PTAB

IPR2017-01475

Samsung Electronics Co Ltd v. Huawei Technologies Co Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method, Terminal, and System for Cell Reselection
  • Brief Description: The ’003 patent relates to a method for a mobile terminal to perform cell reselection in a wireless network with multiple radio access technologies (RATs). The patent purports to reduce power consumption by having a terminal obtain a dedicated priority list and an associated valid time from an LTE system and then use that information to perform cell reselection even when camped on a non-LTE system cell.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over R2-075161 in view of R2-080338

  • Prior Art Relied Upon: R2-075161 (3GPP TSG RAN WG2 #60 Document) and R2-080338 (3GPP TSG RAN WG2 #60bis Document).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that R2-075161 taught the core mechanism of the challenged claims: an LTE network providing a UE-specific (dedicated) priority list for inter-RAT cell reselection, including an optional expiry timer that dictates how long the dedicated list is valid. After the timer expires, the UE reverts to a normal or public reselection procedure. However, R2-075161 did not explicitly state that this LTE-provided list should be used when the UE is already camped on a non-LTE cell. Petitioner asserted that R2-080338 supplied this teaching by describing a scenario where a UE receives priority parameters via dedicated signaling from an LTE network and "remembers" them to perform cell reselection when subsequently camped on a non-LTE network (e.g., UMTS or GSM) that does not broadcast its own priority information. The combination of R2-075161’s priority list mechanism with R2-080338’s specific use-case scenario allegedly rendered the claims obvious.
    • Motivation to Combine: A POSITA would combine these references because they were sequential public contributions to the 3GPP standards body from consecutive working group meetings (Meeting #60 and #60bis). Both documents addressed the same technical problem of defining idle mode mobility and inter-RAT cell reselection for the developing LTE standard. Petitioner contended that a person skilled in the art developing this standard would have naturally reviewed and combined the teachings of these related, contemporaneous proposals to arrive at a complete solution.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination merely involved applying a known priority-based reselection method (from R2-075161) in a clearly defined and anticipated operational scenario (from R2-080338), which was a predictable design choice in developing a robust mobile communication standard.

Ground 2: Claims 1-20 are obvious over R2-075161 and R2-080338, in further view of Eerolainen

  • Prior Art Relied Upon: R2-075161 (3GPP TSG RAN WG2 #60 Document), R2-080338 (3GPP TSG RAN WG2 #60bis Document), and Eerolainen (Application # 2008/0176565).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1, adding Eerolainen to further support the obviousness of all claims, particularly the apparatus claims 15-20. Petitioner argued that Eerolainen, which relates to providing a RAT priority list for multi-RAT mobile devices, described a conventional hardware architecture for implementing the very methods discussed in the 3GPP documents. Eerolainen disclosed a mobile terminal (an apparatus) comprising a processor, a non-transitory memory, and executable instructions for performing cell reselection based on a multi-RAT priority list received from a network, and also described the use of a timer associated with the priority list. This hardware disclosure was argued to map directly onto the limitations of apparatus claims 15-20.
    • Motivation to Combine: A POSITA would be motivated to implement the cell reselection methods proposed in the R2-075161 and R2-080338 standardization documents using the conventional hardware components and architecture described in Eerolainen. Eerolainen explicitly related its teachings to the ongoing LTE standardization efforts and described the precise type of hardware (e.g., UE with processor and memory) known to be used in LTE and non-LTE cellular systems, making it a natural choice for implementing the combined method of Ground 1.
    • Expectation of Success: Implementing the software-based cell reselection method from the 3GPP documents on the standard hardware platform described in Eerolainen would have been a routine and predictable task for a POSITA with a clear expectation of success.

4. Key Claim Construction Positions

  • “Camps/Camping” (Claims 1, 4, 15, 19): For the purpose of the petition, Petitioner adopted the Patent Owner's proposed construction from a related district court litigation, which defined the term to mean “is in a selected non-LTE cell.”

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 8,996,003 as unpatentable.