PTAB

IPR2017-01475

Samsung Electronics Co., Ltd. v. Huawei Technologies Co., Ltd.

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1. Case Identification

2. Patent Overview

  • Title: Method, Terminal, and System for Cell Reselection
  • Brief Description: The ’003 patent discloses a method for a mobile device (User Equipment or UE) to perform cell reselection when moving between different wireless networks. The patent's purported invention is a power-saving method where a UE, after moving from a Long Term Evolution (LTE) network to a non-LTE network, uses a dedicated priority list previously received from the LTE network to select a new cell, rather than receiving a new list from the non-LTE network.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Contributions - Claims 1-20 are obvious over R2-075161 in view of R2-080338.

  • Prior Art Relied Upon: R2-075161 (a 3GPP technical contribution titled "Inter-frequency/RAT idle mode mobility control") and R2-080338 (a 3GPP technical contribution titled "Reselection scenarios for multi-RAT terminals in Rel-8").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these two references teaches every limitation of the challenged claims. Independent claim 1 requires a terminal to (1) receive a dedicated priority list from an LTE system and (2) later use that list to perform cell reselection while camped on a non-LTE system before a valid time expires. R2-075161, a 3GPP standards proposal, was argued to teach the first element by disclosing that an LTE network (e.g., an eNB) provides a UE with "UE specific control information," which is a dedicated priority list of frequencies and Radio Access Technologies (RATs). R2-075161 also disclosed that this list could be sent in a dedicated Radio Resource Control (RRC) release message and could be associated with an expiry timer. R2-080338, a subsequent 3GPP proposal, was argued to explicitly teach the second element by describing a scenario where a UE receives priority information from an LTE network and "remembers" it to perform cell reselection after it has moved to and is camping on a non-LTE network (e.g., UMTS or GSM). Petitioner contended that R2-075161 also teaches the limitations of various dependent claims, such as using a public priority list (via BCCH) after the dedicated list expires and deleting the list upon expiration.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because both were sequential contributions to the 3GPP standards body, addressing the same technical issue of inter-RAT cell reselection for the developing LTE standard. A POSITA would have looked to these related proposals from consecutive meetings to understand and implement a complete solution for priority-based cell reselection.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the teachings, as it involved applying a known procedure (using stored priorities, from R2-080338) to a specific system configuration (the priority list mechanism from R2-075161) within the predictable context of 3GPP standards development.

Ground 2: Obviousness over 3GPP Contributions and Eerolainen - Claims 1-20 are obvious over R2-075161 and R2-080338 in further view of Eerolainen.

  • Prior Art Relied Upon: R2-075161, R2-080338, and Eerolainen (Application # 2008/0176565).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that the method taught by the combination of R2-075161 and R2-080338 would have been obviously implemented on the hardware described in Eerolainen. Eerolainen, which also relates to cell reselection for multi-RAT devices in an LTE context, explicitly discloses the apparatus required by the claims. Specifically, it describes a UE (an "apparatus") comprising a processor (10A) and a non-transitory storage medium (memory 10B) containing executable instructions (program 10C) that cause the apparatus to perform cell reselection using a multi-RAT priority list. Petitioner argued that Eerolainen provides the concrete hardware basis for the "non-transitory computer readable medium" recited in claim 1 and the "apparatus" elements recited in independent claim 15.
    • Motivation to Combine: All three references relate to inter-RAT cell reselection for LTE systems. A POSITA seeking to implement the cell reselection method proposed in the 3GPP documents (R2-075161 and R2-080338) would have been motivated to use the conventional hardware architecture for a UE as described in Eerolainen. Eerolainen was published by Nokia, a major 3GPP contributor and the author of R2-080338, further suggesting that these technologies were part of the same developmental context.
    • Expectation of Success: Implementing a known software method (from the 3GPP references) on a known, suitable hardware platform (from Eerolainen) would have been a straightforward task for a POSITA with a clear expectation of success.

4. Key Claim Construction Positions

  • Petitioner adopted, for the purposes of the petition only, a construction for the term "camps/camping on a cell of a non-LTE system" (claims 1, 4, 15, 19) that was proposed by the Patent Owner in co-pending district court litigation.
  • The adopted construction is: "is in a selected non-LTE cell." This construction was used to frame the arguments that the prior art met the claim limitations.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 of the ’003 patent as unpatentable.