PTAB

IPR2024-00898

RECycLED Plastics Industries LLC v. Tangent Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Multi-Device Media Access Control
  • Brief Description: The ’811 patent discloses methods and systems for wireless communication where a first wireless device transmits a "multi-device block acknowledgement request (M-BAR) frame" to a second wireless device. This M-BAR frame is designed to solicit block acknowledgement (BA) frames from multiple other wireless devices, aiming to improve efficiency in multi-user network environments.

3. Grounds for Unpatentability

Ground 1: Obviousness over IEEE Standard and Merlin - Claims 1-20 are obvious over the IEEE 802.11-2016 standard in view of Merlin.

  • Prior Art Relied Upon: IEEE 802.11-2016 (“IEEE Standard”) and Merlin (Application # 2013/0242857).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the IEEE Standard discloses the fundamental components of the claimed wireless system, including access points (APs), stations (STAs), and the use of Block Ack Request (BAR) and Block Ack (BA) frames for data transmission acknowledgement. The IEEE Standard’s BAR, however, is for a single user. Petitioner asserted that Merlin remedies this deficiency by disclosing a Multi-User BAR (MU-BAR) frame transmitted from an AP to solicit a Multi-STA Block Ack (MS-BA). Petitioner contended that Merlin’s MU-BAR, which contains information identifying multiple STAs to solicit their respective acknowledgements, directly teaches the “M-BAR frame” limitation of independent claims 1, 10, and 17. The responsive MS-BA from the AP in Merlin, containing acknowledgement information for the multiple STAs, was argued to meet the limitation of receiving BAs from multiple devices.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the IEEE Standard with Merlin to improve the efficiency of acknowledgement protocols for uplink multi-user (UL MU) transmissions. The petition argued that improving efficiency in multi-user systems was a well-known goal in the field, and Merlin explicitly presents its MU-BAR mechanism as a solution to the inefficiencies of the standard single-user BAR protocol in a multi-user context.
    • Expectation of Success: A POSITA would have had a high expectation of success because Merlin provides a detailed description of its MU-BAR protocol, including frame formats. Integrating this described protocol into an IEEE Standard-compliant system was presented as a predictable implementation of known networking principles to achieve a desired and expected result.

Ground 2: Obviousness over IEEE Standard and Seok - Claims 1-20 are obvious over the IEEE 802.11-2016 standard in view of Seok.

  • Prior Art Relied Upon: IEEE 802.11-2016 (“IEEE Standard”) and Seok (Application # 2014/0112190).

  • Core Argument for this Ground:

    • Prior Art Mapping: Similar to Ground 1, Petitioner relied on the IEEE Standard for the basic wireless communication framework. Petitioner then argued that Seok, like Merlin, teaches a solution for efficient multi-user acknowledgements. Seok discloses a transmitting device sending an “MU-BAR frame” that includes a list of STAs from which acknowledgements are requested. Petitioner asserted this disclosed MU-BAR frame meets the “M-BAR frame” limitation of the challenged claims. Seok further teaches that in response, a receiving device transmits an MU-BA frame that includes acknowledgement information for each STA identified in the MU-BAR frame, thereby satisfying the claim limitation of receiving BAs from multiple devices.
    • Motivation to Combine: The motivation presented was identical to that for combining Merlin: to address the known problem of inefficient acknowledgement mechanisms in UL MU-MIMO systems. Seok was presented as another clear solution to this known industry problem, providing a strong incentive for a POSITA to incorporate its teachings into the IEEE Standard framework to improve overall system performance.
    • Expectation of Success: The petition argued success would be reasonably expected because Seok provides a clear and enabling disclosure of its multi-user acknowledgement protocol. The combination was characterized as the application of a known technique (Seok’s MU-BAR) to a known system (the IEEE Standard) to achieve a predictable improvement in efficiency.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-20 based on the IEEE Standard in view of Merlin and further in view of Seok, relying on similar motivations to combine the references to enhance acknowledgement efficiency.

4. Key Claim Construction Positions

  • Petitioner argued that the term “multi-device block acknowledgement request (M-BAR) frame” should be given its plain and ordinary meaning. This construction is central to all grounds, as Petitioner contended this meaning is broad enough to encompass the multi-user BAR frames disclosed in the prior art, such as the “MU-BAR” in Merlin and the “MU-BAR frame” in Seok, even if the terminology is not identical to that used in the ’811 patent.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) based on the Fintiv factors would be inappropriate. The petition asserted that the parallel district court proceeding is at a nascent stage, with no substantive events or claim construction rulings having occurred. Petitioner further contended that the IPR presents a more efficient and streamlined path to resolving the invalidity dispute based on a focused set of prior art references that differ from those likely to be the focus in the district court litigation.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’811 patent as unpatentable.