PTAB

IPR2019-00252

Apple Inc v. Uniloc 2017 LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Network with an Optimized Selection Process for a Suitable Transport Format Combination
  • Brief Description: The ’487 patent relates to wireless communication networks compliant with the Universal Mobile Telecommunications System (UMTS) standard. It discloses a method for selecting a transport format combination (TFC) for data transmission, wherein the selection algorithm purportedly uses a "minimum bit rate criteria" applicable to logical channels to guarantee a minimum data rate.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Standards - Claims 11-13 are obvious over TS25.321 in view of R2-010182 and TS25.302.

  • Prior Art Relied Upon: TS25.321 (3GPP Technical Specification V3.6.0), R2-010182 (Mitsubishi Electric Change Request for TS25.321), and TS25.302 (3GPP Technical Specification V3.6.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the base reference, TS25.321, which specifies the Medium Access Control (MAC) protocol for UMTS networks, disclosed most elements of the challenged claims. This included the network structure with a radio network controller (RNC) and terminals (UEs), the mapping of logical channels to transport channels, and a selection algorithm for choosing TFCs. However, TS25.321's algorithm was based on an "absolute priority scheme" that could lead to lower-priority channels being starved of bandwidth. The secondary reference, R2-010182, an official change request for TS25.321, directly addressed this deficiency by proposing a modification to the selection algorithm. This modification introduced a "MinGBr" (Minimum Guaranteed Bit Rate) parameter, which Petitioner contended directly taught the "minimum bit rate criteria" limitation that was the purported novel feature of the ’487 patent. The third reference, TS25.302, which specified the physical layer services, was used to provide further detail on the allocation of a plurality of valid TFCs to the transport channels, a concept relied upon by TS25.321.
    • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have been highly motivated to combine these references. R2-010182 was an explicit change request intended to solve a known problem in the TS25.321 specification; therefore, a POSITA seeking to improve the TFC selection algorithm would have naturally looked to and applied its teachings. Similarly, TS25.321 and TS25.302 were contemporaneous, complementary standards for adjacent layers of the same UMTS protocol stack, with TS25.321 expressly referencing TS25.302. A POSITA would combine them to gain a comprehensive understanding of the UMTS network's operation.
    • Expectation of Success: A POSITA would have had a high expectation of success because R2-010182 provided a specific, detailed proposal for modifying the very algorithm described in TS25.321 to achieve the claimed functionality of guaranteeing a minimum bit rate.

Ground 2: Obviousness over Peisa - Claims 11-13 are obvious over Peisa.

  • Prior Art Relied Upon: Peisa (Patent 6,850,540).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Peisa, on its own, rendered the challenged claims obvious. Peisa disclosed a method for packet scheduling in a UMTS network, including a MAC layer in an RNC or UE that maps logical channels to transport channels. Critically, Peisa described several TFC selection algorithms designed to meet Quality of Service (QoS) constraints. These algorithms explicitly considered "guaranteed bit rates" for each logical channel when selecting a TFC. For example, the algorithm detailed in Peisa's Figure 8 used a "Guaranteed Rate" parameter for each logical channel as a primary input to ensure that the selected TFC transmits at least the guaranteed rate for each data flow. Petitioner contended this "guaranteed rate" directly corresponded to the "minimum bit rate criteria" recited in the challenged claims, thereby teaching the patent's key limitation.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, this element is not applicable.
    • Expectation of Success (for §103 grounds): Peisa explicitly described the implementation of its TFC selection algorithm in both the RNC and the UE, providing a clear path to achieving the claimed system with a reasonable expectation of success.
    • Key Aspects: Petitioner emphasized that while the examiner considered Peisa during prosecution, the analysis was limited to a narrow portion of the reference. The arguments in the petition were asserted to be new, focusing on different, more relevant disclosures within Peisa (such as the detailed algorithm of FIG. 8) that the examiner did not appear to consider.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 11-13 of the ’487 patent as unpatentable.