PTAB

IPR2018-01330

Intel Corp v. Qualcomm Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Power Management for Transmitting Multiple Carrier Aggregated Signals
  • Brief Description: The ’675 patent discloses a system for improving power efficiency when transmitting multiple carrier aggregated radio frequency (RF) signals simultaneously. The patented method uses a single power amplifier and a single power tracking supply generator that creates a single power tracking signal to dynamically adjust the supply voltage for the amplifier.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chen, Wang, and Choi - Claims 28-30 are obvious over Chen in view of Wang and Choi.

  • Prior Art Relied Upon: Chen (a Jan. 2012 article in Microwave and Optical Technology Letters), Wang (an Apr. 2005 article in IEEE Transactions on Microwave Theory and Techniques), and Choi (a May 2010 paper in IEEE MTT-S International Microwave Symposium Digest).
  • Core Argument for this Ground: Petitioner asserted that Chen disclosed the fundamental architecture of the ’675 patent. The remaining claim limitations, Petitioner argued, were well-known elements that a person of ordinary skill in the art (POSA) would have been motivated to incorporate from Wang and Choi to achieve predictable improvements in performance and functionality.
    • Prior Art Mapping:
      • Chen was argued to teach the core system: a single power amplifier (PA) and single power supply generator for transmitting multiple signals (dual-band) simultaneously using envelope tracking. Petitioner contended that Chen's architecture, comprising "Envelope Detectors" that detect the envelope of each signal and an "Envelope Combiner" that sums them, forms a power tracker that generates a single power tracking signal. Chen's "Envelope Amplifier" was identified as the power supply generator.
      • Wang was asserted to supply the teaching of processing signals using in-phase (I) and quadrature (Q) components, a limitation not expressly detailed in Chen. Wang described an envelope-tracking PA system for Orthogonal Frequency Division Multiplexing (OFDM) signals, which explicitly uses I and Q components of a complex baseband signal to calculate signal amplitude (A = (I² + Q²)¹/²).
      • Choi was used to provide a specific, detailed structure for the power supply generator, which is only shown as a generic "Envelope Amplifier" in Chen. Choi described a "hybrid switching amplifier" (HSA) containing a linear amplifier for high-frequency response, a high-efficiency switching buck converter, and a boost converter for robustness against battery depletion. Petitioner argued this structure is identical to the power supply generator disclosed in the ’675 patent.
    • Motivation to Combine (for §103 grounds): Petitioner argued a POSA would have strong motivation to combine the references. A POSA would combine Chen and Wang because both address envelope tracking for wide-bandwidth signals. Since Chen's system is targeted at LTE-Advanced applications which use OFDM, and Wang explicitly teaches an ET system for OFDM using standard I/Q processing, it would have been obvious to implement Chen's system using Wang's well-known I/Q processing to improve data rates. A POSA would then incorporate Choi's HSA into the Chen/Wang system to realize the known benefits of improved efficiency and robustness against battery depletion, key objectives in mobile device design.
    • Expectation of Success (for §103 grounds): Petitioner contended that a POSA would have had a reasonable expectation of success. The combination involved substituting known elements (Wang's I/Q processing, Choi's HSA) into a known system (Chen's ET architecture) to achieve predictable results already demonstrated by the individual references.

4. Key Claim Construction Positions

  • Petitioner addressed several claim terms, largely adopting constructions from a parallel International Trade Commission (ITC) litigation to demonstrate invalidity even under the Patent Owner's preferred interpretations.
  • Means-Plus-Function Limitations: A central part of the argument targeted the means-plus-function limitations of claim 28, governed by §112, ¶6.
    • For the "means for determining a single power tracking signal...", Petitioner identified the corresponding structure in the patent as "power tracker 582," but argued this was a mere black box with no disclosed internal components. This was contrasted with the detailed, functional structures disclosed in the prior art combination, such as Chen's Envelope Detectors and Envelope Combiner, as modified by Wang's I/Q processing.
    • For the "means for generating a single power supply voltage...", Petitioner identified the patent's structure as power supply generator 586 and its components (PT Amp, switcher, boost converter). Petitioner argued this function and structure was taught by substituting Chen's generic "Envelope Amplifier" with Choi's detailed HSA.
    • For the "means for receiving the single power supply voltage... and producing a single output radio frequency (RF) signal", Petitioner identified the patent's structure as PA 560 and argued this was identical to Chen's dual-band PA.
  • Other Key Terms: For non-MPF terms like "power tracker" and "single power tracking signal", Petitioner applied the constructions from the ITC case and argued the combined prior art met those definitions.

5. Key Technical Contentions (Beyond Claim Construction)

  • Voltage as a Proxy for Power: A key technical contention was that even if Chen disclosed calculating signal envelopes based on voltage rather than directly on power (in watts), this did not distinguish it from the claimed invention. Petitioner argued that since power is directly proportional to the square of the voltage, using voltage as a proxy for power was a well-understood and functionally equivalent technique. A POSA would have found it an obvious design choice to calculate power directly, if desired, as it was one of a limited number of known ways to determine the power tracking signal.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 28-30 of the ’675 patent as unpatentable under 35 U.S.C. §103.