PTAB

IPR2025-00637

OnePlus Technology (Shenzhen) Co., Ltd. v. Pantech Corporation

Title: Radio Link Control in Dual-Connectivity Wireless Systems
Brief Description: The ’283 patent is directed to methods and apparatus for radio link control in wireless communication systems that support dual connectivity. The technology addresses how a user equipment (UE) manages a radio link failure (RLF) on one connection (e.g., to a secondary serving cell) while maintaining an active connection on another link (e.g., to a master base station).

Prior Art Relied Upon: Dudda (Patent 10,631,222).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Dudda discloses all limitations of the challenged claims. Dudda teaches a UE operating in a dual connectivity environment with a source eNB (master station) and an assisting eNB (secondary station). Upon detecting an RLF on the link to the assisting eNB, Dudda’s UE stops all uplink transmission on that link and sends an “RLF warning message” containing a cell identifier to the source eNB. This maps directly to the independent claims’ requirements for detecting RLF, generating an indicator with a cell ID, and transmitting it to the master station. Petitioner contended that Dudda’s teaching of stopping all uplink transmission to the assisting cell upon RLF inherently or necessarily discloses stopping the specific physical uplink shared channel (PUSCH), physical uplink control channel (PUCCH), and sounding reference signal (SRS) transmissions, as these are the primary components of uplink communication.
- Key Aspects: The argument hinges on Dudda’s general disclosure of ceasing all uplink transmission upon RLF being sufficient to teach the specific channel cessations that were added to the ’283 patent claims during prosecution to overcome prior art.

Prior Art Relied Upon: Dudda (Patent 10,631,222) and Pelletier (Application # 2011/0134774).
Core Argument for this Ground:
- Prior Art Mapping: To the extent Dudda is deemed not to explicitly disclose the cessation of PUSCH, PUCCH, and SRS transmissions, Petitioner argued that Pelletier provides this teaching. Pelletier describes a dual-connectivity system where, upon detecting an RLF on a secondary cell (SCell), the UE deactivates the SCell and explicitly stops "any UL transmissions (UL-SCH, PUSCH, SRS) for the deactivated SCell."
- Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine Dudda and Pelletier because they are analogous arts addressing the identical problem of managing RLF in dual-connectivity LTE systems. A POSITA would have been motivated to incorporate Pelletier's explicit and specific technique for ceasing uplink channel transmissions into Dudda’s system to ensure that an RLF on the secondary link does not cause interference and to predictably improve resource management.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination because both references describe compatible LTE-based architectures, and applying Pelletier’s specific error-handling procedure to Dudda’s system is a straightforward implementation of a known technique to achieve a predictable result.

Prior Art Relied Upon: Lin (WO 2014/110813) and Pelletier (Application # 2011/0134774).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lin alone renders the claims obvious. Lin discloses a dual-connectivity system with an anchor eNB and a drift eNB (secondary station) and teaches performing RLF detection on the SCell. Upon RLF detection, Lin teaches taking action, including "preventing spontaneous UL transmissions (PUCCH, SRS, SPS)." Petitioner argued this, combined with Lin’s disclosure of deactivating the SCell, teaches stopping all relevant uplink transmissions. Alternatively, if Lin is found insufficient, combining it with Pelletier’s explicit disclosure of stopping PUSCH, PUCCH, and SRS upon SCell deactivation renders the claims obvious.
- Motivation to Combine: The motivation to combine Lin and Pelletier mirrors the motivation for the Dudda combination. A POSITA would look to analogous art like Pelletier to supplement Lin’s teachings to ensure all uplink transmissions, including PUSCH, are ceased upon an SCell RLF. This would be a natural design choice to prevent interference and manage system resources, based on the interrelated teachings of the references.
- Expectation of Success: Success was expected because both Lin and Pelletier address RLF in similar LTE network architectures, making the integration of Pelletier’s specific channel management techniques into Lin’s system straightforward and predictable.

§325(d) (Same or Substantially Same Art): Petitioner argued that discretionary denial under §325(d) is unwarranted because the key prior art references—Dudda, Lin, and Pelletier—were never presented to or considered by the Examiner during the original prosecution of the ’283 patent. The prosecution history focused on a different reference (Lin-548), which the Patent Owner successfully argued against by claiming it did not teach stopping PUCCH transmission. Petitioner contended the newly presented references explicitly teach or suggest this limitation, meaning the Examiner never considered the substance of the current challenge.
§314(a) (Fintiv Factors): Petitioner argued that the Fintiv factors weigh strongly in favor of instituting review.
- Petitioner stipulated that, if IPR is instituted, it will not pursue in the co-pending district court litigation any ground that was raised or reasonably could have been raised in the IPR.
- The petition is argued to be particularly strong, presenting grounds of anticipation and single-reference obviousness.
- Investment in the parallel litigation was described as minimal due to a prior stay, with only initial contentions served.
- The district court trial date is set for late April 2026, which is contemporaneous with the IPR statutory deadline, a factor Petitioner claims is neutral or only marginally favors denial.

Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of Patent 9,763,283 as unpatentable.