PTAB

IPR2018-01737

Ruckus Wireless, Inc. v. Hera Wireless S.A.

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1. Case Identification

2. Patent Overview

  • Title: Wireless Communication Method and Apparatus
  • Brief Description: The ’389 patent discloses a communication method for a wireless system where a radio base station indicates a required reception operation to a radio terminal. The method uses a multiple-field frame containing a single bit that instructs the terminal to adapt its reception operation (e.g., antenna diversity mode) to correspond with the base station’s transmission operation, thereby reducing interference and improving communication performance.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-2 - Claims 1 and 2 are obvious over the IEEE 802.11-1999 standard as amended by the IEEE 802.11b standard under 35 U.S.C. §103.

  • Prior Art Relied Upon: 802.11-1999 (ANSI/IEEE Std 802.11, 1999 Edition) and 802.11b (IEEE Std 802.11b-1999).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of the 802.11-1999 standard and its 802.11b supplement taught all elements of claims 1 and 2. An "Association Request" frame sent from a station (STA) to an access point (AP) constituted the claimed "receiving a connection request." The AP's subsequent transmission of a multi-field frame (e.g., an Association Response PPDU) met the "transmitting a multiple-field frame" limitation. The central "single bit" limitation was met by at least two examples introduced in the 802.11b supplement:
      • The single "Modulation selection" bit (b3) in the SERVICE field of a PPDU header. This bit indicates the AP's transmission operation (CCK or PBCC modulation), and the STA must adapt its reception operation (demodulation scheme) accordingly to correctly receive the frame.
      • The single "Short Preamble" bit (B5) in the Capability Information field. This bit indicates the AP's transmission operation (use of a short or long preamble), and the STA must adapt its reception functions (e.g., antenna selection timing) to successfully interoperate.
    • Prior Art Mapping (Dependent Claim 2): Petitioner contended claim 2 was obvious because the identified single bits (e.g., B5 or b3) inherently have two values ('1' or '0') that specify distinct, mandatory reception operations. For instance, the 802.11b standard uses shall to describe the required actions for interoperability, mandating that a receiver adapt its functions based on the bit's value.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the two standards because 802.11b is explicitly a "Supplement" to the 802.11-1999 standard. It provides instructions on how to merge its features—such as higher data rates and increased throughput—into the base standard, providing a strong and direct motivation for its adoption.
    • Expectation of Success: A POSITA would have had a very high expectation of success, as the standards were created by the same IEEE working group and were expressly designed to be combined into a single, comprehensive standard.

Ground 2: Obviousness of Claim 3 - Claim 3 is obvious over 802.11-1999 as amended by 802.11b in view of Hood under §103.

  • Prior Art Relied Upon: 802.11-1999, 802.11b, and Hood (Patent 6,778,844).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses dependent claim 3, which adds the limitations that the receiving and transmitting steps are performed using a "plurality of antennas." While the 802.11 standards teach antenna diversity, Hood explicitly discloses using an antenna array (a plurality of antennas) at an access point for both receiving and transmitting signals to mitigate multipath fading in 802.11b-compliant systems. Hood describes this as a technique to improve signal quality, directly teaching the missing element.
    • Motivation to Combine: A POSITA would combine Hood with the 802.11 standards to solve a well-known problem. Hood is specifically directed at mitigating the deleterious effects of multipath fading in wireless LAN systems that use the 802.11b standard. Implementing Hood’s antenna array in an 802.11b system is a straightforward application of a known solution to a known problem to achieve improved performance and reliability.
    • Expectation of Success: There would be a high expectation of success because Hood’s teachings are presented as a practical solution for improving 802.11b systems. Combining an antenna array with a standard-compliant access point to improve reception and transmission is a predictable and well-understood engineering task.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 of Patent 7,873,389 as unpatentable.