PTAB

IPR2019-00128

Intel Corp v. Qualcomm Inc

Key Events

Petition

petition

Title: Low Noise Amplifier Supporting Carrier Aggregation
Brief Description: The ’356 patent relates to a low noise amplifier (LNA) within a radio frequency (RF) receiver designed to support carrier aggregation (CA). The LNA includes multiple, independently switchable amplifier stages to process signals received on different carriers simultaneously or separately.

Prior Art Relied Upon: Lee (Application # 2012/0056681).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lee, which was cited but not applied during prosecution, discloses every limitation of the challenged claims. The central assertion was that Lee’s signal amplification circuit, designed for a multi-radio device (e.g., WiFi and Bluetooth), is structurally and functionally identical to the claimed LNA. Lee expressly teaches a plurality of amplifier blocks, each of which can be independently enabled or disabled. This directly maps to the key limitation that the Examiner previously found to be missing from the prior art and was the basis for allowance.
- Key Aspects: Petitioner contended that Lee’s “combo mode,” where both WiFi and Bluetooth functions are active and their respective amplifier stages are “both enabled at the same time,” inherently teaches the claimed “carrier aggregation.” Because WiFi and Bluetooth operate on different carriers, processing them simultaneously constitutes the "simultaneous operation on multiple carriers" required by the claims.

Prior Art Relied Upon: Lee (Application # 2012/0056681).
Core Argument for this Ground:
- Prior Art Mapping: As an alternative position, Petitioner argued that even if the specific embodiment of Lee’s Figure 2 did not anticipate claim 7’s feedback circuit limitation, it would have been obvious to a person of ordinary skill in the art (POSITA) to incorporate the feedback circuit taught elsewhere in Lee (e.g., Figure 4) into the amplifier circuit of Figure 2. Claim 8, which depends on claim 7, recites that the feedback circuit comprises a resistor and/or a capacitor, both of which are disclosed as components of the feedback circuit in Lee’s Figure 4.
- Motivation to Combine: Lee itself provided the motivation, teaching that implementing feedback elements "can improve greatly" the input matching performance and widen the operational frequency range of the amplifier. A POSITA would combine these disclosed elements from different embodiments of the same reference to achieve this predictable and explicitly stated benefit.
- Expectation of Success: A POSITA would have a high expectation of success, as combining a known feedback circuit with a standard amplifier architecture to improve performance was a well-understood and routine design choice in RF engineering.

Prior Art Relied Upon: Lee (Application # 2012/0056681) and the Feasibility Study (3GPP TR 36.912).
Core Argument for this Ground:
- Prior Art Mapping: This ground was presented to rebut any argument that Lee fails to explicitly teach "carrier aggregation" in the context of cellular standards like LTE. The Feasibility Study, a 3GPP technical report, explicitly teaches extending LTE with carrier aggregation to support wider bandwidths. It describes receiver architectures for CA, suggesting that an ideal receiver would use multiple RF front-ends, each with its own amplifier.
- Motivation to Combine: A POSITA seeking to design a receiver for the LTE-Advanced systems described in the Feasibility Study would be motivated to use Lee's multi-path, independently switchable LNA architecture. Lee provides the exact type of circuit—multiple amplifier blocks providing output to different processing paths—that the Feasibility Study identifies as suitable for implementing carrier aggregation. The combination amounts to using Lee's known amplifier circuit to process the CA signals described in the Feasibility Study.
- Expectation of Success: A POSITA would have reasonably expected success because the Feasibility Study teaches that receivers with multiple processing paths can support CA, and Lee's circuitry is demonstrably capable of receiving and processing signals on different frequencies simultaneously.

"carrier aggregation": Petitioner argued this term should be construed as “simultaneous operation on multiple carriers.”
- This construction was taken directly from the ’356 patent’s specification, where it states, “a wireless device may support carrier aggregation, which is simultaneous operation on multiple carriers.” Petitioner argued this plain language acts as a lexicographical definition.
- This construction was critical because it is broad enough to encompass Lee’s simultaneous processing of WiFi and Bluetooth signals. It counters the Patent Owner's narrower interpretation, advanced during prosecution, which attempted to limit the term to uses that result in an "increased aggregated data rate" to distinguish prior art.

Petitioner argued that discretionary denial under §314(a) or §325(d) would be inappropriate despite a co-pending ITC investigation and a related district court case.
The core arguments were that the petition was timely filed, the ITC investigation involved a different remedy (exclusion order vs. claim cancellation) and would not provide the same relief, and the district court case was not in an advanced stage, with trial not scheduled to begin for nearly a year.

Petitioner requests institution of an inter partes review and cancellation of claims 1, 7, 8, 11, 17, and 18 of the ’356 patent as unpatentable.