PTAB

IPR2017-01473

Samsung Electronics Co Ltd v. Huawei Technologies Co Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Timing Synchronization in Mobile Communication Systems
  • Brief Description: The ’583 patent discloses a method and device for a mobile station in a wireless communication system to manage uplink timing synchronization. The purported novelty is the mobile station’s ability to selectively ignore received timing alignment information if the device is already in an “uplink synchronous status.”

3. Grounds for Unpatentability

Ground 1: Claims 3, 4, and 7 are obvious over TS 36.300, alone or in combination with Toskala and Dalsgaard.

  • Prior Art Relied Upon: TS 36.300 (3GPP Technical Specification V8.1.0, June 2007), Toskala (Patent 6,657,988), and Dalsgaard (WO 2007/110483).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that TS 36.300, a foundational 3GPP E-UTRAN standard, discloses all basic elements of the challenged claims, including the contention-based random access procedure and the maintenance of an uplink "synchronization status." Petitioner asserted that TS 36.300's teaching that a timing advance command is executed on a "per need basis" would have rendered it obvious to a POSITA to ignore the command when the mobile station (UE) is already synchronized. This is further supported by TS 36.300's disclosure of a Discontinuous Reception (DRX) mode where the UE saves power by ignoring incoming messages. To the extent TS 36.300 is deemed insufficient, Toskala was cited for teaching a system that ignores individual Time Alignment Bits (timing information) until a counter reaches a threshold, effectively maintaining a synchronous status where adjustments are deferred. Dalsgaard was cited for teaching a UE that determines the validity of a timing advance parameter using a timer; if the parameter is still valid (i.e., the UE is synchronous), it is used, but if it becomes invalid (asynchronous), it is ignored and a new one is acquired. The timer-based management of synchronous status in both Toskala and Dalsgaard was argued to render dependent claim 4 obvious.
    • Motivation to Combine: A POSITA would have been motivated to combine these references as they all operate within the same technical field of 3GPP wireless communication standards. Toskala and Dalsgaard relate to UMTS, the predecessor to the E-UTRAN standard described in TS 36.300, and explicitly state their applicability to such systems. A POSITA seeking to implement or improve the "per need basis" timing control in TS 36.300 would naturally look to prior art like Toskala and Dalsgaard for established methods of managing synchronization status and determining when adjustments are truly needed.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these teachings, as it would involve applying known synchronization management techniques to the well-defined random access framework of the 3GPP standard to achieve the predictable result of improved efficiency.

Ground 2: Claims 3, 4, and 7 are obvious over TS 36.300 in view of Sun.

  • Prior Art Relied Upon: TS 36.300 (3GPP Technical Specification V8.1.0, June 2007) and Sun (Patent 7,286,841).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner relied on TS 36.300 as the primary reference disclosing the standard random access procedure. Sun was introduced to explicitly teach the core inventive concept: ignoring a timing command when synchronized. Sun discloses that a UE can "just ignore the SS [Synchronization Shift] command" if a synchronization counter has not overflowed, which signifies the UE is still in a synchronous status. Petitioner argued this provides an explicit teaching for the "ignore" limitation. Sun's use of a counter to track synchronization status until it overflows was also argued to directly teach the timer limitation of dependent claim 4.
    • Motivation to Combine: Sun explicitly states that its method for maintaining uplink synchronization is applicable to "advanced wireless communication systems in 3GPP," which directly describes the E-UTRAN/LTE standard of TS 36.300. A POSITA would therefore be expressly motivated to apply the specific synchronization techniques from Sun to the broader system architecture described in TS 36.300 to improve efficiency, consistent with the "per need basis" principle.
    • Expectation of Success: Success would be expected, as the combination involves integrating a specific, published control logic for 3GPP systems (from Sun) into the foundational 3GPP framework (TS 36.300).

Ground 3: Claims 3, 4, and 7 are obvious over TS 36.300 in view of R1-072197.

  • Prior Art Relied Upon: TS 36.300 (3GPP Technical Specification V8.1.0, June 2007) and R1-072197 (a 3GPP contribution document from Texas Instruments, May 2007).
  • Core Argument for this Ground:
    • Prior Art Mapping: With TS 36.300 as the baseline, R1-072197 was presented as teaching the key "ignore" limitation. R1-072197 is a 3GPP working group document that proposes solutions for transmitting Timing Advance (TA) commands "only when needed." It describes a scenario where a UE, already in a synchronous state, might erroneously receive a second TA command. In this exact situation, R1-072197 teaches that "the UE can ignore the new TA command" to avoid unnecessary "UL Overhead and System Issues." This was argued to be a direct and explicit teaching of ignoring timing information when in a synchronous status.
    • Motivation to Combine: Both TS 36.300 and R1-072197 are 3GPP documents directed to the same subject matter: E-UTRA uplink operation. A POSITA working with the TS 36.300 standard would have been highly motivated to consult and implement proposals from contemporaneous contribution documents like R1-072197, which were created specifically to refine and solve problems within that standard.
    • Expectation of Success: A POSITA would have had a very high expectation of success, as R1-072197 was a technical proposal designed for direct integration into the system architecture described by TS 36.300.

4. Key Claim Construction Positions

  • "an uplink [a]synchronous status" (Claims 3, 4, and 7): Petitioner proposed this term be construed to mean "status indicating a state of [a]synchrony between a mobile station device and a base station device." Petitioner argued this construction is supported by the patent’s specification and extrinsic dictionaries. The petition asserted that its unpatentability arguments succeed under this construction as well as under the Patent Owner’s substantially similar construction proposed in related litigation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 3, 4, and 7 of Patent 8,885,583 as unpatentable.