PTAB

IPR2022-00343

Apple Inc v. Telefonaktiebolaget LM Ericsson

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Link Quality Estimation and Apparatus in a Telecommunication System
  • Brief Description: The ’432 patent describes a method for improving link quality estimation in a wireless system to support dynamic link adaptation. The method involves a sending node (e.g., base station) transmitting a "measurement adjusting parameter" to a receiving node (e.g., mobile phone), which then uses this parameter to adjust its measured channel properties before sending a channel state information (CSI) report back to the sending node.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Standards - Claims 1-2, 4-7, 9-12, 14-16, and 18 are obvious over [TS-25.331](https://ai-lab.exparte.com/case/ptab/IPR2022-00343/doc/1004) in view of [TS-25.214](https://ai-lab.exparte.com/case/ptab/IPR2022-00343/doc/1005).

  • Prior Art Relied Upon: TS-25.331 (3rd Generation Partnership Project (3GPP) Technical Specification, Mar. 2007), and TS-25.214 (3GPP Technical Specification, Mar. 2007).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of two complementary 3GPP standards for Universal Mobile Telecommunications System (UMTS) technology taught the key limitations of the independent claims. Specifically, TS-25.331 disclosed the higher-layer Radio Resource Control (RRC) protocol for sending a "Measurement Power Offset" (MPO) parameter to user equipment (UE). TS-25.214 disclosed the physical layer procedures where this MPO is used to adjust a measured power of a pilot channel (CPICH) to calculate an assumed power for the data channel. This adjusted value is then used to determine a Channel Quality Indicator (CQI), which is included in a CSI report sent back to the network to enable link adaptation.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine these standards because they are part of the same 3GPP release (Release 7), are intended to work together, and explicitly cross-reference one another for implementation details. TS-25.331 directs a POSITA to TS-25.214 for details regarding the MPO.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as the standards were designed to be implemented together to create a functioning UMTS communication system, yielding the predictable result of improved link quality reporting.

Ground 2: Obviousness over 3GPP Standards with MIMO Enhancements - Claims 3, 5-10, 13, and 15-18 are obvious over TS-25.331 and TS-25.214, further in view of [R1-074426](https://ai-lab.exparte.com/case/ptab/IPR2022-00343/doc/1006) and [Sampath](https://ai-lab.exparte.com/case/ptab/IPR2022-00343/doc/1007).

  • Prior Art Relied Upon: TS-25.331, TS-25.214, R1-074426 (3GPP Meeting Notes, Oct. 2007), and Sampath (Patent 8,971,461).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims requiring the derivation and reporting of a "rank indicator" for Multiple-Input Multiple-Output (MIMO) systems. While the base standards (TS-25.331 and TS-25.214) introduced MIMO, Petitioner argued they lacked explicit implementation details for rank selection. R1-074426, a 3GPP contribution, and Sampath were alleged to supply these missing details. R1-074426 taught calculating a "rank suggestion" at the UE and including it in the CSI report to inform the network of the appropriate CQI format. Sampath disclosed a method for performing optimal rank selection based on an effective Signal-to-Noise Ratio (SNR) and subsequently transmitting both the CQI and rank information back to the network.
    • Motivation to Combine (for §103 grounds): A POSITA implementing the MIMO features of the base standards would be motivated to consult references like R1-074426 and Sampath for implementation details on how to compute and report rank. These references provided well-known methods to optimize MIMO performance, a key goal of the 3GPP standards, by providing specific algorithms and procedures for rank feedback that the base standards left open to the implementer.
    • Expectation of Success (for §103 grounds): Combining these references would predictably result in a more robust and efficient MIMO communication system by incorporating explicit rank feedback, which was a known technique for improving system performance.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Wintzell (Application # 2005/0003782) in view of Catreux-Erceg (Patent 7,876,808) for claims 1-2, 4-7, 9-12, 14-16, and 18 (Ground 2A), and the same combination with the further addition of Sampath for claims 3, 5-10, 13, and 15-18 (Ground 2B). These grounds relied on similar theories but used alternative prior art disclosing power offset calculations for link quality estimation.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) or §325(d) would be inappropriate. The petition asserted that no parallel proceedings existed and that none of the prior art applied in the petition had been considered in any prior review of the ’432 patent.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-18 of Patent 9,300,432 as unpatentable.