PTAB

IPR2024-00820

Apple Inc v. Theta IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Power Dissipation Reduction in Wireless Receivers
  • Brief Description: The ’210 patent discloses methods for reducing power dissipation and extending battery life in portable wireless devices. It achieves this by dynamically adjusting a receiver's dynamic range based on signal conditions, thereby reducing power consumption when operating conditions are better than a "worst-case" scenario of a weak desired signal and strong interferers.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5-6, and 8-11 are obvious over Behbahani in view of Tan.

  • Prior Art Relied Upon: Behbahani (a 2001 IEEE Journal article on an adaptive analog signal processor) and Tan (a 2000 IEEE Journal article on a tunable CMOS channel-select filter).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Behbahani teaches the core inventive concept: a wireless receiver that implements an "adaptive dynamic range" method to save power. Behbahani's system operates in a high-power mode for worst-case conditions (low desired signal, high interferers) and switches to a distinct low-power mode for better conditions. This switch is triggered by measurements of the desired signal and interferer levels. While Behbahani describes the high-level system, it explicitly cites Tan for the specific details of its bandpass filter design.

    • Tan provides the missing implementation details, disclosing scaled Gm-C filters that correspond to Behbahani’s high-power and low-power modes. The combination allegedly teaches all key limitations. When transitioning from the high-power filter to the low-power filter (as conditions improve), Tan's design shows that: (1) signal path impedance is dynamically increased, (2) the noise floor is raised, (3) DC bias current is reduced, and (4) drive currents are reduced. This combination of teachings allegedly renders the various scenarios recited in the independent claims (e.g., claim 1, claim 6, claim 10) obvious. For instance, Behbahani's switch to the low-power filter when the desired signal is strong meets the conditions of claim 1, as the switch increases impedance and reduces drive current. The same switch also reduces DC bias current, anticipating limitations in claim 6.

    • Motivation to Combine: A POSITA would combine Behbahani and Tan because Behbahani expressly cites Tan as providing the specific design details for the filters used in its adaptive system. Petitioner asserted this creates a clear and explicit motivation to read the references together, as they describe different aspects of the same receiver research.

    • Expectation of Success: A POSITA would have a high expectation of success in combining the references. Tan provides the detailed circuit-level implementation for the conceptual system described in Behbahani, effectively completing the design with well-understood filter scaling techniques.

    • Key Aspects: Petitioner highlighted that the inventor of the ’210 patent, in a separate 2003 article, identified Behbahani’s switched filter approach as an exemplary method for achieving "Dynamic Impedance Scaling" to save power, which Petitioner characterized as a significant admission.

4. Key Claim Construction Positions

  • For the purposes of the IPR proceeding, Petitioner proposed adopting the Patent Owner’s constructions for several key terms from parallel district court litigation to enhance judicial efficiency.
  • "Signal path": Petitioner adopted the Patent Owner's broader construction that the signal path can include both analog and digital portions of the receiver.
  • "Dynamically changing/adjust[ing]": Petitioner adopted the Patent Owner’s position that this limitation only requires that an adjustment is made during operation based on information gained during operation, without excluding reliance on a signal strength threshold.
  • Petitioner argued that its proposed grounds render the claims obvious even under the Patent Owner's broader interpretations of these key terms.

5. Arguments Regarding Discretionary Denial

  • §325(d) Discretionary Denial: Petitioner argued that denial under 35 U.S.C. §325(d) is unwarranted. Although the Behbahani and Tan references were cited on an Information Disclosure Statement (IDS) during prosecution, the Examiner never discussed them or applied them in any rejection. Petitioner contended that the Examiner, therefore, did not substantively consider the teachings of these references in combination, and the strength of the proposed ground demonstrates a material error by the Patent Office.
  • Fintiv Factors / §314(a) Discretionary Denial: Petitioner argued against discretionary denial under 35 U.S.C. §314(a) based on the Fintiv factors. Petitioner stipulated that, if the IPR is instituted, 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. Petitioner asserted that this stipulation mitigates any concerns about duplicative efforts and weighs heavily in favor of institution.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-3, 5-6, and 8-11 of the ’210 patent as unpatentable.