PTAB

IPR2018-01419

Ruckus Wireless Inc v. Hera Wireless SA

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Radio Apparatus, Method and Program for Controlling Spatial Path
  • Brief Description: The ’115 patent discloses a radio apparatus and method for establishing multiplex communication using space division. The invention centers on a radio apparatus that stores a value associated with the number of formable spatial paths and transmits this value to another apparatus at a predetermined time to configure the communication link.

3. Grounds for Unpatentability

Ground 1: 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 within its teachings of an adaptive MIMO wireless system designed to maximize communication parameters. Paulraj’s transmitter (e.g., transmitter 50) functions as the claimed "radio apparatus." Its antenna mapping unit, which processes data streams for multiple antennas, constitutes the claimed "communication unit." Paulraj’s database 68, which stores system parameters, functions as the "storage unit." This database stores the number of spatial-multiplexed streams (k), a value limited by the number of transmit/receive antennas. Petitioner contended this k value directly corresponds to the claimed "value indicating possible multiplicity associated with the number of spatial paths." Paulraj's adaptive controller 60, part of its control unit 62, is the "control unit" that determines k based on channel feedback and controls its transmission to the receiver. This transmission occurs at a "predetermined timing," as Paulraj teaches sending this control information "regularly" in a recurring time slot (in a TDMA system) or during session initialization.
    • Prior Art Mapping (Dependent Claims): Petitioner asserted that the limitation of claim 2 (timing comes before communication) is met by Paulraj's disclosure of transmitting control information during system initialization. The limitation of claim 3 (storing the number of paths capable of attaining normal reception) is met because Paulraj’s adaptive control adjusts k based on signal statistics like Signal-to-Interference-plus-Noise Ratio (SINR) or Bit Error Rate (BER) to maximize communication quality. Claims 4-6 are method claims that mirror apparatus claims 1-3, and Petitioner argued they are obvious for the same reasons.
    • Motivation to Combine: The motivation was argued as being inherent to Paulraj, which explicitly seeks to optimize and adapt communication in a variable wireless channel. A POSITA would be motivated to use the parameters disclosed in Paulraj (like k) to enable adaptive communication between a transmitter and receiver, as this is the explicit purpose of the system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Paulraj provides a complete system architecture and the necessary technical components for implementing the claimed features to achieve its stated goal of maximizing communication performance.

Ground 2: 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 discloses a wireless system using multiple-beam antennas that addresses the same problem as the ’115 patent: assigning and reassessing preferred antenna beams. Reudink's base station is the "radio apparatus," and its adaptive antenna array is the "communication unit." Reudink teaches an initialization protocol using a dedicated Multiple Beam Antenna Access Channel (MBAACH). A message on this channel explicitly contains a "Number of Beams" data field, which Petitioner asserted is the claimed "value indicating possible multiplicity." A controller within the base station must store this value beforehand to include it in the message, satisfying the "storage unit" limitation. The transmission of this MBAACH message occurs in a dedicated time slot during an "initial assignment" procedure, meeting the "predetermined timing" limitation.
    • Prior Art Mapping (Dependent Claims): This initial assignment procedure inherently occurs "before a communication" is fully established, satisfying claim 2. The "number of spatial paths capable of attaining normal reception" (claims 3 and 6) is taught because Reudink's entire beam selection process is based on signal strength measurements and identifying preferred beams that meet quality-of-service thresholds. The arguments for claims 4-6 were asserted to be the same as for claims 1-3.
    • Motivation to Combine: The motivation was described as explicit in Reudink: to solve the problem of efficiently assigning communication resources (antenna beams) for each user. A POSITA would utilize Reudink’s taught messaging protocol, including transmitting the number of available beams, to facilitate this assignment process between a base station and a remote station.
    • Expectation of Success: Reudink describes a detailed and practical messaging protocol for beam acquisition and assignment. A POSITA would have a high expectation of success in implementing this protocol to transmit the number of available beams from a base station to a remote terminal as part of establishing a communication link.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 of Patent 8,412,115 as unpatentable.