PTAB

IPR2024-00819

Apple Inc v. Theta IP LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Power Dissipation Reduction in a Portable Wireless Communication Device
  • Brief Description: The ’164 patent discloses methods for reducing power dissipation in wireless transceivers for battery-powered devices. The invention focuses on dynamically adjusting the receiver's "dynamic range" by reducing circuit currents when operating conditions are better than the "worst-case" scenario (e.g., high desired signal and/or low interferers), thereby conserving battery life.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Behbahani in view of Leete and Tan.

  • Prior Art Relied Upon: Behbahani (“Adaptive Analog IF Signal Processor for a Wide-Band CMOS Wireless Receiver,” IEEE Journal of Solid-State Circuits, Aug. 2001), Leete (“A 2.4-GHz Low-IF Receiver for Wideband WLAN…,” IEEE Journal of Solid-State Circuits, Dec. 2000), and Tan (“A Broad-Band Tunable CMOS Channel-Select Filter…,” IEEE Journal of Solid-State Circuits, Apr. 2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Behbahani, Leete, and Tan taught every limitation of the challenged claims. Behbahani disclosed the core concept of an "adaptive dynamic range" method to save power in a wireless receiver by decreasing the dynamic range when signal conditions are better than worst-case. This is achieved through two techniques: a "step-based" dynamic range (DR) that switches between a high-power filter (for worst-case) and a low-power filter (for better-than-worst-case), and a "sliding DR" that adjusts gain. Petitioner asserted that switching from Behbahani's high-power filter to its low-power filter when interferer strength decreases meets the key claim limitations requiring dynamic adjustment of bias current and impedance. The petition contended that Leete, which describes a compatible RF front-end, provided the claimed amplifier and mixer elements to complete the receiver signal path. Tan, which is explicitly cited by Behbahani for filter design details, allegedly confirmed that switching between the scaled filters as taught by Behbahani necessarily involved increasing signal path impedance and reducing DC bias current, as the low-power filter inherently has higher resistance and lower bias current.
    • Motivation to Combine: Petitioner asserted a strong motivation to combine the references. Behbahani explicitly cited Tan for the details of its bandpass filter design. Further, Behbahani and Leete described different aspects of the same research project, were published by a largely overlapping team of authors, and were intended to be used conjunctively, with Leete describing the RF front-end and Behbahani describing the subsequent IF section. A POSITA would combine these references because they were expressly designed to function as a single, cohesive system.
    • Expectation of Success: A POSITA would have had a high expectation of success because the references were not disparate pieces of art but were explicitly cross-referenced and described complementary parts of the same receiver architecture.
    • Key Aspects: Petitioner highlighted that the sole inventor of the ’164 patent, in a January 2003 article, identified Behbahani’s switched filter process as an exemplary means of implementing "Dynamic Impedance Scaling," the very concept of adjusting impedance to save power that forms the basis of the challenged claims.

4. Key Claim Construction Positions

  • For the purpose of the IPR proceeding, Petitioner proposed adopting the Patent Owner's constructions for several key terms disputed in parallel district court litigation.
  • This included adopting the Patent Owner's broader construction of "signal path" (to include both analog and digital portions of the receiver) and its construction of the "dynamic" limitation (requiring only that an adjustment is made during operation based on information gained during operation).
  • Petitioner argued this approach would enhance judicial efficiency and demonstrate that the claims are unpatentable even under the Patent Owner's preferred interpretations.

5. Arguments Regarding Discretionary Denial

  • §325(d) Arguments: Petitioner argued against discretionary denial under 35 U.S.C. §325(d). Although Behbahani and Tan were cited on the face of the ’164 patent, Petitioner contended they were never substantively discussed or applied in a rejection by the Examiner. Leete was not before the Office at all. Petitioner asserted that the strength of the proposed ground demonstrates that the Examiner materially erred by not appreciating the combined teachings of these references.
  • §314(a) Arguments (Fintiv): Petitioner argued against discretionary denial under Fintiv factors, noting that it has stipulated it will not pursue in the parallel district court proceeding the same invalidity grounds raised in the petition, or any grounds that could have reasonably been raised, if the IPR is instituted.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 of 11,564,164 as unpatentable under 35 U.S.C. §103.