Samsung Electronics Co Ltd v. Vasu Holdings LLC

1. Case Identification

• Case #: IPR2025-00450
• Patent #: 10,419,996
• Filed: January 24, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Vasu Holdings, LLC
• Challenged Claims: 1, 12, 23, 25, 34-35, 39, and 41

2. Patent Overview

• Title: Mobile Device Wireless Network Handover
• Brief Description: The ’996 patent describes a mobile communication device that performs wireless handover between different networks, such as cellular and Wi-Fi. The device uses a network switch unit to automatically switch communication based on detecting a change in context, such as signal strength, and includes a timer-activated, multi-stage power-up sequence (sleep to stand-by to active) for the target communication module before the handover occurs.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dorenbosch and Donovan - Claims 1, 12, 23, 25, and 34-35 are obvious over Dorenbosch in view of Donovan.

• Prior Art Relied Upon: Dorenbosch (Application # 2005/0048977) and Donovan (Application # 2005/0063348).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Dorenbosch disclosed a mobile device with both WAN and WLAN transceivers and a "handover manager" that automatically switches between them based on network conditions like signal strength. To address the timer-based power-up sequence, Petitioner asserted that Donovan disclosed a wireless device that, upon activation of a timer (a crystal oscillator), transitions its communication module from a low-power "sleep mode" through a "stand-by mode" (wakeup period) before entering a fully "active mode."
  • Motivation to Combine: A POSITA would combine Donovan’s power-saving, staged wakeup process with Dorenbosch’s handover system. The combination would predictably optimize battery life by keeping the inactive transceiver in a sleep state while still allowing for a quick and orderly power-up sequence to facilitate a seamless network handover when needed.
  • Expectation of Success: Petitioner contended there was a high expectation of success because Dorenbosch’s system already implied a non-instantaneous warm-up period to "bring up" hardware, and Donovan provided a well-understood method for implementing such a power-managed transition using an oscillator, a common component in transceivers.

Ground 2: Obviousness over Iizuka and Donovan - Claim 39 is obvious over Iizuka in view of Donovan.

• Prior Art Relied Upon: Iizuka (Application # 2005/0282541) and Donovan (Application # 2005/0063348).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted Iizuka taught the core handover method of claim 39, disclosing a mobile terminal that monitors the signal strength of a first wireless link (e.g., WLAN). When the signal drops below a threshold, the terminal notifies an interface server, which establishes a second communication link (e.g., via a cellular network) without disrupting the first link, before notifying the terminal to terminate the first link. The combination with Donovan was argued to supply the timer-activated, multi-stage power-up sequence for the second communication module.
  • Motivation to Combine: A POSITA would have been motivated to incorporate Donovan's power-efficient wakeup procedure into Iizuka’s handover method for the same reasons as in Ground 1: to conserve battery power on the mobile terminal while ensuring the secondary communication module could be activated reliably for a smooth handover.
  • Expectation of Success: Success would be expected because both Iizuka and Donovan described conventional wireless devices and networks, making their teachings readily interoperable. Applying Donovan's standard wakeup procedure would predictably activate the wireless-telephone communication unit in Iizuka’s device.

Ground 3: Obviousness over Iizuka, Donovan, and Pan - Claim 41 is obvious over Iizuka in view of Donovan and Pan.

• Prior Art Relied Upon: Iizuka (Application # 2005/0282541), Donovan (Application # 2005/0063348), and Pan (Application # 2004/0002335).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds on the Iizuka/Donovan combination to address claim 41, which recites an interface initiating the handover upon detecting a preferable network. Petitioner argued that Pan disclosed this feature by teaching a "media gateway" (an interface) that monitors the signal strength from the mobile station. Based on this network-side measurement, the gateway determines when to initiate a handover and commands the mobile station to switch to the second network.
  • Motivation to Combine: A POSITA would combine Pan's interface-controlled handover with the Iizuka/Donovan system to create a more robust handover trigger. Relying only on the mobile device's signal detection (as in Iizuka) can be unreliable, whereas Pan’s method of having the network measure the signal and initiate the switch ensures the handover is based on the actual connection quality at the network side.
  • Expectation of Success: This modification would have been a straightforward application of known principles. Iizuka already disclosed a call-management server (an interface) that communicates with the mobile terminal, so modifying it to issue handover commands based on network-side measurements as taught by Pan would be a predictable and successful integration.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including adding DeAnna to the Dorenbosch/Donovan combination to explicitly teach a server (Ground 2), and adding Preston to the Iizuka/Donovan combination to further disclose SIP session termination notifications (Ground 4).

4. Arguments Regarding Discretionary Denial

• The petition argued against discretionary denial under §325(d) because the asserted prior art combinations and expert testimony were not considered during the original prosecution and are not cumulative.
• Regarding discretionary denial under Fintiv, Petitioner argued that the co-pending district court case is in its early stages, with a trial date of November 3, 2025, set for more than three months after the statutory deadline for a final written decision. Petitioner stated its intent to seek a stay of the litigation if the IPR is instituted.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1, 12, 23, 25, 34-35, 39, and 41 of the ’996 patent as unpatentable.