AT&T Corp v. Daingean Technologies Ltd

1. Case Identification

• Case #: IPR2024-00310
• Patent #: 10,932,207
• Filed: March 5, 2024
• Petitioner(s): AT&T Mobility LLC, AT&T Services, Inc., Ericsson Inc., Nokia of America Corporation, T-Mobile USA, Inc.
• Patent Owner(s): Daingean Technologies Ltd.
• Challenged Claims: 4-6 and 8

2. Patent Overview

• Title: Methods and systems for efficiently performing a random access procedure in a radio communications system.
• Brief Description: The ’207 patent discloses a base station that controls both a 2-step and a 4-step contention-based random access procedure for wireless devices. The invention focuses on configuring the transmission power for a random access preamble based on distinct power control parameters for each procedure type.

3. Grounds for Unpatentability

Ground 1: Claims 4-6 and 8 are Anticipated and/or Obvious over Lee1

• Prior Art Relied Upon: Lee1 (Application # 2017/0019930).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Lee1, which aims to reduce latency in random access procedures, discloses every element of the challenged claims. Independent claim 4 requires a base station with control circuitry for both 2-step and 4-step contention-based random access, reception circuitry for receiving a preamble in either procedure, and a method for calculating transmission power based on a PREAMBLE_RECEIVED_TARGET_POWER. Petitioner asserted Lee1 explicitly teaches a base station controlling both procedure types and uses an identical, industry-standard power ramping formula based on preambleInitialReceivedTargetPower and powerRampingStep. Because preamble transmission is the first step of both procedures in Lee1, Petitioner contended the power control formula inherently applies to both, thereby anticipating the claim. Dependent claims 5 (parameters given by radio resource control) and 6 (defining power ramping step as a step size) were also argued to be expressly taught by Lee1.
  • Motivation to Combine (for §103 alternative): In the alternative, Petitioner argued it would have been obvious to a person of ordinary skill in the art (POSITA) to apply the power ramping technique disclosed in Lee1 to both the 4-step and the newly introduced 2-step random access procedures. Since power ramping was a standard technique for managing preamble transmission, a POSITA would have naturally applied it to the 2-step procedure to ensure connection reliability and energy efficiency.
  • Expectation of Success: A POSITA would have a high expectation of success, as applying a standard power control method to a random access procedure was a well-understood and predictable process in wireless communications.

Ground 2: Claims 4-6 and 8 are Obvious over Lee1 in view of Lee2

• Prior Art Relied Upon: Lee1 (Application # 2017/0019930) and Lee2 (Application # 2010/0255847).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative in case the Patent Owner successfully argued that the claims require different power control parameters for the 2-step and 4-step procedures. Petitioner asserted that Lee1 provides the primary framework of a base station managing both procedure types. Lee2 teaches using different transmission power parameters (e.g., initial power, ramping step) for different random access "events" or "cases" (such as handover vs. connection re-establishment) to optimize performance and reduce delay. Petitioner argued a POSITA would combine these teachings by applying Lee2's concept of case-dependent parameters to Lee1's system. This would result in using one set of power parameters (preambleInitialReceivedTargetPower(0), powerRampingStep(0)) for the 4-step procedure and a different set (preambleInitialReceivedTargetPower(1), powerRampingStep(1)) for the 2-step procedure, directly mapping to the claim limitations.
  • Motivation to Combine: The primary motivation was to further reduce latency and enhance system performance, a shared goal of both references. A POSITA would combine Lee1's method of reducing procedural steps with Lee2's method of optimizing power parameters for different scenarios. Specifically, to achieve the low-latency goal of the 2-step procedure, a POSITA would be motivated to use more aggressive power parameters (e.g., a higher initial power or larger ramping step) for it compared to the standard 4-step procedure, as taught by Lee2's optimization principles.
  • Expectation of Success: A POSITA would have a high expectation of success in combining the references. Both relate to power control for random access in wireless systems, and applying case-specific parameters to different but related procedures was a known design choice for improving network efficiency.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is inappropriate. The argument was based on the fact that the primary prior art references, Lee1 and Lee2, were never presented to, or considered by, the patent examiner during the original prosecution of the ’207 patent. Therefore, the petition raised new arguments and art that the Patent Office had not previously evaluated.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 4-6 and 8 of Patent 10,932,207 as unpatentable.