AT&T Corp v. Daingean Technologies Ltd

1. Case Identification

• Case #: IPR2024-00402
• Patent #: 10,841,958
• Filed: January 8, 2024
• Petitioner(s): AT&T Mobility LLC, AT&T Services Inc., Ericsson Inc., Nokia of America Corporation, and T-Mobile USA, Inc.
• Patent Owner(s): Daingean Technologies Ltd.
• Challenged Claims: 1-4

2. Patent Overview

• Title: Efficient Transmission of System Information Blocks
• Brief Description: The ’958 patent relates to techniques for efficiently transmitting system information blocks (SIBs) in wireless communication networks. The disclosed method involves an access node that distinguishes between a "first type" of essential system information required for initial network access, which is always broadcast, and a "second type" of non-essential information, which is initially provided on-demand but switches to being broadcast after it has been changed or updated.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 are Anticipated and/or Obvious over Lee

• Prior Art Relied Upon: Lee (Application # 2019/0158988).
• Core Argument:
  • Prior Art Mapping: Petitioner argued that Lee anticipates or renders obvious every limitation of the challenged claims. Lee was asserted to describe a wireless system where an access node (base station) communicates with a terminal (UE) using different types of SIBs. Petitioner mapped Lee’s SIB1, which contains information for cell access and scheduling for other SIBs, to the claimed "first type SIB." Other on-demand SIBs in Lee were mapped to the "second type SIB." Lee’s disclosure of a "value tag" in its essential system information to indicate changes to other on-demand information was argued to meet the corresponding claim limitation. Critically, Petitioner contended that Lee explicitly teaches that when on-demand system information changes, the network "may broadcast the changed system information," directly teaching the claimed feature of switching a second type SIB from on-demand to broadcast after a change. Claims 2 and 4 were argued to be met by Lee's disclosure of broadcasting the changed system information, and claims 3 and 4 were addressed as method claims corresponding to the apparatus claims 1 and 2.
  • Motivation to Combine (for §103 grounds): To the extent any limitation was not explicitly disclosed, Petitioner argued that a person of ordinary skill in the art (POSITA) would have been motivated to modify Lee’s system for predictable results. For example, a POSITA would understand that for a UE to receive the newly broadcast information, the essential "first type SIB" would need to include an indication that the changed information is now being broadcast. This modification was presented as a simple and predictable design choice to ensure system functionality.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success in implementing any minor modifications to Lee's system, as it would involve applying known signaling principles in a wireless network to achieve a more efficient update mechanism, a well-understood goal in the art.

Ground 2: Claims 1-4 are Anticipated and/or Obvious over Brismar

• Prior Art Relied Upon: Brismar (Application # 2015/0382284).
• Core Argument:
  • Prior Art Mapping: Petitioner argued that Brismar similarly discloses the claimed invention. Brismar was shown to teach a system that distinguishes between "static" system information (mapped to the "first type SIB") and "dynamic" system information (mapped to the "second type SIB"). The static information, necessary for initial network access, is broadcast and includes a "value tag" to indicate when dynamic information has changed. Brismar further discloses that dynamic information can be provided via broadcast or through on-demand requests from a UE. Petitioner argued that when a value tag change occurs, Brismar’s teaching that a UE can monitor an "SI distribution in progress flag" inherently discloses the broadcast of the changed, previously on-demand dynamic SIB. This mechanism was asserted to meet the core limitation of including information in the first SIB indicating that the second SIB is now provided by broadcast.
  • Motivation to Combine (for §103 grounds): In the alternative, Petitioner argued it would have been obvious to a POSITA to modify Brismar’s system to function as claimed. A POSITA would recognize that upon a change to the dynamic SIB, broadcasting it is a highly efficient method for updating multiple UEs. Therefore, explicitly indicating in the static SIB that the updated information is now being broadcast would be an obvious and logical implementation to ensure UEs know to listen for the broadcast rather than initiating individual on-demand requests, thereby improving network efficiency.
  • Expectation of Success: A POSITA would have expected success in implementing this functionality, as it represents a straightforward application of established principles for managing system information distribution in wireless networks.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) would be inappropriate. The basis for this argument was that the primary prior art references asserted in the petition, Lee and Brismar, were never cited by the Examiner nor included in an Information Disclosure Statement (IDS) during the original prosecution of the ’958 patent. Therefore, the Examiner never considered the specific teachings and arguments presented in the petition.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-4 of the ’958 patent as unpatentable.