PTAB

IPR2019-00259

Apple Inc. v. Uniloc 2017 LLC

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1. Case Identification

2. Patent Overview

  • Title: Wireless Data Retransmission Using Abbreviated Sequence Numbers
  • Brief Description: The ’917 patent discloses a system and method for detecting error-affected data transmitted over a wireless network and requesting retransmission. The purported innovation involves improving efficiency by detecting errors at the physical layer, rather than a higher layer, and using abbreviated sequence numbers to identify packet data units, thereby reducing transmission overhead.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 9-10 are obvious over Decker in view of Abrol.

  • Prior Art Relied Upon: Decker (Patent 5,946,320) and Abrol (Patent 6,507,582).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Decker and Abrol discloses all limitations of the challenged claims. Decker provides the foundational system, while Abrol provides the specific inventive concept of using abbreviated sequence numbers for efficiency.
      • Decker was asserted to teach a wireless communication system, such as a GSM cellular network, that uses a hybrid automatic repeat request (ARQ) method for data exchange between a controller and terminals. This system involves transmitting packet data, testing for transmission success at the physical layer of a receiving device, and sending positive (ACK) or negative (NAK) acknowledgements based on the outcome. Petitioner mapped these teachings to the preamble and several limitations of independent claims 1, 9, and 10, including the storing of coded transport blocks and the basic ACK/NAK mechanism.
      • Abrol was asserted to supply the remaining key limitations, primarily concerning the use of "abbreviated sequence numbers." Abrol teaches a method to improve wireless protocol efficiency by generating "shortened" sequence numbers to identify data bytes, which minimizes overhead without causing ambiguity. Critically, Abrol discloses that the length of the abbreviated number can be variable and depend on the number of outstanding data blocks needing unique identification, directly mapping to claim language. Abrol also teaches that data packets are delivered by a radio link protocol (RLP) layer, satisfying the "radio link control layer" limitation.
      • For the dependent claims, Petitioner argued that Decker expressly teaches a Type II hybrid ARQ method (claim 2). The combination of Decker's ACK/NAK signaling with Abrol's abbreviated sequence numbers to identify the specific data block was argued to render claim 3 obvious. Claims 9 and 10, which recast claim 1 from the perspective of a radio network controller and a terminal, respectively, were argued to be obvious as both roles (sender/receiver) are inherent in the systems described by both Decker and Abrol.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine Abrol's efficiency-improving techniques with Decker's foundational ARQ system. The primary motivation was to achieve a predictable improvement in system performance by reducing transmission overhead. Decker's stated goal is to secure high data throughput, and Abrol's method of using shortened sequence numbers to reduce header size directly serves this objective. Furthermore, Abrol stated that its invention is "applicable to any communication system employing transmission of a byte stream over a wireless channel," which provided an express suggestion to a POSITA to apply its teachings to a system like Decker's.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The integration of Abrol's known technique for abbreviated numbering into Decker's standard hybrid ARQ framework was presented as a straightforward design choice, not a complex or unpredictable undertaking. The result—an ARQ system with improved overhead efficiency—was a predictable outcome of combining known elements to solve a known problem in the art.

4. Relief Requested

  • Petitioner requested institution of an inter partes review of claims 1-3 and 9-10 of the ’917 patent and cancellation of those claims as unpatentable under 35 U.S.C. §103.