Intel Corp v. Qualcomm Inc

1. Case Identification

• Case #: IPR2018-01346
• Patent #: 9,535,490
• Filed: July 6, 2018
• Petitioner(s): Intel Corporation, Apple Inc.
• Patent Owner(s): Qualcomm Incorporated
• Challenged Claims: 9, 11-13, 26, and 27

2. Patent Overview

• Title: Processor Communication Power Management
• Brief Description: The ’490 patent discloses a system for conserving power in mobile devices by coordinating data transfers between a modem processor and an application processor. It aims to reduce power-state transitions of the interconnectivity bus by transmitting buffered downlink and uplink data within a single active bus period, using the receipt of downlink data as a trigger for the subsequent uplink transmission.

3. Grounds for Unpatentability

Ground 1: Claims 9, 11-13, 26, and 27 are obvious over Heinrich in view of Balasubramanian under 35 U.S.C. §103.

• 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 taught the fundamental architecture of the challenged claims, including a mobile terminal with a modem (baseband) processor and an application processor coupled by a bus, as well as the core power-saving concept of using timers to buffer and aggregate data transmissions. However, Heinrich did not explicitly teach using the receipt of data from the modem as a "trigger" for the application processor to send its own buffered data. Petitioner asserted that Balasubramanian supplied this missing element, disclosing a system where the receipt of an uplink packet at a second processing node explicitly "triggers" the transmission of any queued downlink packets from that second node back to the first, all within a single wake state to conserve power. The combination of Heinrich's architecture with Balasubramanian's trigger mechanism would result in the system claimed in the ’490 patent.
  • Motivation to Combine: A POSITA would combine Heinrich and Balasubramanian for several reasons. Both references are in the same technical field of processor-to-processor communications and address the identical problem of reducing power consumption from state transitions using similar buffering techniques. Petitioner contended that Heinrich’s system was open to modification, as it broadly taught sending data when the receiving processor was known to be "awake." Balasubramanian’s trigger mechanism provided a specific and efficient method for determining that the other processor is awake, making it a predictable and beneficial modification to improve Heinrich's system by "piggybacking" the return data transmission onto an already-active bus session.
  • Expectation of Success: Petitioner contended that a POSITA would have a high expectation of success, as the combination involved applying a known technique (Balasubramanian's trigger) to a similar system (Heinrich's) to achieve the predictable and desired result of fewer bus power-state transitions. The integration was presented as a straightforward application of established principles.
  • Key Aspects: Petitioner argued that the combination also rendered the dependent claims obvious.
    • For claims 11, 12, 26, and 27, which add limitations for byte or packet counters, Petitioner asserted that Balasubramanian taught using counters to trigger data transmission. A POSITA would have found it obvious to incorporate a counter into Heinrich's system as a well-known alternative to a timer for preventing buffer overflow, a risk Heinrich acknowledged.
    • For claim 13, which adds sending "control packets" before a timer expires, Petitioner argued this was met by Heinrich's disclosure of prioritizing and sending "real-time sensitive" data, such as control information for voice calls, without delay.

4. Key Claim Construction Positions

• Petitioner proposed that the key claim term "triggered by" should be construed to mean "initiated in response to." This construction was central to the invalidity argument, as it aligned with the explicit disclosure in Balasubramanian. During prosecution of the ’490 patent, the applicant distinguished prior art by arguing it used only predetermined time delays, not a responsive trigger. Petitioner's proposed construction directly adopted the language used to overcome this prior art, leveraging the patent's own prosecution history to support its obviousness combination.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 9, 11-13, 26, and 27 of the ’490 patent as unpatentable.