PTAB

IPR2019-01282

BlackBerry Corp v. Uniloc 2017 LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Data Transmission Method
  • Brief Description: The ’487 patent discloses a method and network architecture within a Universal Mobile Telecommunications System (UMTS) for optimizing data transmission. The technology focuses on a selection algorithm for choosing a suitable transport format combination (TFC) that maps data from logical channels to transport channels while maintaining a minimum bit rate for the respective logical channels.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Standards - Claims 1-6 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 (3GPP 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 TS25.321, a 3GPP standard for the Medium Access Control (MAC) protocol, discloses the foundational UMTS network of claim 1, including the mapping of logical channels to transport channels and a TFC selection algorithm based on channel priorities. However, this algorithm used an "absolute priority scheme." To supply the key limitation of using a "minimum bit rate criteria," Petitioner pointed to R2-010182, an official change request for TS25.321. R2-010182 proposed modifying the TFC selection algorithm to solve problems with the absolute priority scheme by introducing new parameters, including a "MinGBr" (Minimum Guaranteed Bit rate), which Petitioner contended directly corresponds to the claimed criteria. R2-010182 also taught considering a "MaxBr" (Maximum Bit rate), meeting claim 2. For other limitations, Petitioner relied on TS25.302, the 3GPP standard for the physical layer, arguing it defines the "plurality of valid transport format combinations" (claim 1) and the specific radio frame timing characteristics recited in dependent claim 4.
    • Motivation to Combine: A POSITA would combine TS25.321 and R2-010182 because R2-010182 is an explicit proposal to improve the very TFC selection algorithm described in TS25.321 by addressing its known deficiencies. A POSITA would combine this pair with TS25.302 because TS25.321 (MAC layer) and TS25.302 (physical layer) are complementary, contemporaneous 3GPP standards for adjacent layers of the same UMTS protocol stack, and TS25.321 explicitly references TS25.302 for definitions of physical layer services.
    • Expectation of Success: A POSITA would have a high expectation of success in combining the references, as it would involve implementing a detailed, official change request (R2-010182) into its target specification (TS25.321) and using definitions from a complementary, cross-referenced standard (TS25.302).

Ground 2a: Obviousness over Peisa - Claims 1 and 2 are obvious over Peisa.

  • Prior Art Relied Upon: Peisa (Patent 6,850,540).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Peisa, which discloses packet scheduling in a UMTS network, renders claims 1 and 2 obvious. Peisa allegedly teaches a MAC layer that schedules packet transmission by selecting valid TFCs from a TFC set. Crucially, Petitioner argued Peisa's selection algorithms are based on "guaranteed rate transmission rates." The algorithm detailed in Peisa's Figure 8 obtains a "Guaranteed Rate" parameter for each logical channel and selects a TFC that transmits "at least the guaranteed rate for each flow." Petitioner argued this "at least" condition directly teaches the claimed "minimum bit rate criteria." Furthermore, Peisa's algorithm allegedly considers a "maximum allowed rate for any logical channel," thus teaching the limitation of claim 2.

Ground 2b: Obviousness over Peisa and TS25.302 - Claims 4-6 are obvious over Peisa in view of TS25.302.

  • Prior Art Relied Upon: Peisa (Patent 6,850,540) and TS25.302 (3GPP Technical Specification V3.6.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the teachings of Peisa for the base invention of claim 1. Petitioner argued that while Peisa discloses the use of a Transmission Time Interval (TTI) for transmitting data, it does not specify its relation to radio frames. To supply the limitations of dependent claim 4, Petitioner combined Peisa with TS25.302. TS25.302, as the definitive 3GPP specification for the UMTS physical layer, explicitly teaches that a TTI is "always a multiple of the minimum interleaving period (e.g. 10ms, the length of one Radio Frame)" and that transmission block timing is "tied exactly to this L1 frame timing." This combination allegedly teaches that the TTI is at least one radio frame and is active when its start coincides with a radio frame, meeting the limitations of claim 4. The combination was also asserted to teach the elements of claims 5 and 6 concerning the MAC and RLC layers.
    • Motivation to Combine: A POSITA seeking to implement the packet scheduling system described in Peisa would encounter UMTS-specific physical layer concepts, such as TTI. The POSITA would be motivated to consult the official 3GPP standard that defines these concepts, TS25.302, to understand their precise attributes and ensure proper implementation within the UMTS framework that Peisa describes.
    • Expectation of Success: There would be a high expectation of success in combining Peisa's scheduling algorithm with the standard physical layer definitions from TS25.302, as this represents a straightforward application of industry standards to a system designed to operate within that standard's framework.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-6 as unpatentable.