PTAB

IPR2025-00328

Intel Corp v. Proxense LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Communication System and Method
  • Brief Description: The ’129 patent describes a technique for wireless communication in a network where individual client devices are assigned specific time slots to communicate with a gatekeeper device, thereby avoiding data collisions. The system uses synchronization information to coordinate transmissions based on a class associated with the device or user.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gilb/802.15.3 - Claims 1-2, 5-7, 16, and 18 are obvious over Gilb in view of IEEE 802.15.3

  • Prior Art Relied Upon: Gilb ("Wireless Multimedia: A Guide to the IEEE 802.15.3 Standard," a 2004 IEEE publication) and IEEE 802.15.3 (a 2003 standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Gilb and the 802.15.3 standard discloses all limitations of these claims. The combination’s piconet system, with a central piconet coordinator (PNC) and multiple devices (DEVs), meets the claimed system. The PNC (network device) wirelessly broadcasts beacons containing Channel Time Allocation (CTA) blocks, which constitute the claimed "synchronization information" assigning specific "time slots." The DEVs (client devices) receive this information. Time slot allocation is determined based on priority data associated with a "class," which Petitioner asserted is met by two alternative schemes in the prior art: (1) prioritizing devices in a synchronized power-save (SPS) mode (a device-based class), or (2) prioritizing data based on its Quality of Service (QoS) category, such as voice over video (a user/application-based class).
    • Motivation to Combine: A POSITA would combine these references because Gilb is an introductory guide that explicitly directs an implementer to the 802.15.3 standard for the specific protocol details required to build a compliant system.
    • Expectation of Success: A POSITA would have a high expectation of success, as Gilb is a companion document designed to be used with the 802.15.3 standard to develop the very systems it describes.

Ground 2: Obviousness over Gilb/802.15.3/Cai - Claims 12-13 and 15 are obvious over Gilb and IEEE 802.15.3 in view of Cai

  • Prior Art Relied Upon: Gilb, IEEE 802.15.3, and Cai ("A Novel Design of IEEE 802.15.3 MAC over UWB," a 2005 journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Cai to address the limitation of a client device "storing a bit field identifying a specific time slot." Petitioner argued that while Gilb/802.15.3 teaches broadcasting time slot information in a beacon, it does not expressly disclose how the device stores it. Cai remedies this by teaching a split MAC architecture where a lower-layer MAC scheduler extracts timing information (like CTA blocks) from a received beacon and stores it in status registers (a bit field) to manage real-time transmission and reception.
    • Motivation to Combine: A POSITA would combine Cai with the Gilb/802.15.3 system to obtain a more flexible, cost-effective, and scalable MAC implementation. Both Gilb and Cai suggest splitting MAC functionality between hardware and software, making Cai’s two-layer design a natural and advantageous implementation choice for an 802.15.3 system.

Ground 4: Obviousness over Gilb/802.15.3/Ward/Brawn - Claims 1-2, 5-7, 16, and 18 are obvious over Gilb, IEEE 802.15.3, and Ward in view of Brawn

  • Prior Art Relied Upon: Gilb, IEEE 802.15.3, Ward (WO 02/067009), and Brawn (Application # 2007/0016637).
  • Core Argument for this Ground:
    • Prior Art Mapping: This combination was asserted to render the claims obvious under Petitioner's proposed construction of "synchronization information" as requiring bitmasks. Ward was added to the base combination to introduce a user-based prioritization scheme where time slots are allocated based on a user's subscription level (e.g., premium vs. standard), satisfying the "class associated with...a user" limitation. Brawn was then added to teach an efficient method for communicating these group-based time slot allocations. Brawn discloses using a bitmask (a starting address plus a bit sequence) to identify multiple destination devices in a group, rather than listing each full address separately. This bitmask, transmitted in the beacon, constitutes the claimed "synchronization information" containing "individual bit masks."
    • Motivation to Combine: A POSITA would first incorporate Ward's teachings into the Gilb/802.15.3 system to create revenue-generating opportunities by offering tiered, user-based service levels. Subsequently, a POSITA would incorporate Brawn's bitmasking technique to efficiently implement the resulting group allocations to users of the same class (e.g., all premium users), which reduces beacon size, conserves network resources, and improves transmission reliability.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of these same references, including Gilb/802.15.3/Ward (Ground 3), Gilb/802.15.3/Ward/Cai (Ground 5), and Gilb/802.15.3/Ward/Brawn/Cai (Ground 6). These grounds relied on similar theories, adding Ward for user-based class association and Cai for storing time slot information.

4. Key Claim Construction Positions

  • “synchronization information”: Petitioner proposed construing this term as "information that contains individual bit masks to be applied to bit fields of individual client devices." This construction was based on the patent's abstract and the specification's sole disclosed embodiment. Petitioner argued this construction was confirmed during prosecution when the Patent Owner distinguished prior art by representing that "a mask is set according to the class" and "the mask sets the...time slot."
  • “class associated with...[device/user]”: Petitioner argued this term should be construed as associated with the device or its user, but specifically not with data items or network characteristics. This was based on prosecution history where the Patent Owner disclaimed coverage of systems that allocate time slots based on network characteristics or data item types to overcome prior art rejections.
  • “time slot”: Petitioner proposed this term be defined as "a period of time that information is communicated between two devices," based on an explicit definition provided in the ’129 patent specification.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) and the Fintiv factors is inappropriate. It was contended that because the median time to trial in the co-pending district court case (WDTX) is 33.1 months, a trial would likely occur well after the statutory deadline for a Final Written Decision in the IPR, favoring institution. Petitioner also argued against denial under §325(d), stating that none of the asserted prior art references were previously applied during prosecution.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 5-7, 12-13, 15-16, and 18 of the ’129 patent as unpatentable.