PTAB

IPR2017-00982

HTC Corp v. Cellular Communications Equipment LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Reporting of Aperiodic Channel Information in Communication Systems with Carrier Aggregation
  • Brief Description: The ’472 patent relates to methods for reducing reporting overhead in wireless communication systems that use multiple component carriers (carrier aggregation). The technology enables a mobile device, upon receiving a request, to measure and report channel quality information for only a single, selected downlink component carrier instead of for all available carriers.

3. Grounds for Unpatentability

Ground 1: Claims 1, 10, 11, 14, 28, 37, 38, and 41 are obvious over Seo.

  • Prior Art Relied Upon: Seo (Patent 8,625,513).
  • Core Argument for this Ground: Petitioner argued that the ’472 patent’s allegedly novel feature—determining the selected component carrier for reporting based on which carrier transmitted the request—was already explicitly disclosed in the prior art. Seo was asserted to address the exact same problem of reducing channel quality indicator (CQI) reporting overhead in multi-carrier systems and to solve it in precisely the same manner. Petitioner contended that the very limitation the patent examiner relied upon for allowance was well-known and taught by Seo.
    • Prior Art Mapping: Petitioner alleged that Seo discloses all limitations of the challenged claims. Independent claims 1 and 28 recite a method and apparatus for receiving a request for aperiodic channel information, determining the selected component carrier based on which carrier carried the request, establishing channel information for that carrier, and sending it. Petitioner mapped this to Seo’s “Embodiment 2,” which teaches that to request CQI reporting for a specific downlink component carrier (CC), a control channel (PDCCH) containing a 1-bit CQI request in an uplink grant is transmitted on that specific CC. The user equipment (UE) then implicitly understands to transmit a CQI report for the downlink CC on which it received the request. This process directly teaches determining the selected carrier based on where the request was received.
    • Petitioner further argued that Seo teaches the limitations of the dependent claims. For claims 37 and 10, Seo’s “Embodiment 5” was cited as teaching a modified request that triggers CQI reporting for all component carriers, thus satisfying the limitation of providing information for "other component carriers." For claims 38 and 11, Seo was shown to teach that CQI can be "wideband CQI," meeting the wideband channel information limitation. For claims 41 and 14, Seo explicitly states that the request for non-periodic CQI reporting is "included in an uplink grant."
    • Motivation to Combine (for §103 grounds): As a single-reference obviousness challenge, the motivation was framed as the desire to solve the known problem of excessive reporting overhead in multi-carrier systems. Petitioner argued a person of ordinary skill in the art (POSITA), aware of the overhead problem Seo explicitly addresses, would have been motivated to implement Seo's efficient and predictable solution of implicitly indicating the target carrier, thereby arriving at the claimed invention. This technique was argued to be more efficient than methods requiring explicit signaling of the target carrier.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in implementing Seo’s teachings, as Seo provides an enabling disclosure of a functioning system for selective CQI reporting that directly addresses and solves the known overhead issue.

4. Key Claim Construction Positions

  • "channel information": Petitioner argued that under the broadest reasonable construction, this term encompasses specific examples disclosed in the specification, such as a channel quality indicator (CQI) or channel state information (CSI). This construction was critical because the primary prior art reference, Seo, extensively discusses reporting "CQI."
  • "a processor configured to...": Petitioner addressed several "processor configured to" limitations (e.g., "determine," "establish"). Recognizing that definiteness cannot be challenged in an inter partes review (IPR), Petitioner argued that for IPR purposes, the broadest reasonable interpretation of these terms encompasses a processor performing the recited functions. Petitioner asserted that the Seo reference discloses such a processor (Processor Unit 131) that performs the claimed functions, rendering the claims obvious regardless of any potential indefiniteness issues.

5. Relief Requested

  • Petitioner requested the institution of an IPR and cancellation of claims 1, 10, 11, 14, 28, 37, 38, and 41 of the ’472 patent as unpatentable.