PTAB

IPR2024-00606

Samsung Electronics America Inc v. Cobblestone Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Transmitting Information in a Wireless Communication Channel
  • Brief Description: The ’802 patent relates to a method of multi-carrier transmission where information is transmitted simultaneously over at least two distinct frequency ranges using a single wireless transmitter. The technology also discloses systems and methods for generating the multi-carrier signal using standard components and for receiving and down-converting the signal.

3. Grounds for Unpatentability

Ground 1: Obviousness over a Single Multi-Carrier Reference - Claim 1 is obvious over Rick

  • Prior Art Relied Upon: Rick (Patent 8,693,525).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rick, a Qualcomm patent, discloses all limitations of claim 1. Rick teaches a "multi-carrier transmitter" capable of transmitting multiple CDMA signals "simultaneously" on different frequency channels. Petitioner asserted that Rick's disclosure of transmitting a first CDMA signal on a first channel and a second CDMA signal on a second channel, via a single antenna, directly maps to the claim's requirement of simultaneously transmitting first and second information across first and second frequency ranges using the same wireless transmitter.
    • Motivation to Combine: Not applicable as this is a single-reference ground. The argument is that Rick's own system anticipates or makes obvious the claimed method.
    • Expectation of Success: Not explicitly argued, as success is inherent in Rick’s disclosure of a functioning system.

Ground 2: Obviousness over a Multi-Band Predistorter System - Claims 1-4, 6-8, 10, 13, 17, 21-22, and 24 are obvious over Suzuki

  • Prior Art Relied Upon: Suzuki (Application # 2006/0276146).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Suzuki, an NTT Docomo application for a multi-band predistorter, teaches the simultaneous transmission of a signal containing "dual frequency bands" (FB1 and FB2), as shown in its Figure 13A. This was argued to meet the limitations of independent claim 1. For the apparatus and detailed method claims (10 and 17), Petitioner mapped Suzuki's system architecture, including its use of lookup tables, digital-to-analog converters (DACs), up-converters, a combiner, and a single power amplifier, to the claimed elements for generating the multi-carrier signal. Dependent claims related to non-overlapping frequencies (claim 2) and using a single power amplifier (claim 3) were also alleged to be disclosed by Suzuki's system, which explicitly teaches amplification by a "common power amplifier."
    • Motivation to Combine: Not applicable as this is a single-reference ground.
    • Expectation of Success: Inherent in Suzuki's detailed disclosure of a system designed to handle multi-band signals.

Ground 3: Obviousness over Combined Signal Generator and Amplifier References - Claims 1-4, 6-8, 10, 13, 17, 21-22, and 24 are obvious over Fernandez and Montojo

  • Prior Art Relied Upon: Fernandez (Application # 2009/0052556) and Montojo (Application # 2005/0135312).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Fernandez discloses a system for creating multi-carrier wireless signals by summing the outputs of multiple individual signal generators. While Fernandez teaches that each signal path includes its own amplification, Montojo teaches a multi-carrier transmitter that uses a single, shared power amplifier. The combination was argued to render the full scope of the independent claims obvious.
    • Motivation to Combine: A POSITA would combine Montojo's single power amplifier with Fernandez's multi-carrier generation system to achieve well-known and predictable benefits. Montojo explicitly teaches that using a single amplifier is "advantageous" over multiple amplifiers to overcome "limitations on space, manufacturing cost, power consumption and other factors." This provides a clear, articulated reason to modify Fernandez's system.
    • Expectation of Success: A POSITA would have reasonably expected success because using a single amplifier for multi-carrier signals was a well-known design choice, and both references are directed to the same field of endeavor.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations based on Suzuki and Fernandez/Montojo with secondary references. These included:

    • Suzuki/Fernandez in view of Jalali (Patent 6,952,454): To teach the use of OFDM symbols and time-division multiplexing (claims 9, 23).
    • Suzuki/Fernandez in view of Chen (Patent 6,359,868): To teach a corresponding receiver with a low-noise amplifier and down-converters (claims 14, 24-25).
    • Suzuki/Fernandez in view of Etemad (Patent 8,036,702): To teach using different wireless protocols like Time Division Duplex (TDD) and Frequency Division Duplex (FDD) on different carriers (claims 6, 13, 21).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is not warranted. The parallel district court litigation was described as being in a very early stage, with no claim construction hearing scheduled, no depositions taken, and only preliminary discovery exchanged. Petitioner asserted that it filed the IPR petition diligently (approximately eight months after being served with the complaint) and that the strong merits of the invalidity grounds weigh heavily in favor of institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-10, 13, 14, 17, and 21-25 of Patent 7,924,802 as unpatentable.