PTAB

IPR2017-01986

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

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1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Transmitting and Receiving Control Channels By Restricting A Set of the Control Channels in a Wireless Communication System
  • Brief Description: The ’195 patent discloses a technique for reducing the number of control channels a wireless terminal must monitor to receive scheduling grants from a base station. The invention is described in the context of the Long Term Evolution (LTE) standard, where a terminal determines a specific subset of all available control channel candidates to monitor, based on parameters like a terminal identifier.

3. Grounds for Unpatentability

Ground 1: Claims 9-12, 14-15, 25-28, and 30-31 are obvious over Patabandi in view of R1-071611.

  • Prior Art Relied Upon: Patabandi (Patent 7,912,471) and R1-071611 (a 3GPP Contribution).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Patabandi teaches the core concept of the ’195 patent: a method for a terminal (UE) in an LTE system to receive control information by monitoring a restricted subset of available control channels. Patabandi disclosed that this subset can be determined based on a UE identifier, a time parameter, and/or a random element. However, Petitioner contended Patabandi does not explicitly detail the structure of the control channels. The R1-071611 reference, a 3GPP standards document summarizing industry consensus for LTE, allegedly supplies this missing detail by teaching that control channels are formed "in a structured way by aggregating 1, 2, 4, or 8 control channel elements (CCEs)" transmitted over Orthogonal Frequency Division Multiplexing (OFDM) symbols.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Patabandi's general architecture for restricting control channel monitoring with the specific, industry-agreed implementation details found in R1-071611. The combination was presented as a predictable implementation of a general system (Patabandi) with a known, standardized component (the CCE aggregation structure from R1-071611) to solve the known problem of reducing monitoring complexity.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because R1-071611 represented an industry-vetted solution for structuring control channels, making its integration with Patabandi's system straightforward.

Ground 2: Claims 9-12, 14-15, 25-28, and 30-31 are obvious over Patabandi in view of R1-071216.

  • Prior Art Relied Upon: Patabandi (Patent 7,912,471) and R1-071216 (a 3GPP Contribution).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative combination, again using Patabandi as the primary reference for restricting the monitored channel set based on a UE identifier. The secondary reference, R1-071216, is another 3GPP proposal from the same time period as R1-071611. It similarly taught forming control channels by aggregating CCEs, providing an illustrative example using 1, 2, or 3 CCEs. Petitioner argued that even though R1-071216 does not explicitly list "1, 2, 4, or 8" CCEs, it suggests a structured aggregation that made the claimed numbers obvious, especially since aggregating by powers of two was a known technique for efficient resource allocation.
    • Motivation to Combine: The motivation was identical to Ground 1: a POSITA implementing Patabandi's system would look to contemporary 3GPP proposals like R1-071216 for guidance on structuring control channels. Petitioner asserted this ground was not redundant because the Patent Owner might challenge the prior art status of one 3GPP document but not the other.
    • Expectation of Success: A POSITA would expect success for the same reasons as in Ground 1, as R1-071216 provided a concrete, proposed implementation for CCE aggregation.

Ground 3: Claims 14-15 and 30-31 are obvious over Patabandi in view of any of R1-071611, R1-071216, or R1-071223, and further in view of Ghosh.

  • Prior Art Relied Upon: Patabandi (Patent 7,912,471), any one of the 3GPP contributions (R1-071611, R1-071216, or R1-071223), and Ghosh (Application # 2005/0250497).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground specifically targeted dependent claims 14, 15, 30, and 31, which add the limitation of using a "random number generation function" that takes the terminal ID and/or subframe transmission time as variables. While Patabandi taught using a terminal ID and time parameters to derive a channel set, Ghosh allegedly supplied the explicit teaching of using a hashing function for this purpose. Petitioner argued that a hashing function is a type of random number generation function and that Ghosh taught using it with a UE identifier and transmission time inputs to allocate resources and avoid collisions.
    • Motivation to Combine: A POSITA would be motivated to combine these references because Patabandi identified the problem of potential collisions when allocating resources, and Ghosh provided a known solution—using a hashing function—to avoid such collisions. Applying Ghosh's specific hashing technique to Patabandi's system was argued to be a predictable combination of known elements to solve a known problem.
    • Expectation of Success: Success was expected because using hashing functions to allocate resources based on UE and time inputs was a well-understood technique, particularly from the predecessor WCDMA standard.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge over Patabandi in view of 3GPP contribution R1-071223, which relied on the same rationale as the grounds involving R1-071611 and R1-071216.

4. Key Claim Construction Positions

  • "a set of control channel candidates": Petitioner argued that, for the purposes of the IPR, this term should be given its broadest reasonable interpretation to include any set of control channels transmittable by a base station, or alternatively that it needs no construction. This counters a potentially narrower construction asserted by the Patent Owner in co-pending litigation that the set must be "necessarily less than all transmittable control channels."
  • "each control channel candidate ... consists of one of one, two, four, and eight control channel element (CCEs)": Petitioner argued that its obviousness grounds succeed regardless of whether this phrase requires only the listed CCE aggregation sizes (1, 2, 4, 8) or if it is also satisfied when other aggregation sizes (e.g., 3) are used, an interpretation advanced by the Patent Owner in litigation. Petitioner contended the prior art teaches the claimed aggregation sizes explicitly or renders them obvious.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 9-12, 14-15, 25-28, and 30-31 of Patent 8,315,195 as unpatentable.