PTAB

IPR2025-00763

OnePlus Technology Shenzhen Co Ltd v. Pantech Wireless LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Releasing Shared Enhanced Dedicated Channel Resources
  • Brief Description: The ’838 patent addresses problems with using shared channels, like the random access channel (RACH), for non-real-time data services in 3GPP networks. The patent discloses a method for a wireless transmit/receive unit (WTRU) to manage uplink resources by receiving a radio resource control (RRC) message that includes information for a medium access control (MAC) timer, which triggers the deactivation of the resources upon expiring.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zeira - Claims 1-10 are obvious over Zeira.

  • Prior Art Relied Upon: Zeira (Application # 2004/0114574).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zeira teaches all limitations of the challenged claims. Zeira discloses a system for allocating a temporary dedicated channel (temp-DCH) to a WTRU for a predetermined "duration" to improve efficiency for non-real-time data. Petitioner contended this temp-DCH corresponds to the claimed "indicated uplink resources" and its "duration" corresponds to the "MAC timer information." Zeira's WTRU receives this information via an RRC message, transmits data using the temp-DCH, and automatically releases (deactivates) the resources when the duration expires. Petitioner asserted that Zeira’s disclosure of a MAC controller that processes signals and configures the MAC layer would have rendered the claimed "processor" obvious to a person of ordinary skill in the art (POSITA). The method claims 6-10 were argued to be obvious for the same reasons as their corresponding apparatus claims 1-5.
    • Key Aspects: The central thesis of this ground is that Zeira’s concept of a channel assigned for a specific "duration," communicated via an RRC message, and automatically released upon expiration, directly maps to the claimed invention's use of a MAC timer configured by an RRC message to control resource deactivation.

Ground 2: Obviousness over Zeira in view of Yi - Claims 1-10 are obvious over Zeira and Yi.

  • Prior Art Relied Upon: Zeira (Application # 2004/0114574) and Yi (Application # 2005/0174956).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative, asserting that to the extent Zeira is found not to explicitly teach certain elements, Yi supplies the missing disclosures. Specifically, Yi explicitly teaches that a mobile terminal includes a "processor" and that a resource-release timer can be implemented in the second layer of the radio protocol, such as at a "MAC entity." Petitioner argued that Yi's explicit teaching of a processor and a MAC-layer timer confirms the obviousness of including these features in Zeira’s WTRU. Yi's MAC timer releases a radio bearer if no data is received before the timer expires, which is analogous to Zeira's duration-based release.
    • Motivation to Combine: Petitioner argued a POSITA would combine the references to implement Zeira's duration-based resource management with a known and reliable technique. A POSITA reading Zeira would be motivated to look for efficient ways to implement the "duration" timer and would find Yi’s disclosure of a MAC-layer timer to be a suitable and predictable solution. Implementing the timer at the MAC layer, as taught by Yi, is a logical design choice for managing channel access, which is a fundamental function of the MAC layer.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Zeira already described configuring the MAC layer based on information in received RRC messages. Therefore, integrating a MAC-layer timer based on duration information from that same message, as suggested by Yi, would be a straightforward implementation of known technologies to achieve a predictable result.

4. Key Claim Construction Positions

  • uplink resources: Petitioner noted a dispute over this term in co-pending litigation. Petitioner contended the term should be construed as "resources that include at least an indication of a spreading code." However, Petitioner argued that the cited prior art, particularly Zeira, discloses this element under either its proposed construction or the patent owner's proposed "plain and ordinary meaning," as Zeira’s RRC messages are alleged to contain channelization codes and their spreading factors.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-10 of the ’838 patent as unpatentable under 35 U.S.C. §103.