PTAB

IPR2025-00292

Google LLC v. Pegasus Wireless Innovation LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Transmitting and Receiving Signal in Wireless Communication System
  • Brief Description: The ’644 patent relates to enhancing signal coverage for Machine Type Communication (MTC) terminals. The technology involves repeatedly allocating downlink control channels over a plurality of subframes, where information about the start subframe is sent via higher-layer signaling and information on the number of subframes is sent via Downlink Control Information (DCI).

3. Grounds for Unpatentability

Ground 1: Claims 1-3 are Anticipated by Lee under 35 U.S.C. §102

  • Prior Art Relied Upon: Lee (WO 2014/055878).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee discloses every element of the challenged claims. Lee teaches enhancing coverage for MTC User Equipment (UE) through repetitive transmissions and subframe bundling. For independent claim 1, Petitioner asserted Lee discloses receiving configuration information via higher-layer signaling, such as a "window size" or a "bitmap" that indicates a subset of subframes for bundling, which inherently includes start subframe information. Lee also allegedly discloses that the DCI includes "indication bits" that define the number of subframes (NTTI) for the bundling. Finally, Petitioner contended Lee teaches that a terminal combines signals from multiple subframes to successfully decode the DCI, thus extracting the control information.

Ground 2: Claims 1-3 are Obvious over Lee under 35 U.S.C. §103

  • Prior Art Relied Upon: Lee (WO 2014/055878).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that to the extent Lee does not disclose a single, specific embodiment containing every element, the claims are obvious over Lee's collective teachings. Lee expressly discloses that its various embodiments for coverage enhancement may be applied individually or in combination.
    • Motivation to Combine: A POSITA would combine Lee's various disclosures to implement a coverage enhancement mode for MTC UEs, a problem Lee explicitly addresses. Specifically, a POSITA would be motivated to use higher-layer signaling to configure the start of subframe repetitions (as suggested by Lee's bitmap disclosure) while using dynamic DCI signaling to indicate the number of subframe repetitions (as suggested by Lee's "indication bits" disclosure).
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining these known signaling techniques from Lee would predictably result in a more robust communication system for MTC UEs in poor coverage environments, which was the stated goal of Lee.

Ground 3: Claims 1-3 are Obvious over Lee in view of You and Zhuang

  • Prior Art Relied Upon: Lee (WO 2014/055878), You (Application # 2016/0353420), and Zhuang (WO 2015/018075).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted this combination remedies any alleged deficiencies in Lee. During prosecution of the ’644 patent, the applicant overcame a rejection based on You by arguing that You did not teach that start subframe information and number of subframes information are obtained separately through different operations (higher-layer signaling vs. DCI). Petitioner argued this combination explicitly teaches that distinction. You discloses transmitting start subframe location information via higher-layer signaling. Lee and Zhuang both disclose transmitting the number of subframes via DCI (Lee's "indication bits" and Zhuang's "subframe indicator").
    • Motivation to Combine: A POSITA would combine the references to improve MTC device performance, a common goal of all three references. A POSITA would look to You for its specific teachings on configuring a subframe bundle start location via higher-layer signals and combine it with Lee's or Zhuang's more efficient DCI-based signaling for the number of repetitions. This combination improves reliability, as the static start information is sent less frequently, while the dynamic number of repetitions is sent more robustly via the repeated DCI.
    • Expectation of Success: The combination involves applying known signaling techniques to their intended purposes to solve a known problem (MTC coverage), leading to the predictable result of an improved and efficient communication protocol.

4. Key Claim Construction Positions

  • Petitioner adopted constructions from the related district court litigation, including that the preambles are limiting and that the term "configured to" in claim 3 means "actually configured to and not merely capable of performing the claimed function." Petitioner argued the prior art satisfies the claims under any reasonable construction.

5. Arguments Regarding Discretionary Denial

  • §314(a) / Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation is in its early stages, with a trial date far in the future (September 2025) and subject to delay. Petitioner contended that minimal court and party resources have been invested, the merits of the petition are exceptionally strong (including a straightforward anticipation ground), and institution would simplify issues for the district court.
  • §325(d) Factors: Petitioner argued against denial under §325(d) because the primary prior art, Lee, and the supporting reference Zhuang were never considered during prosecution. While You was considered, the petition presents it in a new combination with Lee and Zhuang that directly addresses the specific arguments the patent owner made to overcome You during prosecution. Petitioner asserted this constitutes a material error by the Patent Office and presents new, non-cumulative evidence warranting review.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 of the ’644 patent as unpatentable.