Samsung Electronics Co Ltd v. Headwater Partners II LLC

1. Case Identification

• Case #: IPR2025-00426
• Patent #: 9,094,868
• Filed: January 8, 2025
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Headwater Partners II LLC
• Challenged Claims: 1-34

2. Patent Overview

• Title: User Equipment Link Quality Estimation Based on Positioning
• Brief Description: The ’868 patent relates to systems for proactively managing wireless communication links for user equipment (UE), such as smartphones. The technology involves determining and storing a UE's link quality (LQ) at a plurality of different positions or orientations, estimating a future position for the UE, and then estimating the future link quality at that position based on the stored historical data to improve link efficiency and robustness.

3. Grounds for Unpatentability

Ground 1: Claims 1-34 are obvious over Jarvinen in view of Fox.

• Prior Art Relied Upon: Jarvinen (Application # 2008/0248822) and Fox (Application # 2012/0064908).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Jarvinen discloses the core elements of the challenged claims. Jarvinen teaches a system to proactively adapt a radio link by collecting data and storing it in a database that links a UE’s "Geographical Location" with its "Transmission Properties" (i.e., link quality). Jarvinen further discloses predicting the "geographical location the mobile terminal will be entering next" and then using the database to select optimal transmission parameters for that predicted location. This framework was alleged to teach the limitations of the independent claims, which require determining link qualities for a plurality of positionings, storing the associated information, estimating a future positioning, and estimating a future link quality based on that stored information. Petitioner asserted that Fox augments Jarvinen by explicitly teaching the use of a "record of radio quality across a coverage area" combined with a UE's current location and velocity to "estimate the radio conditions available to that mobile terminal at a future location." Fox also teaches allocating resource blocks based on this estimation, which Petitioner mapped to dependent claim 21.
  • Motivation to Combine: A POSITA would combine Jarvinen and Fox because they address the identical problem—predicting future link quality to proactively manage a wireless link—using highly similar database-driven approaches in the same technical field. Petitioner contended that a POSITA, seeking to implement the future link quality estimation described in Jarvinen, would have naturally looked to a reference like Fox that provides a specific, well-defined method for doing so. The combination was characterized as a simple substitution of a known element (Fox’s estimation technique) into an existing system (Jarvinen’s database and predictive framework) to achieve a predictable improvement.
  • Expectation of Success: A POSITA would have had a high expectation of success in combining the references. Since Jarvinen already provides the necessary data structure—linking specific locations to specific link quality measurements—implementing Fox’s estimation method would merely require performing a straightforward database lookup based on the predicted future location, an entirely predictable operation.

Ground 2: Claims 1[d], 24[d], 33[d], and 34[d] are obvious over Jarvinen alone.

• Prior Art Relied Upon: Jarvinen (Application # 2008/0248822).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner presented a single-reference obviousness argument as an alternative. It was argued that Jarvinen’s disclosure of selecting future transmission conditions based on historical "transmission property values" stored for a predicted future location inherently assumes that the past link quality is a reliable estimate of the future link quality. While Jarvinen may not use the exact word "estimate," its method of relying on the stored historical value to make a future-looking decision was argued to be functionally identical to the claimed "estimating."
  • Motivation to Modify: A POSITA would have been motivated to modify Jarvinen to explicitly perform the claimed estimation. The entire purpose of Jarvinen's data collection and storage is to enable proactive link management. The most direct and obvious way to use this stored data is to assume it represents the expected conditions at a future time for the same location, thus making the modification a matter of common sense to achieve Jarvinen's own stated goals. The modification would be minimal, merely formalizing the implicit assumption already present in Jarvinen's system.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should decline to exercise its discretion to deny institution under §325(d) and §314(a) (Fintiv).
• §325(d): The petition contended that the asserted prior art was not substantively evaluated during the original prosecution. Fox was never presented to the Examiner. Although Jarvinen was cited in an Information Disclosure Statement (IDS), it was part of a "sea of 70 references," and the Examiner never substantively addressed its teachings in any office action or reason for allowance. Petitioner argued that this failure to consider the most relevant art constituted a material error by the USPTO that warrants review.
• Fintiv (§314(a)): Petitioner asserted that its grounds present a "compelling unpatentability challenge," indicating a high likelihood of success on the merits, which weighs heavily in favor of institution under current PTAB guidance. Additionally, it was noted that the parallel district court litigation was in its nascent stages at the time of filing, with estimated trial dates more than a year and a half away, meaning the Fintiv factors strongly favor institution of the IPR.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-34 of Patent 9,094,868 as unpatentable.