PTAB

IPR2025-00756

OnePlus Technology Shenzhen Co Ltd v. Pantech Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Enhanced Uplink Operation in Soft Handover
  • Brief Description: The ’803 patent discloses protocols for managing enhanced uplink (EU) operations during a soft handover in a third-generation (3G) mobile telecommunication system. The technology involves transferring information between a wireless transmit/receive unit (WTRU), multiple Node-Bs (base stations), and a radio network controller (RNC) to schedule radio resources efficiently.

3. Grounds for Unpatentability

Ground I: Obviousness over LTE Standards - Claims 1, 5-7, 11, and 12 are obvious over TS 36.300, TS 36.321, and TS 36.331.

  • Prior Art Relied Upon: TS 36.300 (3GPP Technical Specification 36.300 V10.6.0), TS 36.321 (3GPP Technical Specification 36.321 V10.6.0), and TS 36.331 (3GPP Technical Specification 36.331 V10.6.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that this ground is supported by the Patent Owner’s own infringement contentions from related litigation, which allegedly map these 3GPP LTE-Advanced technical specifications (the "TS36 combination") to the elements of the challenged claims. The TS36 combination discloses a User Equipment (UE) operating with a Primary Cell (PCell) and one or more Secondary Cells (SCells), all associated with a network node (eNB). The UE receives configuration information for all cells via an RRCConnectionReconfiguration message and receives messages on the PCell that activate SCells for downlink shared channel transmissions, which are then processed from the indicated SCells. This mapping is argued to meet the limitations of independent claims 1 and 7.
    • Motivation to Combine (for 35 U.S.C. §103 grounds): A person of ordinary skill in the art (POSITA) would combine these technical specifications because they are integral, cross-referencing parts of the same 3GPP LTE-A standard. Understanding and implementing the standard for carrier aggregation would necessitate their combined use.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as evidenced by the widespread industry implementation of the LTE-A standard based on these very documents.

Ground II: Obviousness over Ericsson and TS 25.331 - Claims 1, 2, 5-8, 11, and 12 are obvious over Ericsson in view of TS 25.331.

  • Prior Art Relied Upon: Ericsson (3GPP Technical Document R2-020088) and TS 25.331 (3GPP Technical Specification 25.331 V5.5.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Ericsson teaches an intra-Node B synchronized cell change procedure where a UE’s serving cell (the primary cell) is changed to a target cell (a non-primary cell) within an "active set" controlled by the same Node B. Ericsson discloses that the UE sends a MEASUREMENT REPORT which triggers the network to send a PHYSICAL CHANNEL RECONFIGURATION message to the UE; this message indicates the target cell from which the UE should begin receiving a downlink shared channel. Petitioner argued that TS 25.331 provides the necessary standard-specific details for implementing Ericsson’s proposed procedure, such as the definitions for the MEASUREMENT CONTROL message and the "Event 1d: Change of best cell" trigger criteria.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Ericsson and TS 25.331 because Ericsson was submitted as a technical contribution document intended to inform and propose modifications to the TS 25.331 standard. The references are analogous art, both concerning UMTS radio interface protocols, and implementing the mobility procedures described in Ericsson would naturally lead a POSITA to consult the foundational TS 25.331 specification.
    • Expectation of Success (for §103 grounds): The combination would involve a predictable integration of a proposed enhancement into its corresponding technical standard, which is a routine engineering task with a high likelihood of success.

Ground III: Obviousness over Ericsson, TS 25.331, and Sebire - Claims 5, 6, 11, and 12 are obvious over Ericsson and TS 25.331 in view of Sebire.

  • Prior Art Relied Upon: Ericsson (3GPP Technical Document R2-020088), TS 25.331 (3GPP Technical Specification 25.331 V5.5.0), and Sebire (International Publication No. WO 2003/034766 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon Ground II to address dependent claims related to uplink transmissions. Petitioner contended that Sebire, which discloses handover in a GPRS system, teaches using a Temporary Block Flow (TBF) to provide an uplink grant to a mobile station from the source cell. A POSITA would have understood this TBF mechanism to supply the "grant for an uplink transmission" recited in claims 5 and 11. For claims 6 and 12, Sebire’s disclosure of an "RLC acknowledged mode" was argued to teach the processing of acknowledgements for uplink transmissions.
    • Motivation to Combine (for §103 grounds): A POSITA developing 3G handover protocols (as in Ericsson/TS 25.331) would have looked to solutions for analogous problems in prior 2.5G systems (as in Sebire) to incorporate established techniques for managing uplink grants and acknowledgements, thereby enhancing the data communication system.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in combining these known communication techniques, as it involved applying established principles of uplink resource management to a known handover framework.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention raised by Petitioner is that the challenged claims are not entitled to the 2003 priority date of the parent applications. Petitioner argued that key claim limitations—specifically a system with a "primary cell" and "one or more non-primary cells" that receives "configuration information" for them—were not disclosed until the application was filed on August 6, 2019. Petitioner asserted these concepts relate to the later-developed LTE Carrier Aggregation technology, which is absent from the original 3G-focused specifications. This argument forms the basis for Ground I, which treats several 3GPP standards documents from 2011-2012 as prior art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 5-8, 11, and 12 of Patent 10,764,803 as unpatentable.