Samsung Electronics Co Ltd v. G+ Communications LLC

1. Case Identification

• Case #: IPR2022-01598
• Patent #: 10,594,443
• Filed: October 4, 2022
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): G+ Communications, LLC
• Challenged Claims: 1-2, 6, 8-11, 15, 17, and 18

2. Patent Overview

• Title: Method and Apparatus for Transmitting HARQ Information, Method and Apparatus for Receiving HARQ Information, and Node
• Brief Description: The ’443 patent describes methods and systems for wireless communication, specifically for transmitting Hybrid Automatic Repeat Request (HARQ) feedback. The technology involves a first node (e.g., user equipment) generating HARQ information of M bits to report the status of N transmission blocks received from a second node (e.g., a base station), where a subset of M2 bits indicates the positions of k erroneous blocks.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 6, 8-11, 15, 17, and 18 are anticipated by Kannan under 35 U.S.C. §102.

• Prior Art Relied Upon: Kannan (Application # 2016/0233999). Petitioner established that Kannan qualifies as prior art by claiming the benefit of a provisional application filed February 5, 2015, which predates the ’443 patent's earliest effective priority date.
• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Kannan discloses every limitation of the challenged claims. Independent claim 1 recites a method at a first node for transmitting HARQ information. Petitioner asserted that Kannan’s disclosure of a user equipment (UE) generating and transmitting ACK/NACK feedback for received code blocks (CBs) directly maps to this claim. Petitioner contended a POSITA would understand Kannan’s “code blocks” to be the claimed “transmission blocks.” Kannan’s Figure 4B illustrates an ACK/NACK format (the “HARQ information”) composed of M total bits. This format includes a first field (M1 bits) indicating the number of erroneous CBs (k) and a second field (M2 bits) providing an index to identify the specific combination of CBs in error. Petitioner argued this structure meets the claim limitation that M2 bits indicate the positions of k erroneous blocks. Crucially, Kannan explicitly teaches that the number of bits for this index (M2) is a function of k (specifically, log2(N choose k)), which Petitioner asserted directly teaches the claimed “second length type” where the value of M2 is determined based on k.

  • For independent claim 8 (a reciprocal method at a second node), Petitioner mapped Kannan’s base station, which receives and decodes the ACK/NACK feedback from the UE, to the claimed limitations. For apparatus claims 10 and 17 (reciting a “node”), Petitioner pointed to Kannan’s disclosure of UEs and base stations that include processors and memory configured to perform the claimed functions. Dependent claims were argued to be anticipated by Kannan’s additional disclosures, such as configuring the ACK/NACK format via radio resource control (RRC) signaling (claims 2, 9, 11, 18) and using a portion of the HARQ bits (M1) to indicate the value of k (claims 6 and 15).

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under the Fintiv factors would be inappropriate. The core arguments were:
  • The parallel district court proceeding was in its early stages, with minimal investment by the parties and the court.
  • The median time-to-trial in the Eastern District of Texas is over 24 months, meaning a trial would likely occur after the projected date for a Final Written Decision (FWD) in the inter partes review (IPR).
  • Petitioner stipulated that, if the IPR is instituted, it would not pursue the same invalidity grounds in the district court, thereby avoiding overlap and conserving judicial resources.
  • The merits of the petition are strong, which weighs against denial.

5. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1-2, 6, 8-11, 15, 17, and 18 of the ’443 patent as unpatentable.