PTAB

IPR2022-00338

Apple Inc v. Telefonaktiebolaget LM Ericsson

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Transmission of System Information on a Downlink Shared Channel
  • Brief Description: The ’357 patent relates to methods for transmitting system information to user equipment in a wireless communication network configured for 3GPP E-UTRA (LTE) standards. The invention describes dynamically selecting subframes within recurring time windows to carry system information on a downlink shared channel and including a specific indicator (SI-RNTI) in those subframes.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Lee-746, Lee-668, and R2-072183 - Claims 1-2, 9-10, 22, and 24 are obvious over Lee-746, Lee-668, and R2-072183.

  • Prior Art Relied Upon: Lee-746 (Application # 2010/0167746), Lee-668 (Application # 2008/0285668), and R2-072183 (3GPP TSG RAN WG2#58, May 2007).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Lee-746, discloses transmitting secondary system information, organized in System Information Blocks (SIBs), on a downlink shared channel (DL-SCH) within specific time windows (TTIs). Lee-668 was asserted to teach the claimed dynamic selection of subframes by disclosing that SIBs are transmitted in a dynamic manner where different frequency ranges and time durations (i.e., subframes) can be flexibly used. R2-072183 was argued to supply the claimed indicator, teaching that a control channel (PDCCH) allocated for each subframe carrying system information includes a BCCH RNTI to indicate its presence. Petitioner contended this BCCH RNTI is functionally equivalent to the claimed SI-RNTI. For claim 2, R2-072183 was also cited for teaching that segments of system information can be provided in consecutive subframes, meeting the "contiguous set" limitation.
    • Motivation to Combine: A POSITA would combine Lee-668 with Lee-746 to add the known benefit of flexible and dynamic scheduling to Lee-746's system, thereby prioritizing delay-intolerant transmissions. A POSITA would further incorporate the teaching of R2-072183 to use a well-known indicator (BCCH RNTI) to identify the subframes carrying system information, which was a standard and necessary function in LTE systems for ensuring user equipment could properly receive the information.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because all three references operate in the same field of LTE system information transmission and address interrelated problems. The combination involved applying known techniques to yield predictable improvements in scheduling flexibility and system efficiency.

Ground 1B: Obviousness over Lee-746, Lee-668, R2-072183, and R2-071911 - Claims 3 and 23 are obvious over the combination of Ground 1A and R2-071911.

  • Prior Art Relied Upon: Lee-746 (Application # 2010/0167746), Lee-668 (Application # 2008/0285668), R2-072183 (3GPP TSG RAN WG2#58, May 2007), and R2-071911 (3GPP TSG-RAN WG2 Meeting #58, May 2007).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds R2-071911 to the base combination from Ground 1A to specifically address the limitations of claims 3 and 23, which require selecting a non-contiguous set of subframes. Petitioner argued that R2-071911 explicitly contemplates the possibility of scheduling segments of system information into non-contiguous subframes, particularly for very large SIBs that do not have strong delay requirements. This provides a clear teaching for the non-contiguous selection claimed.
    • Motivation to Combine: A POSITA would add the teaching of R2-071911 to the base combination to gain additional scheduling flexibility. This would allow the system to efficiently transmit large, delay-tolerant system information blocks in available non-contiguous slots, thereby preventing them from blocking more urgent, delay-intolerant unicast data transmissions that require consecutive subframes.
    • Expectation of Success: The combination was presented as a straightforward application of an alternative, known scheduling method to the base system to enhance its capabilities, with predictable results in improving network throughput and resource management.

Ground 1C: Obviousness over Lee-746, Lee-668, R2-072183, and Mukherjee - Claim 4 is obvious over the combination of Ground 1A and Mukherjee.

  • Prior Art Relied Upon: Lee-746 (Application # 2010/0167746), Lee-668 (Application # 2008/0285668), R2-072183 (3GPP TSG RAN WG2#58, May 2007), and Mukherjee (Application # 2007/0263528).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Mukherjee to the base combination to address claim 4's limitation of selecting subframes "in view of competing transmission priorities associated with other control or data signaling." Petitioner asserted that Mukherjee teaches a system for scheduling OFDM frames by ordering data packets based on multiple "scheduling metrics," which it equated with the claimed "competing transmission priorities." These metrics include deadlines, user priorities, and link conditions.
    • Motivation to Combine: A POSITA would be motivated to incorporate Mukherjee's advanced scheduling logic into the base system for transmitting system information. The goal would be to apply a well-known technique for optimizing resource allocation to improve overall system performance, such as by prioritizing transmissions based on radio conditions or conserving power for mobile devices.
    • Expectation of Success: Petitioner argued success would be expected, as it involved applying a known packet scheduling method to the specific type of data packet that is system information. The result would be a more efficient and robust network, which is a predictable outcome.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations incorporating Classon (Application # 2007/0064669) for claims related to varying window sizes, and R2-071762 (3GPP TSG-RAN WG2 #58, May 2007) for claims requiring different indicators for different types of system information. Further grounds relied on R2-071337 (3GPP TSG-RAN2 Meeting #57bis, Mar. 2007) for claims related to a mobile station's monitoring of the downlink channel.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be improper. A prior IPR filed by a different party on the ’357 patent (IPR2021-00450) was dismissed prior to institution and before a preliminary response was filed. Petitioner asserted that because the prior art and arguments in that petition were never evaluated on the merits, the Advanced Bionics test favors institution of the present IPR.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-10, 12, 14-17, and 19-24 of the ’357 patent as unpatentable.