Samsung Electronics America Inc v. Koninklijke KPN NV

1. Case Identification

• Case #: IPR2025-00533
• Patent #: RE48,089
• Filed: January 25, 2025
• Petitioner(s): Samsung Electronics America, Inc., Samsung Electronics Co., Ltd.
• Patent Owner(s): Koninklijke KPN N.V.
• Challenged Claims: 6-10 and 12

2. Patent Overview

• Title: Method and System for Assessing Coverage of a Wireless Access Network
• Brief Description: The ’089 patent discloses a method and system for assessing the radio coverage of a second wireless access network within a telecommunications infrastructure that also includes a first wireless access network. The system uses selected mobile terminals, capable of communicating with both networks, to measure signals from the second network and generate a coverage assessment, aiming to replace traditional drive tests.

3. Grounds for Unpatentability

Ground 1: Claims 6-10 and 12 are obvious over Olofsson in view of Kuruvilla.

• Prior Art Relied Upon: Olofsson (WO Pub. No. 2010/034157) and Kuruvilla (Application # 2009/0181664).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Olofsson discloses the core method of claim 6. Olofsson teaches a telecommunications infrastructure with a first (“originating”) and second (“target”) network, where an information collector (a base station or controller) collects information by selecting user terminals, instructing them to measure signals from the target network, and obtaining the measurement information. This information is provided to a coverage estimator (a “test evaluation server” or TES) which generates a coverage assessment by estimating service quality and radio coverage. Petitioner contended that to the extent Olofsson’s “estimate” is not a full “coverage assessment,” Kuruvilla explicitly teaches using a post-processing module to generate a visual coverage map from such collected data.
  • Motivation to Combine: A POSITA would combine Olofsson and Kuruvilla because they are analogous art addressing the same problem of avoiding inefficient drive tests. A POSITA would be motivated to modify Olofsson’s system to include Kuruvilla’s visual coverage map generation to enhance the usability and clarity of the coverage assessment. Further, a POSITA would incorporate Kuruvilla’s event triggers (e.g., a dropped call) to initiate Olofsson’s terminal selection process, thereby reducing unnecessary network load as recited in dependent claims.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because both references disclose well-established systems. Combining Olofsson’s data collection with Kuruvilla’s map generation would be a straightforward integration of known software techniques to produce a predictable result.

Ground 2: Claims 6-10 and 12 are obvious over Lee in view of Shrum.

• Prior Art Relied Upon: Lee (Application # 2009/0197600) and Shrum (Patent 8,285,310).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Lee discloses a system (an information collector) for collecting signal quality and location information from mobile terminals in a telecommunications infrastructure comprising a mobile communication network (first network) and a mobile broadcasting network (second network). Mobile terminals measure signal quality and report it to a management server. While Lee teaches collecting the necessary data, it does not explicitly disclose a coverage estimator that generates visual maps. Shrum remedies this by teaching a server/processor (a coverage estimator) that processes collected signal quality and location data to generate detailed coverage maps, identifying areas of poor signal strength.
  • Motivation to Combine: A POSITA would combine Lee and Shrum because their teachings are complementary components of a complete coverage assessment system. Lee provides the front-end data collection mechanism, while Shrum provides the back-end data processing and visualization engine. Combining them would create a fully functional system for assessing network coverage. A POSITA would be motivated to use the data collected by Lee’s system as input for Shrum’s system to generate actionable coverage maps, thereby enhancing network analysis and improvement efforts.
  • Expectation of Success: A POSITA would expect success in this combination because it represents a logical and predictable integration of known technologies. The measurement data output from Lee’s system is precisely the type of input data that Shrum’s system is designed to process. This hardware/software integration would be considered routine.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution. Regarding Fintiv, Petitioner stated there is no parallel litigation concerning the validity of the ’089 patent between the parties. Regarding §314(a), Petitioner argued this is not an improper follow-on petition, as the prior IPR (IPR2022-00079) was filed by a different petitioner (Ericsson) and challenged different claims. Finally, under §325(d), Petitioner asserted that the prior art and arguments presented in the petition were not previously presented to or considered by the USPTO during prosecution.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 6-10 and 12 of Patent RE48,089 as unpatentable.