PTAB

IPR2017-01974

Huawei Technologies Co Ltd v. Samsung Electronics Co Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Discontinuous Reception of Connected Terminal in a Mobile Communication System
  • Brief Description: The ’588 patent relates to a power-saving method for mobile devices known as Discontinuous Reception (DRX). The technology uses a first timer and a second timer to manage the length of an "active time period," allowing a User Equipment (UE) to switch between an active mode for receiving data and a dormant or sleep mode to conserve battery power.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1, 4, 5, 7, 10, and 11 are anticipated by Gollnick under 35 U.S.C. §102

  • Prior Art Relied Upon: Gollnick (Application # 2004/0073933).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gollnick discloses every limitation of the challenged claims. Gollnick teaches a power-saving technique for a roaming terminal that uses two timers to control active and dormant states. Petitioner mapped Gollnick's "one-second timer," which is started to monitor for control data, to the claimed "first timer." When a transmission is received (e.g., a POLL or RFP frame, which Petitioner asserted is "control data"), Gollnick starts or restarts a "ten-second timer," which was mapped to the claimed "second timer" to keep the terminal's radio active. This process of starting a first timer to monitor for data, and then starting or restarting a second timer upon data receipt, was argued to directly read on the independent claims.

Ground 2: Obviousness - Claims 1, 4-7, and 10-12 are obvious over Gollnick in view of Harris

  • Prior Art Relied Upon: Gollnick (Application # 2004/0073933) and Harris (Patent 6,871,074).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Gollnick teaches the core two-timer DRX method. However, to the extent Gollnick's system might not be considered a modern "mobile communication system," Harris explicitly discloses implementing DRX operations within cellular systems like UMTS or CDMA2000. Harris further teaches the use of a "shared control channel" and "Physical Downlink shared control channel" common in such systems.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Gollnick's power-saving scheme with the cellular environment of Harris to improve efficiency and reliability. Gollnick itself suggested its invention could be an upgrade to existing systems. A POSITA would have recognized that modern cellular networks, as described in Harris, were a superior and well-established infrastructure for implementing the DRX functionality taught by Gollnick, making the combination a predictable and logical step.
    • Expectation of Success: Petitioner argued there was a high expectation of success, as the combination involved applying a known power-saving technique (Gollnick) to a known and more efficient communication environment (Harris), with each element performing its established function.

Ground 3: Obviousness - Claims 2-3, 5, 8-9, and 11 are obvious over Gollnick in view of Muqattash (with or without other references)

  • Prior Art Relied Upon: Gollnick (Application # 2004/0073933) and Muqattash (Application # 2007/0160027), optionally combined with Harris, TS 25.321, and Libes.

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground specifically targeted dependent claims requiring the UE to receive timer durations and starting information from a "Node B" (a base station). While Gollnick's timers have fixed durations, Muqattash teaches a "dynamic wakeup period" where a base station sends recommendations for hibernation and active periods to a mobile device. This allows the device's wakeup times to be tailored to anticipated network traffic patterns. Muqattash explicitly discloses this information coming from a source node in a cellular environment, which a POSITA would understand to be a Node B.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the dynamic scheduling from Muqattash into the Gollnick system to further enhance its power-saving capabilities. By allowing a base station, which has more information about network traffic, to control the timer durations, the DRX operation becomes more flexible and efficient than one with fixed timers. This would have been a predictable improvement to optimize the system's performance.
    • Expectation of Success: The combination was presented as a straightforward integration of a known dynamic scheduling feature into a known DRX system to achieve the predictable benefit of improved power management.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, primarily building upon Gollnick. These grounds incorporated references like TS 25.321 to disclose specific channel structures (HS-SCCH) and the use of a "New Data Indicator"; Libes to teach conventional software implementation of timers in separate structures for code efficiency; and R2-060591 to show the use of explicit network commands to direct a UE into DRX mode.

4. Key Claim Construction Positions

  • "Discontinuous Reception (DRX) Operation": Petitioner proposed this term be construed as its conventional meaning: "an operation where a UE wakes up at a predetermined time, monitors a predetermined channel for a predetermined time period, and then enters again into a sleep mode in an idle state." This broad construction was intended to align the claims with the fundamental power-saving techniques disclosed in the prior art.
  • "timer": Petitioner argued for a broad construction of "a mechanism capable of determining the passage of a particular amount of time," not limited to a specific hardware or software implementation. This construction allows the functional descriptions of timers in Gollnick (e.g., a "one-second timer") to satisfy the claim limitation without requiring disclosure of a specific software structure, which Libes was offered to supply if needed.
  • "Control Channel": Petitioner proposed construing this term as "a channel that carries control information." This construction avoids limiting the channel to carrying only control information, consistent with specifications suggesting user data could also be sent on such a channel.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’588 patent as unpatentable.