PTAB

IPR2024-01336

Qualcomm Inc v. Cobblestone Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Carrier Wireless Transmission
  • Brief Description: The ’802 patent discloses a method and system for multi-carrier wireless transmission, where information is transmitted simultaneously over multiple, distinct frequency ranges. The technology uses conventional components, such as digital-to-analog converters (DACs) and amplifiers, for transmitting the signal and a corresponding receiver architecture for down-conversion.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rick - Claim 1 is obvious over Rick.

  • Prior Art Relied Upon: Rick (Patent 8,693,525).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rick, which discloses a multi-carrier transmitter for wireless communication, teaches every limitation of claim 1. Rick describes simultaneously transmitting multiple CDMA signals (first and second information) on different CDMA channels (first and second frequency ranges), each having a defined center, highest, and lowest frequency. The combined signal is transmitted using a single antenna, satisfying the "same wireless transmitter" limitation.
    • Key Aspects: While Petitioner contended that Rick anticipates claim 1, the ground was presented under 35 U.S.C. §103 to address any potential arguments from the Patent Owner that Rick does not explicitly disclose certain claim elements, such as the carrier frequency being the exact center frequency of the channel.

Ground 2: 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 asserted that Suzuki, which describes a predistorter for multi-band wireless systems, renders the challenged claims obvious. Suzuki explicitly discloses transmitting signals across "dual frequency bands" (FB1 and FB2) simultaneously. This core teaching allegedly meets the limitations of independent claims 1, 10, and 17 by showing the transmission of first and second information over distinct, non-overlapping frequency ranges. Petitioner further argued that Suzuki’s system inherently uses the conventional components recited in the claims, including DACs, up-converters, a combiner, a single power amplifier, and a single antenna for transmission. The non-overlapping nature of Suzuki's frequency bands was argued to satisfy the frequency separation requirement of claim 2, and the disclosure of a "common power amplifier" was mapped to claims 3 and 4.

Ground 6: 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 a multi-carrier signal by summing the outputs of multiple parallel signal generators, which maps to most limitations of the independent claims. However, Fernandez teaches that each signal generator performs its own amplification. Montojo was introduced for its express teaching that it is "advantageous to utilize a single power amplifier" for multi-carrier transmissions to address limitations on space, cost, and power consumption.
    • Motivation to Combine: A POSITA would combine Montojo’s single-amplifier architecture with Fernandez’s signal generation system to achieve the well-known and explicitly stated benefits of lower complexity, reduced cost, and improved power efficiency.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success, as using a single amplifier for a combined multi-carrier signal was a conventional and well-understood design choice. Both references operate in the same technical field, and Montojo provides clear instructions for implementing its single-amplifier design.

  • Additional Grounds: Petitioner asserted further obviousness challenges, including: (1) combining Suzuki with Jalali (Patent 6,952,454) to add teachings of OFDM and time-division multiplexing; (2) combining Suzuki with Chen (Patent 6,359,868) to add a conventional multi-carrier receiver architecture; (3) combining Suzuki with Etemad (Patent 8,036,702) to add teachings of using different duplexing protocols (TDD/FDD); and (4) analogous combinations based on Fernandez and Montojo.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation is at an early stage, the petition presents strong merits, and it challenges more claims than are asserted in the litigation. Petitioner also argued against denial under General Plastic, explaining that this petition is not an abusive "follow-on" filing but an identical "copycat" of a previously filed IPR (IPR2024-00606). This action was taken to conserve Board resources and preserve Petitioner's rights upon learning of a potential settlement in the earlier case involving a different petitioner.

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 the ’802 patent as unpatentable.