles.

Ground 3: Obviousness of Claims 1-7, 8, 9, 10, 15, 16, 19, and 20 over Ichihara in view of Barak

  • Prior Art Relied Upon: Ichihara (Patent RE40,553) and Barak (Patent 7,471,935).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground asserted that even if Ichihara alone did not teach every element of claim 1, any missing elements would have been obvious in view of Barak. Specifically, for the limitation of controlling digital gain to minimize analog gain contribution, Petitioner argued Barak discloses an automatic level control system that does precisely this. Barak teaches that if transmitted power is too high and the digital gain is already at its minimum, the analog gain is attenuated; this demonstrates a system that prioritizes digital gain adjustment to control power, thereby minimizing the analog gain's role. For dependent claims related to fine and coarse gain adjustments (claim 3), Petitioner cited Barak’s disclosure of an automatic level control having both fine and coarse control capabilities.
    • Motivation to Combine: A POSITA would combine Ichihara and Barak due to their overlapping focus on automatic level and power control in mobile communication systems. A POSITA would look to Barak’s detailed gain control strategies to enhance the precision and effectiveness of the power control system described in Ichihara.
    • Expectation of Success: The combination was argued to be predictable, as it would involve integrating known gain control logic from Barak into the well-defined signal processing architecture of Ichihara.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 5, 6, 8, 10-14, 17, and 18 based on the combination of Ichihara, Barak, and Xiong, relying on similar arguments for combining the references to address various aspects of power control, measurement, and calibration.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-20 of the ’393 patent as unpatentable.