PTAB

IPR2024-00094

Inergy Technology Inc v. Force MOS Technology Co Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and system for managing context information in a wireless communication system
  • Brief Description: The ’143 patent describes methods for managing user equipment (UE) context information during handovers between different Radio Access Technologies (RATs), specifically from a newer Evolved-UTRAN (E-UTRAN) to an older UTRAN/GERAN. The claimed invention focuses on storing the UE's E-UTRAN context at a network node and using a temporary identity assigned by the older network to later retrieve this context when the UE returns to the E-UTRAN.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Standards - Claims 1-4, 6-12, and 14-20 are obvious over SAE System Architecture in view of GPRS Enhancements.

  • Prior Art Relied Upon: 3GPP TS 36.300 V8.3.0 ("SAE System Architecture") and 3GPP TS 23.401 V8.4.0 ("GPRS Enhancements").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that SAE System Architecture, a foundational specification for the LTE network architecture, disclosed all key elements of the claimed system, including a Mobility Management Entity (MME) that stores UE context information. This context includes security information and bearer information. GPRS Enhancements, a complementary specification detailing inter-system procedures, explicitly taught the process for handovers between E-UTRAN and UTRAN/GERAN, including the use of temporary identities like the Packet-Temporary Mobile Subscriber Identity (P-TMSI) in the target legacy network. Petitioner argued the combination disclosed receiving a request from a UE to re-establish a connection in the E-UTRAN using this temporary identity, which the MME then uses to retrieve the stored UE context.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) developing inter-RAT mobility procedures for an LTE system would have been directly motivated to combine the teachings of these two specifications. SAE System Architecture provided the high-level system design, while GPRS Enhancements provided the necessary detailed procedures for that system to interoperate with legacy networks. The standards were developed concurrently by the same standards body (3GPP) and were intended to be used together to create a functional wireless system.
    • Expectation of Success: A POSITA would have had a high expectation of success because the references were designed as complementary parts of a single, coherent 3GPP system architecture. Combining them represented the intended implementation of standardized inter-RAT mobility.

Ground 2: Obviousness over 3GPP Standard and Ericsson Contribution - Claims 1-4, 6-12, and 14-20 are obvious over SAE System Architecture in view of Ericsson.

  • Prior Art Relied Upon: SAE System Architecture (3GPP TS 36.300 V8.3.0) and Ericsson (R2-075304, a 3GPP technical contribution titled "Idle mode mobility between E-UTRAN and UTRAN/GERAN").

  • Core Argument for this Ground:

    • Prior Art Mapping: As in Ground 1, Petitioner argued SAE System Architecture disclosed the fundamental network architecture and context storage at the MME. The Ericsson contribution, submitted during the development of the LTE standards, specifically addressed the problem of managing UE context during idle mode mobility between E-UTRAN and older UTRAN/GERAN systems. Ericsson explicitly proposed mapping the UE's temporary identity from the E-UTRAN (the S-TMSI) to the legacy network's temporary identity (P-TMSI) to maintain a link to the UE's context. This mapping directly taught the claimed concept of using a temporary ID from the legacy network to retrieve the stored E-UTRAN context upon the UE's return.
    • Motivation to Combine: A POSITA tasked with implementing the architecture of SAE System Architecture would naturally look to technical contributions like Ericsson for detailed solutions to known technical challenges, such as inter-RAT mobility. Ericsson was a direct proposal for how to handle the exact scenario claimed in the ’143 patent. The motivation was to solve the known problem of seamless mobility between new and legacy networks using a proposed, practical solution.
    • Expectation of Success: The expectation of success would have been high. Ericsson was a technical proposal from a major industry participant intended for incorporation into the 3GPP standards. It provided a clear and logical solution to a recognized problem within the established framework of the SAE System Architecture.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of SAE System Architecture with other 3GPP contributions like Motorola (R2-075035), which similarly disclosed solutions for inter-RAT context management and the use of temporary identities.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) and the Fintiv factors would be inappropriate. Petitioner contended that the co-pending district court litigation was in its early stages, with no trial date set and claim construction not yet underway. Furthermore, Petitioner asserted that the invalidity grounds presented in the IPR are exceptionally strong, relying on foundational 3GPP standards that defined the very technology at issue. It argued that instituting the IPR would be a more efficient and effective way to resolve the patentability questions, serving the public interest by canceling claims that should not have been granted.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-4, 6-12, and 14-20 of the ’143 patent as unpatentable under 35 U.S.C. §103.