Samsung Electronics Co Ltd v. Four Batons Wireless LLC

1. Case Identification

• Case #: IPR2025-00494
• Patent #: 8,073,436
• Filed: January 30, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Four Batons Wireless, LLC
• Challenged Claims: 1-17 and 19

2. Patent Overview

• Title: Improved Utilization of Silent Periods in Multi-Interface Wireless Devices
• Brief Description: The ’436 patent discloses systems and methods for controlling a wireless mobile device with multiple heterogeneous network interfaces. The technology utilizes "silent periods"—brief intervals with no application traffic—to perform tasks based on application awareness (e.g., real-time vs. non-real-time) and operating situation awareness (e.g., stationary vs. moving, battery level).

3. Grounds for Unpatentability

Ground 1: Claims 1-8 and 10-14 are obvious over Bahl, Hsu, and Weisshaar.

• Prior Art Relied Upon: Bahl (Application # 2005/0239497), Hsu (Application # 2004/0165563), and Weisshaar (Application # 2003/0130001).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Bahl teaches a framework for selecting a wireless network interface from multiple options based on various factors, including the needs of active applications and sensed operating conditions like battery life. Hsu was asserted to teach performing network handoffs during periods when a packet data session is dormant, which directly corresponds to the claimed "silent periods" of no application traffic. Weisshaar was cited for its disclosure of a connection manager that reports the concurrent use of multiple interfaces by the same or different applications to ensure session continuity. The combination allegedly teaches all elements of the independent claims, including controlling heterogeneous interfaces during silent periods based on application and situation awareness.
  • Motivation to Combine: A POSITA would combine Hsu with Bahl to improve Bahl's network selection method by incorporating the known technique of timing handoffs during silent periods, which would predictably minimize packet loss and service interruption. A POSITA would further add Weisshaar's teachings to allow an active application to use a second, idle interface (during a silent period for another application) to improve overall performance, such as by increasing bandwidth or ensuring session continuity across interfaces.
  • Expectation of Success: Petitioner contended that because Bahl, Hsu, and Weisshaar all describe software-based techniques for managing network interfaces, a POSITA would have possessed the ordinary skill to combine their teachings with a high expectation of success in achieving a more efficient and robust network selection system.

Ground 2: Claim 13 is obvious over Bahl, Hsu, Weisshaar, and White.

• Prior Art Relied Upon: Bahl (Application # 2005/0239497), Hsu (Application # 2004/0165563), Weisshaar (Application # 2003/0130001), and White (Patent 7,539,175).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon the Bahl-Hsu-Weisshaar combination to specifically address claim 13, which requires concurrent use of interfaces for "enhanced bandwidth support." Petitioner argued that while the primary combination teaches concurrent use, White explicitly discloses transmitting packetized traffic concurrently over multiple heterogeneous interfaces to aggregate bandwidth. White teaches that this load sharing provides "broadband capacity, beyond the capability of any individual network connection" by "summing" the capacity of multiple network paths.
  • Motivation to Combine: A POSITA would combine White's well-known bandwidth aggregation technique with the Bahl-Hsu-Weisshaar system to achieve the predictable result of enhanced bandwidth. This addresses a primary goal in the art: improving performance by using otherwise idle network resources to support an active application's traffic, particularly during a silent period when an interface becomes available.
  • Expectation of Success: Petitioner asserted that White's teachings are applied through software on similar multi-interface devices, making its integration into the base combination straightforward for a POSITA and yielding predictable improvements in bandwidth.

Ground 3: Claims 9, 15-17, and 19 are obvious over Bahl, Hsu, Weisshaar, and Ranta.

• Prior Art Relied Upon: Bahl (Application # 2005/0239497), Hsu (Application # 2004/0165563), Weisshaar (Application # 2003/0130001), and Ranta (Application # 2003/0081657).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground modifies the primary combination by adding Ranta to address claim limitations related to device motion and power conservation. Petitioner argued Ranta teaches techniques to optimize power consumption by reducing network interface usage based on a detected "absence of motion." This directly maps to claim 9 (control processes based on mobile moving or not moving) and claims 15-17 and 19, which involve performing certain processes based on combinations of the device's state (stationary/moving, real-time/non-real-time application) and whether power consumption is an issue.
  • Motivation to Combine: A POSITA would combine Ranta with the Bahl-Hsu-Weisshaar system because all references share the common goal of optimizing mobile device operation. Ranta provides a known, complementary technique for power conservation based on motion detection, which would predictably improve the efficiency of the multi-interface devices disclosed in the primary combination by adding another factor to the decision-making process.
  • Expectation of Success: As Ranta's power-saving techniques are also implemented via software, a POSITA would have been able to integrate these motion-based criteria into Bahl's factor-based selection framework with a reasonable expectation of successfully creating a more power-efficient device.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) and §325(d) is unwarranted.
• Fintiv Factors (§314(a)): Petitioner contended the factors weigh against denial. The parallel litigation is in its early stages with minimal investment and no substantive orders issued. While the district court trial is scheduled approximately five months before the statutory Final Written Decision (FWD) deadline, Petitioner argued this factor alone is not determinative and should be weighed only minimally in favor of denial given the early stage of the case and the strong merits of the petition.
• Same or Substantially Same Art (§325(d)): Petitioner asserted that the grounds raised are not the same or substantially the same as those considered during prosecution. The petition's primary reference, Bahl, was never cited or considered by the Examiner. Further, the art relied upon by the Examiner during prosecution was argued to be substantively different from the combinations presented in the petition, which address the core limitations of the challenged claims more directly.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-17 and 19 of the ’436 patent as unpatentable.