Lenovo United States Inc v. Universal Connectivity Technologies Inc

1. Case Identification

• Case #: IPR2024-01481
• Patent #: 7,746,798
• Filed: October 2, 2024
• Petitioner(s): Lenovo (United States) Inc., Dell Inc., Dell Technologies, Inc., HP Inc.
• Patent Owner(s): Universal Connectivity Technologies, Inc.
• Challenged Claims: 1-9, 11-26, and 28

2. Patent Overview

• Title: Serial Communications Architecture
• Brief Description: The ’798 patent describes a serial communications architecture for data transmission between devices. The disclosed system uses multiple "synchronization primitives," which are special bit patterns used by the physical layer to ensure correct alignment of data symbols and to encode the type of an associated data packet (e.g., control or data).

3. Grounds for Unpatentability

Ground 1: Obviousness over Auld and MPEG-2, Part 1 - Claims 1, 4-7, 9, 11, 14-16, 18-19, 22-25, and 28 are obvious over Auld in view of MPEG-2, Part 1.

• Prior Art Relied Upon: Auld (Patent 5,686,965) and MPEG-2, Part 1 (ISO/IEC 13818-1).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Auld teaches a general synchronization scheme for video decoders that uses "sync codes" or "start codes" in a bitstream to ensure proper data alignment and to identify packet types. The combination of Auld and the MPEG-2, Part 1 standard allegedly discloses the key limitations of the independent claims. Specifically, Auld’s "sync codes" were presented as analogous to the ’798 patent’s "synchronization primitives." The MPEG-2 standard provides the specific structure for these codes, which include a packet_start_code_prefix and a stream_id. Petitioner contended the stream_id serves as the claimed "synchronization symbol" because its value specifies the packet type (e.g., audio, video, or control), and different packet types are assigned different stream_id values.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Auld and MPEG-2, Part 1 because Auld expressly teaches that its synchronization scheme is designed for use with bitstreams conforming to the MPEG standard. Therefore, a POSITA implementing Auld's system would have naturally looked to the official MPEG-2, Part 1 standard to understand and use the specific packet and sync code structures.
  • Expectation of Success: A POSITA would have had a high expectation of success in combining the references, as Auld’s system was explicitly designed to be interoperable with MPEG-compliant bitstreams.

Ground 2: Obviousness over Auld, MPEG-2, Part 1, and Shin - Claims 2, 3, 12, 13, 20, and 21 are obvious over Auld in view of MPEG-2, Part 1 and Shin.

• Prior Art Relied Upon: Auld (Patent 5,686,965), MPEG-2, Part 1 (ISO/IEC 13818-1), and Shin (Patent 5,974,464).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Shin to the base combination of Auld and MPEG-2 to teach limitations related to "in-band" and "out-of-band" symbols distinguished by bit transition frequency. Petitioner argued that Shin, which shares inventors with the ’798 patent, discloses a transition-controlled encoding scheme where "in-band" data symbols are "transition optimized" to have a high number of bit transitions (e.g., four or more), while "out-of-band" synchronization symbols are not optimized and have few transitions (e.g., three or less). This mapping directly addressed the limitations of claims requiring such a distinction.
  • Motivation to Combine: Shin is analogous art directed to the same field of high-speed video data transmission. A POSITA seeking to improve the reliability and efficiency of the Auld/MPEG-2 system would combine Shin's teachings to create a more robust method for distinguishing synchronization codes from the data payload. This addresses the known technical challenge of preventing data from being mistaken for a sync code.
  • Expectation of Success: The combination would have been predictable and successful. The MPEG-2 standard provides for "private data" stream types, which would allow a POSITA to incorporate Shin's specialized encoding scheme for the packet payload while retaining the standard Auld/MPEG-2 start code for synchronization and packet type identification.

Ground 3: Obviousness over Auld, MPEG-2, Part 1, and Hiroshima - Claims 8, 17, and 26 are obvious over Auld in view of MPEG-2, Part 1 and Hiroshima.

• Prior Art Relied Upon: Auld (Patent 5,686,965), MPEG-2, Part 1 (ISO/IEC 13818-1), and Hiroshima (Patent 5,801,781).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Hiroshima to the Auld/MPEG-2 combination to supply the claim limitation of transmitting or receiving symbols via a "switch network." While Auld teaches a system of interconnected components, it does not specify the network architecture. Hiroshima was cited for its disclosure of a video-on-demand system that converts and transmits MPEG data over an Asynchronous Transfer Mode (ATM) network, which is a well-known type of switch network.
  • Motivation to Combine: Hiroshima is analogous art focused on transmitting MPEG data streams. A POSITA tasked with implementing the Auld/MPEG-2 system for practical communication between devices would combine its teachings with a standard, high-speed network architecture. Hiroshima’s disclosure of using an ATM switch network provided a natural and readily available solution for interconnecting the components of Auld’s system.
  • Expectation of Success: A POSITA would have expected success, as this combination merely involves implementing a known data processing system (Auld/MPEG-2) over a conventional network transport layer (Hiroshima's ATM network), a common and predictable engineering task.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 11-26, and 28 of Patent 7,746,798 as unpatentable.