PTAB

IPR2024-00897

Samsung Electronics Co Ltd v. Empire Technology Development LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Decoding a Signal Using Replicated Data
  • Brief Description: The ’331 patent discloses methods and devices for decoding signals in a wireless communication system. The technology involves using replicated payload data, transmitted across multiple data streams, as a form of pilot symbol to generate or update an estimate of the channel matrix, thereby aiming to reduce overhead associated with dedicated pilot symbols.

3. Grounds for Unpatentability

Ground 1: Obviousness over Haustein - Claims 1-8 are obvious over Haustein.

  • Prior Art Relied Upon: Haustein (European Patent Application Publication No. EP 2114029).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Haustein teaches all limitations of the challenged claims. Haustein discloses improving channel estimation by transmitting certain payload data with "additional redundancy" (i.e., replicated data) in a first transmission. Although this data is initially unknown, its high redundancy ensures it can be successfully decoded. If a retransmission is required, this now-decoded data is treated as "known data" or "pseudo pilot" signals, which, along with original pilot symbols, are used to generate an updated and more accurate channel estimate for decoding the retransmitted signals.
    • Motivation to Combine (for §103 grounds): N/A (Single reference ground).
    • Expectation of Success (for §103 grounds): N/A (Single reference ground).
    • Key Aspects: Petitioner contended that Haustein’s use of pre-designated, high-redundancy payload data as "pseudo pilots" for updating channel estimates in a subsequent transmission directly maps onto the ’331 patent's core concept of using replicated data for channel estimation.

Ground 2: Obviousness over Ban in view of Wang - Claims 1-8 are obvious over Ban in view of Wang.

  • Prior Art Relied Upon: Ban (Application # 2008/0222482) and Wang (Application # 2002/0003774).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Ban discloses replicating data for use in channel estimation, and Wang provides the motivation to apply this technique across multiple data streams. Ban teaches a method to extend the cyclic prefix of a data block by copying data symbols from a preceding block; it explicitly states this technique can be applied to a block of pilot symbols, where some pilots are replaced by copied data symbols. Because these copied symbols are known from the preceding block’s demodulation, they can be used for channel estimation. Wang teaches using space-time coding (specifically, Alamouti coding) to transmit a data stream over two separate, spatially diverse streams to improve transmission quality, thereby teaching the "multiple data streams" limitation.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Ban and Wang to improve the overall reliability of the communication system. A POSITA implementing Ban’s technique for improving decoding reliability would have been motivated to incorporate Wang’s well-known space-time diversity technique to further guard against fading and other channel impairments.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success, as combining a data replication technique with a standard spatial diversity technique was a predictable implementation of known methods to enhance signal robustness.

Ground 3: Obviousness over Tang - Claims 1-8 are obvious over Tang.

  • Prior Art Relied Upon: Tang (L. Tang & M. A. Abu-Rgheff, Joint Pilot-Aided and Blind Decision-Directed Channel Estimation for MIMO-OFDM System, 2007 IEEE Symposium).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tang, a single reference, discloses every element of the challenged claims. Tang describes a "joint pilot-aided and blind decision-directed channel estimation" scheme for a MIMO-OFDM system. It teaches inserting data symbols (using a space-frequency block code format, which inherently replicates data across antennas) between adjacent pilot sub-carriers. At the receiver, these inserted data symbols are first decoded using an initial channel estimate derived from the pilots. The decoded data symbols are then treated as "extra 'pilot symbols'" to generate a new, "enhanced" or updated channel estimate, which is then used to decode subsequent signals.
    • Motivation to Combine (for §103 grounds): N/A (Single reference ground).
    • Expectation of Success (for §103 grounds): N/A (Single reference ground).
    • Key Aspects: Petitioner emphasized that Tang's method of decoding replicated data and immediately repurposing it as known "extra pilot symbols" to update the channel estimate within the same data transmission is functionally identical to the inventive concept claimed in the ’331 patent.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8 of Patent 8,565,331 as unpatentable.