Samsung Electronics America Inc v. Collision Communications Inc

1. Case Identification

• Case #: IPR2024-01247
• Patent #: Patent 7,593,492
• Filed: August 1, 2024
• Petitioner(s): Samsung Electronics America, Inc., Samsung Electronics Co., Ltd.
• Patent Owner(s): Collision Communications, Inc.
• Challenged Claims: 1-18

2. Patent Overview

• Title: Hybrid Multi-User Detector System
• Brief Description: The ’492 patent discloses a system for processing wireless signals that selects a multi-user detection (MUD) algorithm from a plurality of available MUDs. The selection is based on a parameter estimate of the received signal, such as channel conditions, to balance computational complexity with performance.

3. Grounds for Unpatentability

Ground 1: Obviousness over Onggosanusi and Egnor - Claims 1-16 are obvious over Onggosanusi in view of Egnor.

• Prior Art Relied Upon: Onggosanusi (Application # 2006/0018410) and Egnor (Application # 2005/0053173).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Onggosanusi taught the core concept of the ’492 patent: a system that selects from a plurality of detectors of varying complexity (e.g., maximum likelihood, linear detectors) based on a "channel metric" derived from a channel estimation of received signals. This allows the system to use high-complexity detectors for ill-conditioned channels and low-complexity detectors for well-behaved channels. Petitioner asserted that Egnor supplied several well-known, complementary components to complete the claimed invention. These included a bank of decoders for processing multiple information streams, iterative decoding where decoder outputs are fed back to the detector, interleavers and deinterleavers for handling specific signal formats like CDMA, and a front-end filter to improve signal quality before detection.
  • Motivation to Combine: A POSITA would combine Egnor’s teachings with Onggosanusi's system to achieve a more robust and efficient implementation. For example, a POSITA would recognize that using a bank of decoders, as taught by Egnor, was a well-known and efficient way to process in parallel the multiple output streams generated by Onggosanusi's selectable detectors. Similarly, incorporating Egnor's iterative decoding would be a standard technique to increase decoding accuracy, a universally desired goal in communications systems. The addition of Egnor's interleavers and filters would be necessary to handle common signal types (e.g., CDMA) and improve overall system performance.
  • Expectation of Success: A POSITA would have a high expectation of success because the combination involved integrating conventional components (bank of decoders, iterative feedback loops, filters) for their known purposes into a system whose fundamental principle (selectable detectors) was already established by Onggosanusi.

Ground 2: Obviousness over Egnor and Onggosanusi - Claims 17-18 are obvious over Egnor in view of Onggosanusi.

• Prior Art Relied Upon: Egnor (Application # 2005/0053173) and Onggosanusi (Application # 2006/0018410).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground targeted method claims reciting iterative multi-user detection performed on sequential, sliding windows of data. Petitioner argued that Egnor disclosed the foundational method of pipelining data processing through a series of MUD processors, where each processor operates on a "window" of received data before passing it to the next stage. This windowing technique formed the structural basis of the claimed method. Petitioner asserted that Onggosanusi supplied the missing element: the dynamic selection of a MUD for each processing stage based on channel conditions.
  • Motivation to Combine: A POSITA would be motivated to incorporate Onggosanusi's dynamic detector selection into Egnor's pipelined architecture to optimize performance and significantly reduce power consumption, a critical concern for mobile devices. As data passes through Egnor's pipeline, each stage of MUD processing and decoding tends to decorrelate the signals and reduce interference. By applying Onggosanusi's selection logic at each stage, the system could intelligently switch to less computationally complex and more power-efficient detectors for subsequent windows as the signal quality improves. This would provide a clear advantage over a static system.
  • Expectation of Success: A POSITA would have reasonably expected success in this combination. Onggosanusi provided detailed implementation guidance for its selection logic, which could be readily applied to each MUD stage in Egnor's disclosed pipeline without undue experimentation.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors is not warranted. The core arguments were that the parallel district court litigation is in a very early stage, with discovery still preliminary and a claim construction order not scheduled until well after the PTAB's institution decision deadline. Petitioner also asserted that the IPR challenges a broader set of claims than the district court case and that the petition presents compellingly strong merits for unpatentability.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 7,593,492 as unpatentable.