PTAB

IPR2023-00793

American Honda Motor Co Inc v. Neo Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: METHOD AND SYSTEM FOR MULTI-CARRIER PACKET COMMUNICATION WITH REDUCED OVERHEAD
  • Brief Description: The ’450 patent discloses a resource allocation method for orthogonal frequency-division multiplexing (OFDM) communication systems. The invention aims to reduce control overhead by defining communication segments using "time-frequency resource units," where each segment is specified by a "starting time-frequency coordinate" and a number (N) of such units.

3. Grounds for Unpatentability

Ground 1: Obviousness over Vijayan089 and Laroia - Claims 1-5, 7-11, and 13-17 are obvious over Vijayan089 in view of Laroia.

  • Prior Art Relied Upon: Vijayan089 (Application # 2005/0058089) and Laroia (Application # 2005/0277429).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Vijayan089 teaches the core inventive concept by disclosing an OFDM system that allocates resources using time-frequency "transmission slots." Vijayan089 explicitly specifies an assigned resource segment using two parameters: "the start of the segment" (mapping to the claimed "starting time-frequency coordinate") and "the length of the segment" (mapping to the claimed "N time-frequency resource units"). Laroia was argued to supply the limitation of "assigning an identifier to the mobile station," as it describes assigning terminal-specific IDs in an OFDM system to allow wireless terminals to identify their own messages.
    • Motivation to Combine: A POSITA would combine Laroia with Vijayan089 to implement the "unicast communications" that Vijayan089 discloses but does not detail. Laroia provided a well-known technique for assigning identifiers to enable such targeted communication. This combination would predictably achieve the shared goal of both references: minimizing power consumption by allowing a device to process only its intended data stream.
    • Expectation of Success: Petitioner asserted a high expectation of success because both references describe conventional OFDM systems, and assigning device-specific identifiers was a ubiquitous and well-understood technique to improve such systems.

Ground 2: Obviousness over Vijayan475 and Wu - Claims 1-5, 7-11, and 13-17 are obvious over Vijayan475 in view of Wu.

  • Prior Art Relied Upon: Vijayan475 (Application # 2005/0141475) and Wu (Application # 2005/0063345).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Vijayan475, like Vijayan089, discloses allocating segments of time-frequency "slots" in an OFDM system. It defines these segments using a starting coordinate (via "Start Offset" and "Slot Info" parameters) and a number of units (via a "Stream Lengths" parameter), thereby teaching the core resource allocation method of the ’450 patent. To meet the identifier limitation, Petitioner cited Wu, which teaches assigning a "sixteen bit UE identifier" to user equipment so that each device can identify the specific OFDM slots scheduled for it.
    • Motivation to Combine: A POSITA would implement Wu's identifier system in Vijayan475's framework to enable the "unicast communications" disclosed by Vijayan475. This combination would improve the functionality of Vijayan475's system by providing a simple and known method for wireless devices to discern their specifically allocated resources from those allocated to other devices.
    • Expectation of Success: Success would have been expected, as the combination involved applying a standard technique (device identifiers) to a conventional OFDM system to achieve the predictable result of efficient, targeted communication.

Ground 3: Obviousness over Vijayan089, Laroia, and Choi - Claims 6, 12, and 18 are obvious over Vijayan089 and Laroia in view of Choi.

  • Prior Art Relied Upon: Vijayan089 (Application # 2005/0058089), Laroia (Application # 2005/0277429), and Choi (Application # 2005/0243774).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds upon the combination of Vijayan089 and Laroia from Ground 1 to address the additional limitation of "repetition coding" in claims 6, 12, and 18. Petitioner argued that Choi explicitly teaches enhancing data transmission by applying "repetition encoding" to OFDM symbols to improve "error correction" and provide a more robust transmission scheme. Choi discloses applying this technique in both the time and frequency domains.
    • Motivation to Combine: A POSITA would be motivated to add Choi's teachings to the Vijayan089/Laroia system to further the goal of robust communication. Vijayan089 already acknowledges the need for error correction by disclosing "forward error correction coding." Applying Choi's simple and well-known repetition coding technique was presented as an obvious way to further this objective and improve system performance.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in applying a known technique for improving signal robustness (repetition coding) to a standard OFDM communication system.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 6, 12, and 18 based on the combination of Vijayan475, Wu, and Choi, relying on a similar motivation to add repetition coding for improved error correction.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. Regarding discretionary denial under Fintiv, Petitioner contended that no trial date is scheduled in the parallel district court litigation, and any eventual trial would occur well after a Final Written Decision (FWD) from the Board. Petitioner also argued against denial for serial petitioning, noting this is its first inter partes review (IPR) of the ’450 patent and that a prior IPR filed by an unrelated third party (Dell Inc.) relied on different prior art and arguments. Finally, under §325(d), Petitioner argued that institution is strongly favored because the prior art references asserted in the petition are new, non-cumulative, and were never considered by the examiner during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’450 patent as unpatentable.