PTAB

IPR2018-00571

CommScope Technologies LLC v. Dali Wireless Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Transporting Wireless Communications
  • Brief Description: The ’473 patent describes a Distributed Antenna System (DAS) for dynamically allocating wireless communication resources. The system comprises a host unit and multiple remote units, where the host unit is software-configurable to route different subsets of downlink signals to different remote units to manage network capacity efficiently.

3. Grounds for Unpatentability

Ground 1: Anticipation over Sabat - Claims 6, 7, 11-14, 16, and 18 are anticipated by Sabat.

  • Prior Art Relied Upon: Sabat (Application # 2009/0180426).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sabat, which was not considered during prosecution, discloses every limitation of the independent claims. Sabat’s DAS hub (e.g., hub 510 in Fig. 6) functions as the claimed host unit, and its remote digital radios (504) are the claimed remote units. The core limitation—a host "configurable to transmit" different signal subsets to different remotes—was allegedly met by Sabat’s disclosure of a fully programmable electronic switch. This switch allows any remote unit to be connected to any base station sector, thereby enabling the hub to route different subsets of signals to different remote units.
    • Key Aspects: Petitioner contended that Sabat’s disclosure of using the Common Public Radio Interface (CPRI) standard inherently teaches the “packetizing” required by dependent claims 9, 10, 14, and 16, as CPRI defines a protocol for grouping data into frames for network communication.

Ground 2: Obviousness over Sabat and Daisy-Chain References - Claims 15, 17, and 19-21 are obvious over Sabat in view of various "Daisy-Chain References."

  • Prior Art Relied Upon: Sabat (’426 application) in view of any of CPRI (a technical standard), Wu (Application # 2010/0128676), Stratford (Patent 6,785,558), Bauman (Patent 8,958,789), Kummetz (Patent 8,346,091), or Schwartz 2 (Patent 6,801,767).
  • Core Argument for this Ground:
    • Prior Art Mapping: Sabat was asserted to teach a DAS with direct connections between the host and remote units. The challenged dependent claims (15, 17, 19-21) recite features characteristic of a daisy-chain topology, such as indirect connections or interfaces for coupling one remote to another. The secondary references were cited to demonstrate that daisy-chaining was a well-known, conventional topology for DAS remote units prior to the ’473 patent’s filing date.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Sabat's system with a daisy-chain topology for the known and predictable benefits of reduced cabling costs, simplified installation, and improved system scalability and flexibility. These benefits were particularly relevant for DAS deployments in environments like tunnels or large buildings.
    • Expectation of Success: The combination was argued to be a predictable implementation of known design choices, as daisy-chaining was a familiar technique that could be implemented using various well-understood methods.

Ground 3: Anticipation over Oh - Claims 6, 7, 11-13, and 19 are anticipated by Oh.

  • Prior Art Relied Upon: Oh (Patent 7,286,507).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Oh, also not considered during prosecution, discloses all limitations of the independent claims. Oh’s DAS hub (26) is the host unit, and its DAS antenna units are the remotes. The key "configurable" limitation was allegedly met by Oh’s use of "mapping data" (shown in Fig. 2) that correlates specific RAN coverage segments (subsets of signals) to the IP addresses of different remote units. Petitioner asserted this mapping table is inherently configurable, allowing it to route different signal subsets to different remotes as needed, for instance, based on "event-scheduling data" like changing user density during a lunch hour.
    • Key Aspects: Oh explicitly discloses an "indirect connection" through a packet-switched network, which Petitioner argued anticipates claim 19.

Ground 4: Obviousness over Oh and Feder - Claim 18 is obvious over Oh in view of Feder.

  • Prior Art Relied Upon: Oh (’507 patent) in view of Feder (Application # 2005/0157675).

  • Core Argument for this Ground:

    • Prior Art Mapping: Oh discloses a DAS where the host unit connects to remote units indirectly via a packet-switched network. Claim 18 requires a direct connection. Feder, which describes a similar packet-based DAS, was cited for its disclosure of a host unit (a "Radio Distributor/Aggregator" or RDA) that uses a plurality of ports to establish direct connections to its remote units.
    • Motivation to Combine: A POSITA would have been motivated to modify Oh's system to incorporate Feder's direct connection capability. Both systems are packet-based DASs for similar applications (e.g., in-building distribution), making the combination straightforward. The motivation would be to gain deployment flexibility and reduce costs in scenarios where a direct connection from the host hub to a remote unit is more efficient than connecting through a separate network node.
    • Expectation of Success: The combination would yield a predictable result. Petitioner argued that modifying Oh’s hub to include the direct-port functionality of Feder’s switch-like RDA was a simple extension of Oh’s own teaching, as Oh already discloses the necessary building blocks (e.g., a mapping table for routing).

  • Additional Grounds: Petitioner asserted additional challenges, including that Wu (’676 application) anticipates claims 6-8, 11-13, and 18-21. Further obviousness grounds were based on Wu in light of Sabat, and on Oh in view of Sabat and/or other references, relying on similar theories of combining known elements for predictable results.

4. Key Claim Construction Positions

  • "packetizing": Petitioner proposed the broadest reasonable construction of this term is "making units of data which are sent over a network." This construction was based on dictionary definitions and was argued to be important for demonstrating how prior art references that use standard communication protocols (like CPRI) meet the limitations of dependent claims requiring packetization.

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner's core technical contention, woven throughout its arguments, was that the challenged claims are impermissibly broad. It argued the claims use functional language like "capable of" and "configurable to" to cover any system that can perform a function, without being limited to the specific software-programmable DUC/DDC structures described as the invention in the ’473 patent's specification. This broad functional claiming, Petitioner asserted, caused the claims to read on numerous prior art systems that achieve similar results through different, but well-known, means like programmable switches or mapping tables.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 6-21 of the ’473 patent as unpatentable under 35 U.S.C. §102 and/or §103.