PTAB

IPR2024-00946

T-Mobile USA Inc v. Cobblestone Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Carrier Transmission
  • Brief Description: The ’802 patent discloses a method and system for multi-carrier transmission, where information is transmitted simultaneously over at least two distinct frequency ranges using a single wireless transmitter and power amplifier.

3. Grounds for Unpatentability

Ground 1: Obviousness over Suzuki - 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 argued that Suzuki, which discloses a predistorter for a "multi-band wireless system," teaches every limitation of the challenged claims. Suzuki's system outputs a single, combined signal across dual frequency bands (FB1 and FB2), which Petitioner asserted maps directly to the limitations of independent claim 1 requiring simultaneous transmission of first and second information across two frequency ranges from the same transmitter. Petitioner further argued that Suzuki's explicit disclosures meet the dependent claims, including its illustration of non-overlapping frequency bands with a gap between them (claim 2), its use of a single, common power amplifier (claim 3), and its stated applicability to systems using multiple wireless protocols such as GSM (claim 6). The method and system claims (10 and 17) were argued to be obvious as they recite a standard arrangement of well-known components (e.g., DACs, up-converters, amplifiers) that Suzuki discloses for generating its multi-carrier signal.

Ground 2: Obviousness over Suzuki and Jalali - Claims 7-9, 22, and 23 are obvious over Suzuki in view of Jalali.

  • Prior Art Relied Upon: Suzuki (Application # 2006/0276146) and Jalali (Patent 6,952,454).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Jalali supplies teachings on specific modulation techniques that are absent from Suzuki but would have been obvious to incorporate. Specifically, Jalali teaches a system using Orthogonal Frequency Division Multiplexing (OFDM) with time-division multiplexing (TDM). Petitioner asserted that Jalali’s disclosure of transmitting different data streams as sequences of OFDM symbols across different sub-channels (frequency ranges) within the same time slots meets the limitations of claims 9 and 23. Jalali also discloses transmitting the same data across multiple sub-channels for redundancy, satisfying claims 7, 8, and 22.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Jalali’s advanced OFDM/TDM techniques with Suzuki’s multi-band system to achieve well-known benefits, such as improved spectral efficiency, robustness against interference, and greater flexibility. Because Suzuki explicitly states its system is compatible with GSM (a TDMA/FDMA system), a POSITA would have been motivated to look to known improvements like OFDM with TDM, as taught by Jalali.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as both references are in the analogous art of multi-carrier wireless communications. Implementing the well-known OFDM/TDM scheme into Suzuki's compatible system was argued to be a straightforward application of known principles.

Ground 3: Obviousness over Fernandez and Montojo - Claims 1-4, 6-8, 10, 13, 17, 21-22, and 24 are obvious over Fernandez in view of 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 generating multi-carrier signals by summing the outputs of multiple parallel signal generators, where each generator includes its own amplifier. Montojo, in contrast, teaches the specific advantages of using a single power amplifier for multi-carrier transmissions. Petitioner asserted that modifying Fernandez’s system to replace the multiple amplifiers with a single, common power amplifier post-combination, as taught by Montojo, would result in the system claimed in the ’802 patent.
    • Motivation to Combine: A POSITA would combine Montojo's single-amplifier architecture with Fernandez's signal generation system to achieve the explicit benefits taught by Montojo, including reduced complexity, lower manufacturing cost, decreased power consumption, and a single point of failure. This modification was presented as a predictable and advantageous design choice for optimizing the system disclosed in Fernandez.
    • Expectation of Success: A POSITA would expect success because using a single amplifier for multi-carrier signals was a well-known technique. Montojo provides a clear blueprint for its implementation, and integrating this architecture into the Fernandez system would be well within the capabilities of a skilled artisan.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Rick alone; combinations of Suzuki with Chen (for receiver claims) and Etemad (for specific wireless protocols); and combinations of Fernandez/Montojo with Jalali, Chen, and Etemad, which relied on similar technical rationales for receiver design, modulation techniques, and protocol implementation.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is inappropriate. It contended that the district court trial date (May 2025) and the Board's potential Final Written Decision in a related IPR (IPR2024-00606, August 2025) are closely timed, a factor that favors institution or is neutral. Petitioner also argued that the co-pending litigation is in its infancy, the petition was filed diligently, and the strong merits presented 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.