Intel Corp v. Proxense LLC

1. Case Identification

• Case #: IPR2025-00327
• Patent #: 9,265,043
• Filed: December 23, 2024
• Petitioner(s): Intel Corporation
• Patent Owner(s): Proxense, LLC
• Challenged Claims: 1-5, 8-11

2. Patent Overview

• Title: Wireless Communication System and Method
• Brief Description: The ’043 patent describes a wireless communication system for preventing data collisions between multiple client devices. The system uses a fixed reader device to broadcast synchronization information, which assigns specific time slots to portable client devices based on priority level data associated with a device or user class.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gilb and IEEE 802.15.3 - Claims 1-5 and 8-11 are obvious over Gilb in view of the IEEE 802.15.3 Standard.

• Prior Art Relied Upon: Gilb ("Wireless Multimedia ... A Guide to the IEEE 802.15.3 Standard") and 802.15.3 (the IEEE 802.15.3 Standard (2003)).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued the combination discloses every limitation of the challenged claims. Gilb describes the IEEE 802.15.3 protocol for wireless personal area networks ("piconets"), which consist of a central piconet coordinator (PNC) and multiple devices (DEVs). This maps to the claimed fixed reader and portable client devices. The PNC broadcasts beacons containing Channel Time Allocation (CTA) information, which assigns specific time slots for DEVs to communicate, satisfying the "synchronization information" and "time slot" limitations. The combination discloses two methods for prioritizing these time slots: first, based on a device's Power Management (PM) status (e.g., giving earlier slots to devices in power-save mode), and second, based on the Quality of Service (QoS) category of the data being sent (e.g., prioritizing voice over best-effort data). Petitioner contended these PM statuses and QoS categories constitute the claimed "class" and "priority level data associated with a first class."
  • Motivation to Combine: A POSITA would combine these references because Gilb is an introductory guide to the 802.15.3 standard and explicitly directs the reader to the standard itself for technical and implementation details. The combination involves using the standard to supply the specific protocol formats and rules for the high-level system described in Gilb.
  • Expectation of Success: Success would be expected and the results predictable, as Gilb is a companion document intended to be used with the 802.15.3 standard to build compliant systems.

Ground 2: Obviousness over Gilb, IEEE 802.15.3, and Ward - Claims 1-5 and 8-11 are obvious over the combination of Gilb, 802.15.3, and Ward.

• Prior Art Relied Upon: Gilb, 802.15.3, and Ward (WO 02/067009).
• Core Argument for this Ground:
  • Prior Art Mapping: This combination builds on Ground 1 by adding Ward's teachings on user-based prioritization. Ward discloses prioritizing time slot assignments based on a user's subscription level or payment for premium services (e.g., more frequent stock updates). Petitioner argued this provides an alternative basis for the claimed "class," where the class is associated with the user (e.g., "premium subscriber") rather than just the device's technical state (PM mode) or data type (QoS). This user-based class is associated with priority level data (the subscription tier) to determine time slot allocation.
  • Motivation to Combine: The 802.15.3 standard leaves the specific time slot allocation algorithm as an implementation choice. A POSITA would combine Ward's user-based prioritization scheme with the Gilb/802.15.3 system to create revenue-generating opportunities. Ward's method allows a service provider to offer tiered services, charging more for better or faster access, a known business model that Ward teaches can be applied to time-division multiplex systems.

Ground 3: Obviousness over Gilb, IEEE 802.15.3, Ward, and Brawn - Claims 1-5 and 8-11 are obvious over the combination of Gilb, 802.15.3, Ward, and Brawn.

• Prior Art Relied Upon: Gilb, 802.15.3, Ward, and Brawn (Application # 2007/0016637).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground adds Brawn's teachings on efficient data encoding to the system from Ground 2. Brawn discloses using a bitmask (an initial address followed by a bit sequence) to efficiently identify multiple network devices instead of listing each full address. Petitioner argued this bitmask is the "synchronization information" containing "individual masks" as recited in the claims under its proposed construction. In the context of an 802.15.3 group allocation (sending one message to multiple DEVs), Brawn’s mask would be used in the beacon’s CTA information to designate all recipient devices in a single, compact data block.
  • Motivation to Combine: A POSITA would combine Brawn's technique to improve the efficiency of the Gilb/802.15.3 system. Gilb teaches that reducing the size of the beacon increases the probability of its successful reception. For group allocations, the standard method requires sending repetitive CTA blocks. Applying Brawn’s known masking technique would significantly reduce the beacon size, conserving network resources and improving reliability, which is a predictable improvement.

4. Key Claim Construction Positions

• "synchronization information": Petitioner proposed this term be construed as "information that contains individual bit masks to be applied to bit fields of individual client devices." This construction was based on language in the patent's abstract and arguments made by the Patent Owner during prosecution of a parent patent to overcome a rejection, where the Patent Owner stated that "the mask sets the times or time slot."
• "class is associated with one or more of the [] client device and a user...": Petitioner argued this term should be construed to mean the class is associated with the device or user itself, "not data items or network characteristics." This was based on prosecution history disclaimers where the Patent Owner distinguished prior art by arguing that its claimed "class" was distinct from classes based on data types (like QoS) or network conditions.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv Factors): Petitioner argued against discretionary denial, asserting that the median time to trial in the co-pending district court case (WDTX) is 33.1 months. This would place the trial in early 2027, well after the statutory deadline for a Final Written Decision in the IPR, weighing against denial.
• §325(d): Petitioner contended that denial under §325(d) is inappropriate because none of the asserted prior art references were cited or applied during the original prosecution, and no asserted reference is substantially the same as any art previously considered by the USPTO.

6. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-5 and 8-11 of the ’043 patent as unpatentable.