PTAB

IPR2018-01261

Intel Corp v. Qualcomm Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Conserving Power in a Mobile Device
  • Brief Description: The ’490 patent discloses systems for conserving power in mobile devices by managing communications between a modem processor and an application processor. The invention focuses on reducing the number of power state transitions of an interconnectivity bus by coordinating uplink and downlink data transfers into a single active period.

3. Grounds for Unpatentability

Ground 1: Obviousness over Heinrich in view of Balasubramanian - Claim 31 is obvious over Heinrich in view of Balasubramanian.

  • Prior Art Relied Upon: Heinrich (Patent 9,329,671) and Balasubramanian (Patent 8,160,000).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Heinrich disclosed the foundational elements of claim 31, and Balasubramanian supplied the specific "pull" data transfer mechanism that Heinrich lacked. Heinrich was asserted to teach a mobile device with an application processor and a modem processor (termed a "baseband processor") that communicate over a bus. To save power, Heinrich’s system aggregates non-real-time data at the modem processor and transmits it in a group upon the expiration of a "lazy timer," reducing the number of transitions from a sleep state to an active state. Heinrich explicitly taught that these same power-saving techniques could be used for data transfers in the opposite direction (from the application processor to the modem processor).

      Petitioner contended that while Heinrich disclosed data buffering and consolidated "push" transmissions, it did not teach the claimed limitation where the application processor holds data until the modem processor pulls data from it. This specific "pull" mechanism, where the recipient processor initiates the data transfer by request, was allegedly disclosed by Balasubramanian. Balasubramanian taught a power-saving system for two processing nodes (a transceiver and a network interface) that consolidates data transfers into a single "wake state." Critically, Balasubramanian disclosed an embodiment where, after the first node pushes its data, it can then "send a message to the network interface 112 requesting transmission of all queued packets," thereby "pulling" the data from the second node. Petitioner argued this pull occurs during the same single wake state, satisfying the final limitation of claim 31 that the pull occurs before the bus transitions back to a low power state.

    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine Heinrich and Balasubramanian for several reasons. First, both references address the same problem—reducing power consumption from processor/bus state transitions in mobile communication systems—using the same fundamental approach of grouping data transfers. Second, Balasubramanian's "pull" mechanism would be a natural and advantageous modification to Heinrich's system. Heinrich taught that an opportune time to send aggregated data is when the receiving processor is already awake; Balasubramanian’s method of pushing data and then immediately pulling data ensures both processors are active, fitting this principle perfectly. A POSITA would have recognized that applying Balasubramanian’s efficient, single-wake-state push/pull sequence to Heinrich’s architecture would further optimize the power-saving goals already central to Heinrich’s disclosure.

    • Expectation of Success: Petitioner argued that a POSITA would have had a high expectation of success. "Push" and "pull" data transfer protocols were well-known and predictable solutions for managing data flow between processors. Implementing Balasubramanian's "pull" scheme within Heinrich's established inter-processor communication framework would have involved routine scheduling adjustments, not fundamental technical hurdles, making the successful integration of the teachings predictable.

4. Key Claim Construction Positions

  • "pull": Petitioner proposed that the term "pull" should be construed to mean "receiving data in response to a request for the data." This construction was argued to be critical for distinguishing the claimed invention from prior art "push" systems, where the sending device initiates transmission without a request from the recipient. The argument for obviousness relied on Balasubramanian teaching this specific request-based transfer, which was absent from the primary reference, Heinrich.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 31 of Patent 9,535,490 as unpatentable under 35 U.S.C. §103.