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

Petition

Petition summary

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

## 1. Case Identification
- Case Number: [IPR2025-00637](https://ai-lab.exparte.com/case/ptab/IPR2025-00637)
- Patent #: Patent [9,763,283](https://ai-lab.exparte.com/patent/9763283)
- Filed: March 18, 2025
- Petitioner(s): [OnePlus Technology (Shenzhen) Co., Ltd.](https://ai-lab.exparte.com/party/oneplus-technology-shenzhen-co-ltd); [Guangdong OPPO Mobile Telecommunications Corp., Ltd.](https://ai-lab.exparte.com/party/guangdong-oppo-mobile-telecommunications-corp-ltd)
- Patent Owner(s): [Pantech Corporation](https://ai-lab.exparte.com/party/pantech-wireless-inc)
- Challenged Claims: 1-13

## 2. Patent Overview
- Title: Radio Link Control in Dual Connectivity Systems
- Brief Description: The ’283 patent discloses methods and apparatuses for radio link control in wireless communication systems that support dual connectivity. The invention focuses on individually managing radio links by declaring a radio link failure (RLF) on an affected secondary link while continuing data transmission on the primary link.

## 3. Grounds for Unpatentability
#### Ground 1: Claims 1-13 are anticipated or, in the alternative, obvious over Dudda
- **Prior Art Relied Upon:** Patent 10,631,222 ("Dudda").
- **Core Argument for this Ground:**
  - **Prior Art Mapping:** Petitioner asserted that Dudda, which addresses RLF handling in dual-connectivity Long-Term Evolution (LTE) systems, discloses every limitation of the challenged claims. Dudda teaches a user equipment (UE) that detects an RLF on a secondary serving cell ("assisting cell"), generates an RLF indicator ("RLF warning message"), and transmits it to the master base station ("source eNB"). The central argument was that Dudda’s disclosure of the UE "stop[ping] the transmission on this link" upon RLF inherently teaches the specific limitation of stopping uplink transmission of Physical Uplink Shared Channel (PUSCH), Physical Uplink Control Channel (PUCCH), and Sounding Reference Signal (SRS), which was the key feature added to overcome prior art during prosecution of the ’283 patent.
  - **Key Aspects:** This argument hinges on a person of ordinary skill in the art (POSITA)’s understanding that ceasing all uplink communication to prevent interference on a failed link would necessarily include stopping PUSCH, PUCCH, and SRS transmissions.

#### Ground 2: Claims 1-13 are obvious over Dudda in view of Pelletier
- **Prior Art Relied Upon:** Dudda (`’222 patent`), Application # 2011/0134774 ("Pelletier").
- **Core Argument for this Ground:**
  - **Prior Art Mapping:** This ground asserted that if Dudda is found not to explicitly disclose the "stopping limitation" (ceasing PUSCH, PUCCH, and SRS), Pelletier supplies the missing element. Dudda provides the foundational dual-connectivity system with RLF handling. Pelletier, which addresses the same technical problem, explicitly teaches that when a UE deactivates a secondary cell (SCell) due to RLF, it "may stop any UL transmissions (UL-SCH, PUSCH, SRS) for the deactivated SCell."
  - **Motivation to Combine:** A POSITA would combine the interrelated teachings of Dudda and Pelletier because both are analogous art addressing RLF in dual-connectivity LTE systems. A POSITA would be motivated to apply Pelletier's explicit technique for ceasing specific uplink channel transmissions to Dudda's system to achieve the predictable result of preventing interference and managing radio resources upon an RLF event.
  - **Expectation of Success:** Petitioner argued a high expectation of success, as Pelletier’s techniques are directly applicable to Dudda’s similar system and address the identical technical challenge without requiring undue experimentation.

#### Ground 3: Claims 1-13 are obvious over Lin alone or in view of Pelletier
- **Prior Art Relied Upon:** Application # 2014/110813 ("Lin"), Pelletier (`’774 application`).
- **Core Argument for this Ground:**
  - **Prior Art Mapping:** Petitioner argued that Lin, like Dudda, discloses a dual-connectivity system with RLF handling on a secondary cell and explicitly teaches actions that meet the "stopping limitation." Lin discloses "preventing spontaneous UL transmissions (PUCCH, SRS, SPS)" upon RLF detection and deactivating the RLF-affected SCell, which would stop all transmissions. To the extent Lin is viewed as not explicitly teaching the claimed hardware (e.g., processor, transmitter) or the cessation of PUSCH transmission, Pelletier was cited to provide these disclosures.
  - **Motivation to Combine:** A POSITA would combine Lin and Pelletier due to their interrelated teachings on the same subject matter. Pelletier’s explicit disclosure of hardware components (processor, transceiver) and specific UL channel cessations would be a natural and obvious addition to Lin's more method-focused disclosure to create a complete and functional apparatus.
  - **Expectation of Success:** The combination would predictably result in the claimed invention, as it involves applying a known technique (from Pelletier) to a similar system (Lin) to improve its function.

## 4. Key Technical Contentions
- The petition’s primary technical contention, central to all grounds, was the interpretation of broad disclosures like "stopping uplink transmission" (in Dudda) or "preventing spontaneous UL transmissions" (in Lin). Petitioner argued that a POSITA would understand these phrases to necessarily encompass the cessation of all key uplink channels—including PUSCH (for user data), PUCCH (for control information), and SRS (for channel sounding)—to fully mitigate interference and abandon a failed radio link, which was the stated purpose of the RLF procedures in the prior art.

## 5. Arguments Regarding Discretionary Denial
- **§325(d) (Same or Substantially Same Art or Arguments):** Petitioner argued against discretionary denial under §325(d), asserting that the primary references (Dudda, Lin, Pelletier) were never presented to or considered by the Examiner during the original prosecution. The prosecution history relied on a different reference (Lin-548), and the Patent Owner’s arguments for allowance—that Lin-548 failed to teach stopping PUCCH uplink transmission—would not apply to the current references, which explicitly teach or suggest this limitation.
- **§314(a) (Fintiv Factors):** Petitioner contended that the Fintiv factors strongly favor institution of inter partes review (IPR). Key arguments included a binding stipulation not to pursue the same invalidity grounds in the parallel district court litigation (EDTX case), the minimal investment in the litigation due to a prior stay, and the asserted strength of the petition's grounds. Petitioner also argued that the district court trial date (late April 2026) is close to the IPR statutory deadline, minimizing concerns of duplicative efforts and making that factor only marginally unfavorable to institution.

## 6. Relief Requested
- Petitioner requested the institution of an IPR and the cancellation of claims 1-13 of Patent [9,763,283](https://ai-lab.exparte.com/patent/9763283) as unpatentable under 35 U.S.C. §102 and/or §103.

OnePlus & OPPO challenge radio link control patent: Dudda & Pelletier cited against 13 claims, arguing obviousness of stopping UL channels on link failure.

IPR2025-00637

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