PTAB

IPR2022-01005

Samsung Electronics Co Ltd v. Smart Mobile Technologies LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Interfacing Internet Protocol-Based Wireless Devices With Networks
  • Brief Description: The ’291 patent discloses a wireless mobile device, such as a cellular telephone, equipped with multiple transmitters, receivers, and antennas. This configuration is intended to provide enhanced capabilities that allow the single device to perform communication tasks across different network environments.

3. Grounds for Unpatentability

Ground 1: Obviousness over Raleigh, Sainton, and Gernert - Claims 1-16 are obvious over Raleigh in view of Sainton and Gernert.

  • Prior Art Relied Upon: Raleigh (Patent 6,144,711), Sainton (Patent 5,854,985), and Gernert (Patent 6,600,734).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of these three references teaches every limitation of the challenged claims. Raleigh was asserted to disclose the foundational multi-antenna communication system, referred to as the "first communication component." Specifically, Raleigh teaches a multiple-input, multiple-output (MIMO) system that uses a substantially orthogonalizing procedure (SOP) to improve communication quality over wireless media, employing a base unit and remote units with multiple antennas.

    • To this base system, Petitioner argued a person of ordinary skill in the art (POSITA) would add the teachings of Sainton. Sainton discloses a frequency and protocol-agile "omni-modal circuit," implemented on a single chip or chipset, that functions as a "second communication component." This circuit enables a wireless device to operate across a variety of networks and standards, such as cellular (TDMA, CDMA), wireless LAN, and others, by switching between different protocols. Sainton also teaches separate processing for voice and data signals.

    • Finally, Gernert was argued to supply the remaining features, including an "adapter" or docking station. Gernert describes an apparatus that functions as a gateway to interface a mobile device with wired networks like a LAN or the Public Switched Telephone Network (PSTN). This apparatus provides a docking well for recharging the mobile device and transferring data via various ports, including a Universal Serial Bus (USB) port, and supports functionalities like Voice over IP (VoIP). The combination of these references, Petitioner contended, results in the system claimed in the ’291 patent.

    • Motivation to Combine: Petitioner asserted multiple motivations for the combination. A POSITA would combine Raleigh and Sainton because Raleigh suggests the advantage of using alternate frequency bands but fails to teach how to implement such capability. Sainton explicitly provides this missing element, teaching a multi-modal circuit designed for flexible operation across diverse networks. The combination would predictably yield a device with both the high-performance multi-antenna communication of Raleigh and the enhanced flexibility and geographical coverage of Sainton.

    • A POSITA would further combine this enhanced device with Gernert's gateway/docking station to add even more functionality. This step was presented as a predictable design choice to improve user convenience and expand connectivity. The combination would allow the powerful wireless device to interface with high-speed wired networks, gain VoIP capabilities, and benefit from the simplicity of a docking station for recharging and data synchronization.

    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in creating the combination. Sainton describes its omni-modal circuit as a "standard building block" designed for easy integration into consumer products. Furthermore, combining a portable device with a docking station to expand its capabilities was a well-established and understood technique in the art. The integration of these known elements to achieve their expected functions would have been a straightforward engineering task.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors would be inappropriate. The petition asserted that the parallel district court litigation was in its nascent stages, with minimal investment from the parties, as key events like claim construction and expert discovery had not yet occurred. Petitioner further noted that the scheduled trial date was over a year away and would occur after the statutory deadline for a Final Written Decision (FWD) in the inter partes review (IPR). Finally, Petitioner stipulated that if the IPR is instituted, it would not pursue the same invalidity grounds in the district court, thereby avoiding duplicative efforts and conserving judicial resources.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-16 of Patent 9,084,291 as unpatentable under 35 U.S.C. §103.