Intel Corp v. Qualcomm Inc

1. Case Identification

• Case #: IPR2018-01344
• Patent #: 9,535,490
• Filed: July 6, 2018
• Petitioner(s): Intel Corporation
• Patent Owner(s): Qualcomm Incorporated
• Challenged Claims: 20, 28, and 30

2. Patent Overview

• Title: Controlling Power Consumption in a Computing Device
• Brief Description: The ’490 patent discloses a system and method for conserving power in a computing device, such as a mobile terminal, containing a modem processor and an application processor. The invention aims to reduce power consumption by limiting the number of bus transitions between low-power and active states by consolidating data transfers.

3. Grounds for Unpatentability

Ground 1: Claims 20, 28, and 30 are 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 the combination of Heinrich and Balasubramanian rendered the challenged claims obvious. Heinrich disclosed the core architecture of the ’490 patent: a computing device with an application processor and a modem processor (termed a "baseband processor") that communicate over an interconnectivity bus. To save power, Heinrich taught buffering non-real-time data at both processors and using timers (a "lazy timer") to schedule aggregated data transmissions, thereby reducing the number of power state transitions. However, Heinrich did not explicitly teach using the receipt of data from one processor to trigger a return transmission from the other.

    Balasubramanian allegedly supplied this missing element. It disclosed a power-saving scheme for communication between two processing nodes (a transceiver and a network interface) where transmissions are synchronized to occur within a single "wake state." Critically, Balasubramanian taught that the "receipt of an uplink packet" from the first node could be used as a "trigger" to transmit any queued downlink packets from the second node back to the first. Petitioner contended that substituting Balasubramanian’s "trigger" mechanism into Heinrich's power-saving framework would arrive at the invention of the ’490 patent.

    Specifically for the dependent claims:

    • Claim 20 adds an "override capability" based on factors like accumulated packet count. Petitioner asserted Balasubramanian taught this by disclosing that a buffer could be cleared based on either an elapsed timer or a configurable number of queued packets, making one an override for the other.
    • Claim 28 recites a "mobile terminal" with an "application byte counter." Petitioner argued that Balasubramanian's packet counter rendered a byte counter obvious, as tracking bytes is a predictable alternative to tracking packets for managing buffer overflow, especially with variable-sized packets.
    • Claim 30 recites a method with similar trigger logic. Petitioner’s arguments for this claim mirrored those for the system claims.

  • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Heinrich and Balasubramanian because both references were in the same field (power management for inter-processor communication) and addressed the identical problem of reducing power consumption from frequent bus state transitions. Heinrich itself suggested its system was open to modification by teaching that transmissions should occur at the "best possible time," such as when a processor is already known to be awake. Balasubramanian provided a known, predictable, and highly relevant technique for determining that "best possible time": the receipt of data from the other processor, which inherently confirms it is awake and active.

  • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because incorporating Balasubramanian's trigger mechanism into Heinrich's system was merely the application of a known technique (triggering on receipt) to a similar system (Heinrich's dual-processor architecture) to obtain a predictable result (reduced power state transitions).

4. Key Claim Construction Positions

• "triggered by" / "triggers": Petitioner proposed this key term, which was added during prosecution to achieve allowance, should be construed to mean "initiated in response to." This construction was argued to be supported by the patent's specification, the prosecution history, and dictionary definitions. The construction was critical to Petitioner's argument, as it allowed Balasubramanian's disclosure—where receipt of an uplink packet causes the transmission of downlink packets—to be mapped directly onto the "trigger" limitation of the challenged claims.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and cancellation of claims 20, 28, and 30 of the ’490 patent as unpatentable.