Intel Corp v. Qualcomm Inc

1. Case Identification

• Case #: IPR2019-00047
• Patent #: 9,154,356
• Filed: November 8, 2018
• Petitioner(s): Intel Corporation
• Patent Owner(s): Qualcomm Incorporated
• Challenged Claims: 1, 7-8, 10-11, and 17-18

2. Patent Overview

• Title: Low Noise Amplifier for Carrier Aggregation
• Brief Description: The ’356 patent relates to a low noise amplifier (LNA) within a radio frequency (RF) receiver configured to support carrier aggregation (CA). The LNA features multiple, independently enable-able amplifier stages to process multi-carrier signals and provide separate output RF signals to different load circuits.

3. Grounds for Unpatentability

Ground I: Anticipation of Claims 1, 11, 17, and 18 by Uehara

• Prior Art Relied Upon: Uehara (Application # 2011/0217945).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Uehara discloses every element of the challenged independent claims. Specifically, Uehara teaches a multi-carrier LNA with parallel transconductance stages that function as the claimed first and second amplifier stages. Petitioner asserted that Uehara’s use of cascode transistors, which can be selectively turned on or off via controlling voltages, directly corresponds to the key limitation of amplifier stages that are "configured to be independently enabled or disabled." This limitation was the primary basis on which the patent was allowed during prosecution. Uehara further discloses processing a dual-carrier RF signal and routing the outputs to separate load circuits (mixers), satisfying the carrier aggregation limitations of the claims. For dependent claim 11, Uehara’s explicit disclosure of a “matching network” was argued to meet the "input matching circuit" limitation.

Ground II: Obviousness of Claims 7-8 over Uehara in view of Perumana

• Prior Art Relied Upon: Uehara (Application # 2011/0217945) and Perumana ("Resistive-Feedback CMOS Low-Noise Amplifiers for Multiband Applications," May 2008).
• Core Argument for this Ground:
  • Prior Art Mapping: Uehara was asserted to teach the base LNA architecture with independently controlled amplifier stages as detailed in Ground I. Perumana was cited for teaching the addition of a resistive feedback circuit (comprising resistors and capacitors) between the input and output of an LNA to improve performance, reduce input impedance, and achieve high gain. This feedback circuit directly maps to the limitations of dependent claims 7 and 8.
  • Motivation to Combine: A POSITA would combine Perumana's feedback circuit with Uehara's LNA to achieve predictable benefits. Perumana explicitly teaches that its circuit can significantly reduce implementation costs and enable the LNA to operate with a higher bandwidth, a known desirable characteristic for the multi-carrier systems disclosed in Uehara.
  • Expectation of Success: Petitioner argued success would be highly likely because combining a known feedback circuit with a standard LNA architecture involved well-understood design techniques. This combination would predictably yield improved performance without requiring undue experimentation.

Ground III: Obviousness of Claims 1, 11, 17, and 18 over Uehara in view of Feasibility Study

• Prior Art Relied Upon: Uehara (Application # 2011/0217945) and Feasibility Study (3GPP TR 36.912, "Feasibility study for Further Advancements for E-UTRA (LTE-Advanced)," Dec. 2009).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground was presented as an alternative to anticipation, arguing that even if Uehara alone were found not to sufficiently teach the "carrier aggregation" element, the combination with the Feasibility Study rendered it obvious. Uehara provides the LNA architecture with multiple, independently controlled signal paths. The Feasibility Study explicitly teaches the design and implementation details for LTE-Advanced systems supporting carrier aggregation and suggests that an ideal receiver for noncontiguous carrier aggregation would have multiple RF front-ends, an architecture that mirrors Uehara's design.
  • Motivation to Combine: A POSITA would be motivated to apply the carrier aggregation techniques from the Feasibility Study to a receiver architecture like Uehara's to unlock the known benefits of LTE-Advanced systems, such as wider transmission bandwidths and spectrum aggregation. The motivation arises from the references themselves, combining a known standard (Feasibility Study) with a suitable hardware implementation (Uehara).
  • Expectation of Success: Success would be expected because the Feasibility Study teaches that a receiver with multiple processing paths can successfully support carrier aggregation, and Uehara provides such an architecture. Modifying Uehara to accept the specific signals described in the Feasibility Study would involve only routine and well-known receiver tuning and filtering techniques.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Uehara and Youssef for claim 10 (adding an attenuation circuit) and three-way combinations of Uehara, the Feasibility Study, and either Perumana or Youssef for dependent claims 7, 8 and 10.

4. Key Claim Construction Positions

• "carrier aggregation": Petitioner proposed this term be construed as “simultaneous operation on multiple carriers,” based on an explicit definition in the ’356 patent’s specification. This construction was central, as Petitioner argued the Patent Owner advocated for a narrower definition (requiring increased bandwidth or data rate) in parallel litigation. Petitioner contended its broader construction was correct under the broadest reasonable interpretation standard and that the prosecution history did not create a clear and unambiguous disavowal of scope.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a). It asserted that co-pending litigation should not bar the IPR because the related district court case was not in an advanced stage, and a parallel International Trade Commission (ITC) investigation involved a different legal standard and remedy (an exclusion order versus claim cancellation). Petitioner also noted it had not filed any other petitions challenging the patent prior to the current group of related filings.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1, 7-8, 10-11, and 17-18 of Patent 9,154,356 as unpatentable.