PTAB

IPR2017-01483

Samsung Electronics Co Ltd v. Huawei Technologies Co Ltd

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Accessing Legacy Networks through Temporary ID of Evolved Network
  • Brief Description: The ’166 patent discloses methods for a mobile device (User Equipment or UE) to access a legacy 2G/3G network after moving from an evolved (LTE) network. The method involves embedding identifying information of the prior LTE network node (MME) into a temporary identity (P-TMSI) used by the legacy network to ensure seamless context retrieval and service continuity.

3. Grounds for Unpatentability

Ground 1: Obviousness over TS 23.236 and S2-073255 - Claims 1-3, 5, 12-14, and 16

  • Prior Art Relied Upon: TS 23.236 (a 3GPP technical specification) and S2-073255 (a 3GPP temporary document).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of TS 23.236 and S2-073255 renders the challenged claims obvious. TS 23.236 taught the foundational procedure in 2G/3G networks where a UE sends an access message containing a temporary identity (P-TMSI) to a Radio Access Network (RAN) node. This P-TMSI includes a Network Resource Identifier (NRI) that identifies the UE’s current core network node (SGSN), enabling the RAN node to route the UE correctly. S2-073255, which discusses interoperability between LTE and legacy networks, explicitly proposed adapting this known procedure for a UE moving from an LTE network. It taught that MME identifying information (MME-id) from the LTE network's temporary ID (S-TMSI) should be incorporated into the legacy P-TMSI, specifically suggesting to "Reassign... part of P-TMSI as the MME id."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve seamless interoperability between LTE and legacy networks, a well-understood goal at the time. The references are directly related, as both are 3GPP documents addressing network architecture and mobility. The combination represents a simple substitution of one known identifier (the NRI for an SGSN) with its known LTE analog (the MME-id for an MME) to perform the exact same function: identifying the previous core network node to facilitate handover.
    • Expectation of Success: A POSITA would have had a high expectation of success because the legacy RAN node was already configured to parse an identifier from that specific location within the P-TMSI. Substituting the MME-id for the NRI would not require any significant or unexpected change in functionality, thus yielding predictable results.

Ground 2: Obviousness over TS 23.236, S2-073255, and TR 23.882 - Claims 4 and 15

  • Prior Art Relied Upon: TS 23.236, S2-073255, and TR 23.882 (a 3GPP technical report).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on Ground 1 to specifically address claims 4 and 15, which require the legacy network's SGSN to be a "combined MME/SGSN" where its NRI is identical to its MME-id. The primary combination of TS 23.236 and S2-073255 teaches using the MME-id in place of the NRI. Petitioner introduced TR 23.882 to demonstrate that combined MME/SGSN nodes were well-known in the art at the time of the invention. TR 23.882 explicitly illustrates an architecture where an MME is "co-localised with 2G/3G SGSN" to reduce signaling and improve coordination.
    • Motivation to Combine: A POSITA would be motivated to apply the identifier-swapping technique taught by the primary combination to the well-known and efficient "combined MME/SGSN" architecture disclosed in TR 23.882. The motivation is to improve interworking between network generations, a goal expressly discussed in TR 23.882 in the context of combined nodes. Implementing the method in this known architecture would have been an obvious design choice to enhance network efficiency.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Shaheen (Application # 2007/0248064). These grounds argued that to the extent the primary combination did not inherently disclose apparatus elements like a transmitter and receiver, Shaheen provided express disclosure of these conventional components in a mobile device, rendering the apparatus claims obvious.

4. Key Claim Construction Positions

  • Petitioner argued that the term "Mobility Management Entity (MME) information adding module," recited in apparatus claims 12, 13, and 16, should be construed as a means-plus-function limitation under 35 U.S.C. §112, ¶6.
  • Petitioner contended that the phrase lacks an understood meaning in the art and that the ’166 patent specification fails to disclose corresponding structure for performing the claimed functions of "adding" MME information. The only disclosure is a generic block diagram.
  • Based on this, Petitioner asserted that these claims are indefinite but proceeded with the IPR by interpreting the corresponding structure as software configured to perform the recited functions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 12-16 of Patent 8,483,166 as unpatentable.