IPR2018-01016
Ruckus Wireless Inc v. XR Communications LLC
1. Case Identification
- Case #: IPR2018-01016
- Patent #: 6,611,231
- Filed: May 3, 2018
- Petitioner(s): Ruckus Wireless, Inc.; ARRIS Solutions, Inc.; ARRIS Enterprises, LLC; Netgear, Inc.; and Belkin International, Inc.
- Patent Owner(s): XR Communications, LLC
- Challenged Claims: 1-9, 12
2. Patent Overview
- Title: Adaptive Antenna Array Steering for Wireless Networks
- Brief Description: The ’231 patent addresses limitations in conventional wireless networks, such as interference from omnidirectional antennas, by disclosing an apparatus for use in a wireless routing network. The system employs an adaptive antenna and uses routing information to control the transmission of multi-beam electromagnetic signals with selectively placed peaks and nulls to improve communication performance and reduce interference.
3. Grounds for Unpatentability
Ground 1: Claims 1-9 and 12 are obvious over Agee
- Prior Art Relied Upon: Agee (Patent 6,359,923).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the single prior art reference, Agee, discloses every limitation of the challenged claims. Agee teaches a telecommunications system that makes efficient use of spectral bandwidth through adaptive antennas and beamforming. Petitioner provided a detailed mapping for each limitation of independent claim 1.
- Agee was said to disclose an "adaptive antenna" (limitation 1[a]) through its description of "adaptive antenna arrays" used to steer energy.
- A "transmitter operatively coupled" to the antenna (1[b]) and a "receiver operatively coupled" (1[c]) were allegedly shown in Agee’s block diagram of a base station (Fig. 73), which includes distinct transmit and receive paths connected to the antenna via a switch.
- Agee’s "control logic" (1[d]) was mapped to its disclosure of applying "weight values" to perform beamforming and "null steering." Petitioner asserted these weight values constitute "routing information" used to selectively place transmission peaks toward desired users and nulls toward interferers.
- Finally, Agee's computational flowchart (Fig. 85A) was argued to disclose a "search receiver logic" (1[e]) that updates these weight values based on cross-correlated signal information derived from the receiver, thus updating the routing information.
- Petitioner contended that Agee's teachings also rendered the dependent claims obvious. For claim 2, Agee's use of "pilot tones" during a "traffic establishment phase" was argued to function as a "synchronization packet" for cross-correlation. For claim 3, Agee explicitly illustrates an antenna array with a "plurality of antenna elements." For claim 4, Petitioner asserted that Agee’s time-division duplexing (TDD) system uses substantially the same calculated weights to control both transmission and reception patterns, thereby selectively controlling reception. Claims 7 and 8 were allegedly met by Agee’s disclosure of storing these weights in Random Access Memory (RAM), which functions as the claimed "routing table." Claim 12 was met because the calculated weights function as a "transmission constraint" derived from received signals.
- Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference.
- Expectation of Success (for §103 grounds): Not applicable as this ground relies on a single reference.
- Prior Art Mapping: Petitioner argued that the single prior art reference, Agee, discloses every limitation of the challenged claims. Agee teaches a telecommunications system that makes efficient use of spectral bandwidth through adaptive antennas and beamforming. Petitioner provided a detailed mapping for each limitation of independent claim 1.
4. Key Claim Construction Positions
Petitioner submitted that the following constructions were necessary to provide clarity for considering the patentability of the challenged claims under the broadest reasonable interpretation standard.
"Routing information" (claims 1, 4-9, 12): Petitioner proposed this term be construed as "information used to direct outgoing multibeam electromagnetic signals." This broad construction is central to Petitioner's argument that the beamforming "weight values" disclosed in Agee constitute the claimed routing information.
"synchronization packet" (claim 2): Petitioner proposed this term means "known sequence used to estimate channel information." This construction allows Agee's disclosure of using "pilot tones" transmitted during a traffic establishment phase to meet the claim limitation.
"Routing table" (claims 7, 8): Petitioner proposed this term be construed as "a storage mechanism or data structure containing routing information such as weighting values." This construction allows Agee's disclosure of storing calculated weights in a spread weight RAM (a "storage mechanism") to qualify as a "routing table."
"Transmission Constraint" (claim 12): Petitioner proposed this term be construed as "routing information relating to certain rules for transmissions such as information about discovered and/or historical transmission/reception performance." This enables the calculated beamforming weights in Agee, which dictate transmission patterns based on received signals, to be considered a constraint.
5. Arguments Regarding Discretionary Denial
- Petitioner argued that discretionary denial under 35 U.S.C. §§ 314 and 325 would be inappropriate. It asserted that this was its first petition filed against the ’231 patent. Petitioner further argued that the primary prior art, Agee, was not cumulative to art previously considered by the USPTO during prosecution or to art cited in other IPRs filed by different parties against the same patent.
6. Relief Requested
- Petitioner requested institution of an inter partes review and cancellation of claims 1-9 and 12 of the ’231 patent as unpatentable.