PTAB

IPR2018-01476

Apple Inc v. Invt SPE Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: MIMO Communication with Combined Spatial Multiplexing and Transmit Diversity
  • Brief Description: The ’711 patent discloses a Multiple-Input/Multiple-Output (MIMO) wireless communication system that simultaneously combines spatial multiplexing and transmit diversity techniques. The system distinguishes between normal data and higher-priority "specific data" (e.g., control signals or retransmission requests), applying transmit diversity to the specific data for improved reliability while using spatial multiplexing for other data to maintain high transmission efficiency.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are obvious over Paulraj, Huang, and Walton.

  • Prior Art Relied Upon: Paulraj (Patent 6,067,290), Huang (a 1999 IEEE publication titled “Achieving High Data Rates in CDMA Systems Using BLAST Techniques”), and Walton (Patent 7,095,709).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Paulraj taught the foundational elements of the challenged claims, including a MIMO transmitter that uses both spatial multiplexing (to increase data rate) and transmit diversity (to improve link reliability). Paulraj’s system splits a data stream into multiple substreams, maps them to different antennas, and discloses that a single substream may be transmitted from more than one antenna for diversity purposes. However, Paulraj did not explicitly detail the mechanism for replicating the substream for diversity. Walton remedied this by teaching a transmit diversity processor with a specific "symbol repetition unit" for generating one or more replicas of a datastream. Further, to the extent Paulraj was ambiguous about simultaneous transmission, Huang explicitly taught that for transmit diversity, "the same substream is simultaneously transmitted from more than one antenna." For dependent claim 2, Petitioner asserted Walton taught applying diversity modes to achieve higher reliability for "certain data transmissions" like control signals or data sent under poor channel conditions, aligning with the ’711 patent’s "specific data" concept. For claim 3, Paulraj was argued to disclose a CDMA embodiment where different data is multiplexed onto a substream using unique codes.
    • Motivation to Combine: A POSITA would combine Walton's explicit repetition unit with Paulraj’s system to implement the disclosed diversity function, as this represented a known technique to achieve the predictable result of improved link reliability. A POSITA would look to Huang to implement Paulraj's space diversity function, as simultaneous transmission was a well-known and simple method for doing so. The motivation to apply diversity to specific data types as taught by Walton was to ensure the reliable reception of critical signals (e.g., control channels) to maintain the communication link.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as the combination involved applying well-known diversity techniques and components (Walton's repetition, Huang's simultaneous transmission) to a conventional MIMO architecture (Paulraj) to achieve the known benefits of improved reliability.

Ground 2: Claims 1-6 are obvious over Wallace and Walton.

  • Prior Art Relied Upon: Wallace (Application # 2002/0193146) and Walton (Patent 7,095,709).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented to cover a broader interpretation of the claims that encompasses systems that switch between diversity and multiplexing modes, rather than employing them simultaneously. Petitioner argued Wallace disclosed a MIMO system that does exactly this, selecting a mode based on link quality. When link quality is poor, Wallace’s system enters a diversity mode where a data signal is replicated and transmitted from multiple antennas. When link quality is good, it uses a spatial multiplexing mode where the signal is split into portions, with each portion transmitted from a different antenna. As in Ground 1, Walton was cited for its explicit teaching of a "symbol repetition unit" to generate the data replicas needed for diversity.
    • Motivation to Combine: A POSITA would combine Walton's repetition unit into the transmitter of Wallace to perform the data replication that Wallace’s system required when operating in its diversity mode. The motivation was to use a known, off-the-shelf component (a repetition unit) to implement a function (data replication for diversity) explicitly disclosed in the primary reference (Wallace) to achieve its stated goal of improving communication link reliability.
    • Expectation of Success: The combination would predictably enable Wallace’s disclosed diversity communication mode. A POSITA would have understood that incorporating a standard repetition unit into Wallace’s processor was a straightforward design choice with a high likelihood of success.

4. Key Claim Construction Positions

  • "MIMO (multi-input/multi-output) scheme": Petitioner argued this term, consistent with the specification and its meaning in the art, requires a system comprising a transmitting apparatus with multiple transmit antennas and a receiving apparatus with multiple receive antennas.
  • "user data requiring a better communication quality than other user data": Petitioner contended this limitation should be construed to include data given "higher priority in transmission," such as control signals or data transmitted to a receiver experiencing poor channel quality. This construction was central to mapping the teachings of references like Walton, which apply diversity to improve reliability for such critical data transmissions.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6 of Patent 7,764,711 as unpatentable.