PTAB

IPR2018-01420

Ruckus Wireless Inc v. Hera Wireless SA

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Radio Apparatus, and Method and Program for Controlling Spatial Path
  • Brief Description: The ’851 patent discloses a radio apparatus and methods for adaptively modifying a plurality of communication paths between a terminal and a base station in a Multiple-Input Multiple-Output (MIMO) system. The invention focuses on transmitting information about the number of possible spatial paths (multiplicity) to improve communication stability and speed.

3. Grounds for Unpatentability

Ground 1: Obviousness over Paulraj - Claims 4-6 are obvious over Paulraj in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Paulraj (Patent 6,351,499).
  • Core Argument for this Ground: Petitioner argued that Paulraj taught a sophisticated wireless communication system that adaptively optimizes transmissions to maximize parameters like data capacity and throughput. Paulraj’s system used multiple antennas at both the transmitter and receiver to create multiple spatial-multiplexed streams, a technique a Person of Ordinary Skill in the Art (POSITA) would recognize as a MIMO scheme. The system dynamically adjusted the number of these streams (k) based on channel conditions, which required storing and transmitting this value between devices.
    • Prior Art Mapping: Petitioner contended that Paulraj disclosed all elements of independent claim 4.
      • The claimed "communication unit configured to communicate using a plurality of antennas" was disclosed as Paulraj's antenna mapping unit, which includes space-time coders and a transmit processing unit that map data streams to a plurality of transmit antennas.
      • The "storage unit configured to store beforehand a value indicating possible multiplicity" was disclosed as Paulraj’s database 68. This database stored parameters including the number of spatial-multiplexed streams (k), which Petitioner argued was a "value indicating possible multiplicity" associated with the number of formable spatial paths.
      • The "control unit configured to control a processing of transmitting the value" was disclosed as Paulraj’s adaptive controller 60. This controller determined the value of k and controlled its transmission to the receiver, which needed to know k to recover the data. Paulraj taught transmitting this information "regularly" or during "initialization," which a POSITA would understand corresponds to a "predetermined timing" in a known TDMA system.
      • For dependent claim 5, Petitioner argued Paulraj’s teaching of transmitting k during system "initialization" met the limitation that the timing comes "before a communication."
      • For dependent claim 6, Petitioner asserted that in systems with reciprocal channels, which Paulraj disclosed, the transmitter’s own receiver determines the value of k based on what it can receive, thereby satisfying the limitation of storing the number of paths the apparatus is "capable of receiving."
    • Motivation to Combine (for §103 grounds): Petitioner argued a POSITA would be motivated to apply general knowledge of TDMA systems to Paulraj’s teachings to implement the "predetermined timing" of control information transmission. The overall motivation, explicitly stated in Paulraj, was to adapt to changing channel conditions to maximize communication parameters like data capacity and throughput.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because Paulraj provided the necessary technical components and motivation, and implementing control signaling in a known TDMA framework was a well-understood and predictable design choice.

Ground 2: Obviousness over Reudink - Claims 4-5 are obvious over Reudink in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Reudink (Patent 7,039,441).
  • Core Argument for this Ground: Petitioner contended that Reudink disclosed a wireless system using multi-beam antennas to optimize the use of RF spectrum and provide high data bandwidth. Reudink addressed the problem of assigning and assessing the most preferred antenna beams for each user, which required the base station to communicate its capabilities to remote stations. This communication included transmitting the number of available antenna beams (i.e., spatial paths) at a predetermined time.
    • Prior Art Mapping: Petitioner argued that Reudink disclosed the limitations of claims 4 and 5.
      • The "communication unit" using a "plurality of antennas" was met by Reudink's disclosure of base stations and remote stations using "multiple narrow beam antennas" and "adaptive antenna" arrays to form and direct beams.
      • The "storage unit" storing a "value indicating possible multiplicity" was met by Reudink’s disclosure of a base station transmitting a message that included a "Number of Beams" field. Petitioner argued that for the base station to transmit this value, it must have been stored beforehand. This "Number of Beams" directly corresponded to the claimed "value indicating possible multiplicity associated with the number of spatial paths."
      • The "control unit" transmitting the value at a "predetermined timing" was met by Reudink's base station controller. Reudink disclosed transmitting the "Number of Beams" message in a dedicated Multiple Beam Antenna Access Channel (MBAACH) slot. The timing and frequency of this slot were known in advance by the base station, thus occurring at a "predetermined timing."
      • Dependent claim 5 was met because Reudink's transmission of the "Number of Beams" occurred as part of an "initial assignment" and beam acquisition procedure, which a POSITA would understand occurs "before a communication" link is fully established.
    • Motivation to Combine (for §103 grounds): The motivation, inherent in Reudink, was to solve the problem of efficiently assigning preferred communication beams between a base station and multiple users. A POSITA would be motivated to use Reudink's disclosed messaging protocol to provide remote stations with the necessary information about the base station's capabilities to establish an optimal link.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in implementing Reudink’s system because it employed well-known TDMA principles and a straightforward messaging protocol to achieve adaptive beam selection.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 4-6 of the ’851 patent as unpatentable.