PTAB

IPR2018-01418

Ruckus Wireless Inc v. Hera Wireless SA

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Petition

1. Case Identification

2. Patent Overview

  • Title: Radio Apparatus and Method for Controlling a Spatial Path
  • Brief Description: The ’103 patent discloses a radio apparatus for establishing multiplex communication, such as in a Multiple Input Multiple Output (MIMO) system. The apparatus features an adaptive array unit, a storage unit to hold a value indicating the number of formable spatial paths, and a control unit to transmit this value to another apparatus to adaptively configure and modify the communication link.

3. Grounds for Unpatentability

Ground 1: Obviousness over Paulraj - Claims 1-6 are obvious over Paulraj in view of POSITA knowledge.

  • Prior Art Relied Upon: Paulraj (Patent 6,351,499).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Paulraj discloses all elements of the challenged claims. Paulraj teaches a MIMO wireless communication system that uses antenna arrays to adapt transmissions to changing channel conditions to maximize parameters like data capacity and throughput. Petitioner asserted that Paulraj's transmitter is a radio apparatus comprising an adaptive array unit (its S-T coding and transmit processing units), a storage unit (database 68), and a control unit (adaptive controller 60). Paulraj's system adaptively determines the number of spatial-multiplexed streams, denoted as k, based on channel quality. Petitioner contended this parameter k is a "value indicating possible multiplicity" that is stored (or parameters dependent on it are stored) in database 68 before being transmitted to the receiver. The control unit transmits this value k to the receiver at a predetermined timing ("regularly" or at initialization) so the receiver can correctly recover the transmitted data.
    • Motivation to Combine: The ground relies on Paulraj in view of the general knowledge, skill, and creativity of a person of ordinary skill in the art (POSITA). Petitioner asserted that the motivation was inherent in Paulraj's objective: to maximize communication performance by adaptively controlling transmission parameters, including the number of spatial streams, in response to variable channel conditions. This aligns directly with the stated purpose of the ’103 patent.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Paulraj explicitly teaches a complete system for adaptively controlling the number of spatial streams (k) by storing related parameters in a database and transmitting the value to a receiver to enable communication. The system components and their interactions are described for the express purpose of optimizing performance.

Ground 2: Obviousness over Reudink - Claims 1-6 are obvious over Reudink in view of POSITA knowledge.

  • Prior Art Relied Upon: Reudink (Patent 7,039,441).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Reudink, which describes wireless systems using multi-beam antennas to optimize RF spectrum usage, renders the claims obvious. Reudink's base station was asserted to be a radio apparatus with an adaptive array unit (its adaptive multi-beam antenna array). During an "initial assignment" procedure, the base station transmits a message over a dedicated access channel containing a "Number of Beams" data field. Petitioner contended this field is a "value indicating possible multiplicity" that must be stored beforehand in a storage unit before being transmitted by a control unit. The transmission occurs at a predetermined timing, as Reudink's system uses a TDMA protocol where messaging slots are known in advance. The remote station uses this information to establish a communication link, selecting the most preferred antenna beam.
    • Motivation to Combine: This ground combines the Reudink reference with the knowledge of a POSITA. The motivation, as argued by Petitioner, stems from Reudink’s goal of solving the problem of efficiently assigning and assessing the most preferred antenna beams for communication with each user. To achieve this, the system must communicate its capabilities—specifically the number of available beams (spatial paths)—from the base station to the user terminal.
    • Expectation of Success: A POSITA would expect success because Reudink explicitly teaches a protocol for a base station to broadcast the number of its available antenna beams to a remote station to facilitate link setup. Implementing this by storing a known value and transmitting it within a defined TDMA protocol was a straightforward and predictable design choice for a skilled artisan.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6 of the ’103 patent as unpatentable under 35 U.S.C. §103.