PTAB

IPR2025-00637

OnePlus Technology Shenzhen Co Ltd v. Pantech Corp

Key Events

Petition

petition

Title: Radio Link Control in Dual Connectivity Systems
Brief Description: The ’283 patent discloses methods and apparatuses for managing radio link control in wireless communication systems that support dual connectivity. The technology addresses scenarios where a radio link failure (RLF) occurs on one link (e.g., a secondary cell), allowing the user equipment to declare the failure for that specific link while maintaining data transmission through the other available link (e.g., a primary cell).

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 dual-connectivity system where user equipment (UE) detects an RLF on an "assisting cell" (secondary cell) and, in response, sends an RLF warning message to the "source eNB" (master base station). Crucially, Petitioner asserted that Dudda's teaching that the UE "stops uplink transmission" to the assisting cell upon detecting an RLF inherently discloses the key limitation of stopping transmission of the physical uplink shared channel (PUSCH), physical uplink control channel (PUCCH), and sounding reference signal (SRS), as these are the fundamental components of uplink transmission.
- Key Aspects: This ground asserted that Dudda's general disclosure of stopping all uplink communication is sufficient to meet the specific claim limitations, as a person of ordinary skill in the art (POSITA) would understand this to include all constituent uplink channels like PUSCH, PUCCH, and SRS.

Prior Art Relied Upon: Dudda (Patent 10,631,222) and Pelletier (Application # 2011/0134774)
Core Argument for this Ground:
- Prior Art Mapping: This ground presented an alternative argument where Dudda provides the foundational dual-connectivity system that detects an RLF on a secondary cell and stops uplink transmission. Pelletier was introduced to explicitly supply the teaching of stopping PUSCH, PUCCH, and SRS transmissions upon RLF detection on a secondary cell. Petitioner argued that Pelletier expressly teaches that when a UE deactivates a secondary cell due to an RLF, it "may stop any UL transmissions (UL-SCH, PUSCH, SRS) for the deactivated SCell."
- Motivation to Combine: Petitioner contended a POSITA would combine Dudda and Pelletier due to their "interrelated teachings." Both references address the same problem of RLF handling in dual-connectivity LTE systems. A POSITA would have looked to Pelletier's explicit disclosure of which specific uplink channels to stop to supplement Dudda's more general teaching of ceasing uplink transmission, thereby arriving at the claimed invention.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing Pelletier's specific channel-stopping techniques into Dudda's system. The combination involved applying a known technique (stopping specific UL channels) to a similar system to yield the predictable result of improved radio resource management during an RLF event.

Prior Art Relied Upon: Lin (International Publication # WO 2014/110813) and Pelletier (Application # 2011/0134774)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lin, like Dudda, discloses a dual-connectivity system where a UE detects RLF on a secondary cell and reports it to the primary base station. Lin explicitly teaches "preventing spontaneous UL transmissions (PUCCH, SRS, SPS)" upon RLF detection. Petitioner asserted this alone renders the claims obvious. Alternatively, to the extent Lin's disclosure was considered incomplete regarding PUSCH or the claimed hardware (e.g., processor), Pelletier was cited to supply these elements. Pelletier explicitly discloses stopping PUSCH and teaches the use of processors and transceivers for implementing such functions in a UE.
- Motivation to Combine: The motivation to combine Lin and Pelletier was based on their analogous nature and interrelated teachings, addressing the same technical problem. A POSITA would have been motivated to incorporate Pelletier's explicit teachings on stopping all uplink channels (including PUSCH) and its hardware descriptions into Lin's system to ensure comprehensive and efficient RLF handling.

§325(d) - Same or Substantially Same Art: Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting that the primary references (Dudda, Lin, and Pelletier) were never presented to or considered by the Examiner during the original prosecution. The Examiner's rejection was based solely on a different reference ("Lin-548"), which the Patent Owner successfully argued against by claiming it failed to teach stopping PUCCH transmission—a limitation that Dudda, Lin, and Pelletier all disclose.
§314(a) - Fintiv Factors: Petitioner argued that the Fintiv factors strongly favor institution. Key arguments included a stipulation that Petitioner will not pursue any IPR grounds in the parallel district court case if review is instituted; the asserted grounds are particularly strong; investment in the co-pending litigation has been minimal; and the district court trial date is scheduled for late April 2026, around the same time as the statutory deadline for a Final Written Decision in this IPR.

Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’283 patent as unpatentable.