PTAB

IPR2017-00927

Apple Inc v. Evolved Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of expanding a code sequence, a structure of a random access channel and a method of transmitting data in a mobile communication system.
  • Brief Description: The ’481 patent discloses methods and transmitters for generating and sending a preamble sequence on a Random Access Channel (RACH) in a mobile communication system. The invention involves repeating a specific base sequence N times to create a longer consecutive sequence and then prepending a single cyclic prefix (CP) to the front of this repeated sequence before transmission.

3. Grounds for Unpatentability

Ground 1: Obviousness over Panasonic 700 - Claims 1 and 2 are invalid over Panasonic 700.

  • Prior Art Relied Upon: Panasonic 700 (a 3GPP contribution document titled “RACH preamble evaluation in E-UTRA uplink,” Feb. 2006).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Panasonic 700 discloses every limitation of independent claim 1. It teaches a RACH preamble structure consisting of M repetitions of a Zadoff-Chu Constant Amplitude Zero Auto Correlation (CAZAC) sequence to form a consecutive sequence. This structure is preceded by a single cyclic prefix (CP) and is transmitted within a single radio frame, which was known to be 10 ms. This maps to the claimed method of repeating a sequence, generating a consecutive sequence, concatenating a CP, and transmitting on a RACH. For dependent claim 2, Petitioner asserted that Panasonic 700 explicitly identifies the specific sequence being repeated as a CAZAC sequence.

Ground 2: Obviousness over Panasonic 700, Panasonic 114, and Chu - Claims 4 and 6 are obvious.

  • Prior Art Relied Upon: Panasonic 700, Panasonic 114 (a 3GPP contribution document titled “Random access design for E-UTRA uplink,” May 2006), and Chu (a 1972 IEEE paper titled “Polyphase Codes With Good Periodic Correlation Properties”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Panasonic 700 teaches the foundational preamble structure with repeated CAZAC sequences. Panasonic 114, which addresses the same technical problem, improves upon this by proposing the use of cyclic-shifted Zadoff-Chu sequences for superior performance. Chu, the seminal paper on Zadoff-Chu sequences cited by the Panasonic references, teaches the fundamental properties of these sequences, including that applying cyclic shifts does not negatively affect correlation properties. Chu explicitly discloses that a cyclic shift can be determined as an integer multiple of a shift unit (claim 4) and can be applied by multiplying the base sequence by an exponential sequence (claim 6).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) designing a RACH preamble would combine Panasonic 700 and Panasonic 114 as they both address the same design problem in the same standards body (3GPP WG1), with Panasonic 114 offering a clear performance improvement. A POSITA would logically consult the foundational Chu reference, cited by both Panasonic documents, to understand the mathematical properties of the Zadoff-Chu sequences and how to implement the cyclic shifts proposed in Panasonic 114.
    • Expectation of Success: A POSITA would have a high expectation of success, as the benefits of cyclic shifting were well-documented and the mathematical principles in Chu were well-established and predictable.

Ground 3: Obviousness over Panasonic 700 and Motorola 595 - Claims 8 and 9 are obvious.

  • Prior Art Relied Upon: Panasonic 700 and Motorola 595 (Application # 2007/0058595).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses the apparatus claims (8 and 9) by mapping the preamble generation method from Panasonic 700 onto a conventional hardware transmitter structure disclosed in Motorola 595. Petitioner argued that Panasonic 700 discloses the functional steps for the "preamble generation unit" and "transmission unit." Motorola 595 provides the necessary structural components, teaching a standard transmitter architecture with logic circuitry (e.g., a microprocessor) and a transmission circuit that are inherently capable of performing the signal generation and transmission steps taught by Panasonic 700. Claim 9 adds that the specific sequence is a CAZAC sequence, which is directly taught by Panasonic 700.
    • Motivation to Combine: A POSITA would combine the functional teachings of Panasonic 700 with the structural disclosure of Motorola 595 because it would be a routine, common-sense design choice to implement the known preamble generation method on a standard, well-known transmitter architecture. Both references are from the same field of endeavor (cellular communication), making the combination straightforward.
    • Expectation of Success: Implementing known signal processing algorithms on standard hardware like a microprocessor was a routine task with a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 3, 10, 11, and 13 based on further combinations of Panasonic 700, Panasonic 114, Chu, and Motorola 595, which largely extended the arguments for the grounds summarized above to further dependent claims.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this petition, filed with a motion for joinder to IPR2016-01342, is not time-barred under 35 U.S.C. §315(b). Petitioner also contended that its grounds are not redundant with other pending IPR proceedings against the ’481 patent because this petition relies on different primary prior art references, grounds, and arguments than those presented in the other proceedings.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6, 8-11, and 13 of Patent 8,218,481 as unpatentable.