PTAB

IPR2022-01248

Samsung Electronics Co Ltd v. Smart Mobile Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Wireless Devices with Transmission Control and Multiple Paths of Communication
  • Brief Description: The ’653 patent describes techniques for improving data transmission speed in a wireless device by using multiple Internet Protocol (IP) based wireless transmissions simultaneously. The disclosed device uses multiple antennas, multiple transmit/receive units, and multiple processors to provide and manage multiple data paths between the wireless device and a server.

3. Grounds for Unpatentability

Ground 1A: Claims 14-16 are obvious over Yegoshin in view of Johnston and Billström

  • Prior Art Relied Upon: Yegoshin (Patent 6,711,146), Johnston (Patent 5,784,032), and Billström (Patent 5,590,133).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yegoshin taught a dual-mode (cellular and WLAN) mobile phone capable of IP communication over a WLAN, disclosing the basic hardware elements of claim 14. The proposed combination modified Yegoshin in two ways. First, it incorporated Johnston’s teaching of using multiple antennas (a three-way diversity antenna) for cellular communication to improve signal quality, thus teaching the limitation of a wireless component enabled to communicate using multiple antennas simultaneously. Second, it incorporated Billström’s teaching of using IP for packet data services over TDMA cellular networks. This addition allegedly rendered it obvious that Yegoshin's cellular interface would also be IP-enabled, thereby maintaining a first IP address for the cellular connection and a second for the WLAN connection.
    • Motivation to Combine: A POSITA would combine Johnston with Yegoshin to achieve the well-known benefits of antenna diversity, such as improved signal reliability in multipath fading environments, a problem Yegoshin aimed to solve. A POSITA would combine Billström with the Yegoshin/Johnston phone to implement efficient, IP-based packet data services over its cellular connection, extending data service coverage beyond the local area network (LAN).
    • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success because implementing known antenna diversity techniques (Johnston) and established IP-based cellular data protocols (Billström) in a dual-mode phone (Yegoshin) involved predictable applications of existing technologies.

Ground 1B: Claims 1-11, 17-21, and 23 are obvious over Yegoshin in view of Johnston, Billström, and Bernard

  • Prior Art Relied Upon: Yegoshin (Patent 6,711,146), Johnston (Patent 5,784,032), Billström (Patent 5,590,133), and Bernard (Patent 5,497,339).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Bernard to the combination from Ground 1A to teach the multiplexing limitations of independent claims 1 and 17. Petitioner argued that Bernard disclosed a "communication cradle" for a PDA that integrated multiple communication circuits (e.g., cellular, packet radio). Bernard’s cradle included a "communication server" that multiplexed data packets from these disparate networks into a single interface for applications on the PDA. This architecture, Petitioner contended, explicitly taught creating a single transmission interface comprised of multiplexed signals from a plurality of wireless components, as required by the claims.
    • Motivation to Combine: Yegoshin described its phone as becoming a "multi-purpose device" via an "adapter port" but provided no implementation details. A POSITA would have been motivated to look to references like Bernard to provide this multi-network functionality. Bernard’s cradle served as a concrete example of an adapter that could connect to Yegoshin's phone to manage and multiplex signals from different networks. Alternatively, Bernard’s software and hardware architecture could be integrated directly into the Yegoshin phone's circuitry.
    • Expectation of Success: The combination was allegedly predictable. A POSITA would understand that Bernard's cradle, which connects a device to multiple networks, was functionally analogous to the adapter Yegoshin suggested for expanding its phone's capabilities. Implementing Bernard’s well-defined multiplexing architecture, either externally or internally, to manage Yegoshin's dual cellular/WLAN connections was within the ordinary skill in the art.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the core Yegoshin/Johnston/Billström/Bernard combination, adding:

    • WO 98/27748 to teach a "network box" with multiple antennas for claim 12.
    • Sainton (Patent 5,854,985) to teach using a first processor for voice communication and a second processor for data communication for claims 13 and 24-26.
    • Preiss (Patent 6,031,503) to teach using multiple antennas for WLAN to achieve polarization diversity for claims 27-30.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The co-pending district court litigation was in its early stages with minimal investment, as claim construction and substantive discovery had not yet occurred. Petitioner noted that the district court trial date was scheduled to begin only about one month before the statutory deadline for a Final Written Decision (FWD) in the IPR, weighing against denial. Furthermore, Petitioner stipulated that it would cease asserting in the district court any invalidity contention based on the grounds presented in the petition if the Board institutes trial, thereby avoiding overlap and conserving judicial resources.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 and 23-30 of the ’653 patent as unpatentable.