PTAB

IPR2022-01249

Samsung Electronics Co Ltd v. Smart Mobile Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless and Cellular Voice and Data Transmission with Multiple Paths of Communication
  • Brief Description: The ’946 patent describes a wireless communication device that uses multiple antennas, transmit/receive units, processors, and I/O ports to enable simultaneous, multiple Internet Protocol (IP) based wireless data transmissions between the device and a server.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Yegoshin, Johnston, and Billström - Claims 14-15 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 mobile phone capable of communicating over both a cellular network and a local area network (LAN) using IP. To meet the claim limitation of "at least two or more antennas," Petitioner asserted that modifying Yegoshin with Johnston’s teachings of a compact diversity antenna system was obvious. To meet the limitations related to multiple IP addresses and IP-based cellular communication, Petitioner relied on Billström, which taught using IP to provide packet data services in TDMA cellular systems. The combination allegedly rendered a mobile device with multiple antennas, processors, and wireless units that could communicate over separate IP addresses for its cellular and WLAN interfaces.
    • Motivation to Combine: A POSITA would combine Johnston with Yegoshin to achieve the well-known benefits of antenna diversity, such as improved signal quality and reliability in multipath fading environments, which aligned with Yegoshin's goal of improving signal quality. A POSITA would combine Billström's IP-based cellular packet data system with the Yegoshin/Johnston device to extend IP data services to the wide-area cellular network, thereby increasing the device's data coverage area beyond the local range of a WLAN.
    • Expectation of Success: Petitioner contended that combining these references involved applying established technologies (antenna diversity, IP over cellular) to a conventional dual-mode phone, which would yield predictable results and require only routine skill in the art.

Ground 1B: Obviousness over Yegoshin, Johnston, Billström, and Bernard - Claims 1-11 and 16-21 are obvious over the combination of Ground 1A in view of 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 adds Bernard to address claim limitations requiring a "single interface comprised of multiplexed signals" from multiple wireless units. Petitioner argued that Bernard disclosed a device cradle with multiple communication circuits (e.g., cellular, packet radio) that connect to a PDA. A "communication server" in the cradle multiplexes data packets from these different networks into a single serial interface for processing by applications on the PDA. This teaching, when applied to the base combination, allegedly met the multiplexed single interface limitation.
    • Motivation to Combine: Petitioner argued that while Yegoshin described a "multi-purpose device," it lacked specific implementation details for managing multiple communication paths. Bernard provided a concrete, obvious solution for this by teaching how to multiplex data from different network sources into a single channel. A POSITA would integrate Bernard’s functionality either by connecting a cradle-like adapter to Yegoshin's phone or by incorporating Bernard's multiplexing circuitry directly into the phone to manage its dual cellular and WLAN connections.
    • Expectation of Success: The technologies were compatible, and the combination would predictably result in a device capable of robustly managing multiple network connections. The modification was well within the skill of a POSITA.

Ground 1D: Obviousness over Yegoshin, Johnston, Billström, Bernard, and Sainton - Claims 13 and 26 are obvious over the combination of Ground 1B in view of Sainton.

  • Prior Art Relied Upon: The combination of Ground 1B, plus Sainton (Patent 5,854,985).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Sainton to address claims requiring separate processors for voice and data communication. Petitioner asserted that Sainton explicitly taught an "omni-modal circuit" for mobile phones that included separate "voice processing circuitry" and "data processing circuitry." This was to optimize performance based on the distinct characteristics of voice (low-latency) and non-voice (delay-tolerant) data.
    • Motivation to Combine: Yegoshin recognized the different requirements for "voice-data" and "data-data" but did not specify how to handle them. Sainton provided an obvious and well-known solution: using dedicated processors for each data type. A POSITA would be motivated to incorporate Sainton's design to improve efficiency, reduce power consumption, and enhance the performance of the multi-network device from the base combination.
    • Expectation of Success: Petitioner argued that Sainton described its circuit as a "standard building block" for communication devices, making its integration into the combined device straightforward and its results predictable.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including Ground 1C (adding WO748 to the Ground 1B combination to teach communication with a network box in a distributed antenna system) and Ground 1E (adding Preiss to the Ground 1B combination to teach polarization diverse antennas for the WLAN interface).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv was unwarranted. The co-pending district court litigation was in its early stages, with minimal investment from the parties and no claim construction hearing having occurred. While the trial date was scheduled near the FWD deadline, it remained over a year away. Petitioner also stipulated that if the IPR is instituted, it would not pursue the same invalidity grounds in the district court, thus avoiding overlapping issues and conserving judicial resources.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 and 26-30 as unpatentable.