PTAB

IPR2025-00788

Samsung Electronics Co Ltd v. GenghisComm Holdings LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Carrier Interferometry Coding for Communications
  • Brief Description: The ’568 patent describes methods and systems using Carrier Interferometry (CI) coding for signal processing. The technology involves applying an invertible transform function, such as a Fourier transform, to spread data symbols across multiple subcarriers in a multicarrier system like Orthogonal Frequency Division Multiplexing (OFDM) to reduce the signal's peak-to-average-power ratio (PAPR).

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 6, and 20 are anticipated by or obvious over Galda

  • Prior Art Relied Upon: Galda (Dirk Galda & Hermann Rohling, A Low Complexity Transmitter Structure for OFDM-FDMA Uplink Systems, IEEE 55th Vehicular Technology Conference, May 2002).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Galda, a conference paper describing an OFDM-FDMA transmitter, disclosed all limitations of independent claim 1. Galda taught dividing a block of complex-valued symbols into sets (columns of a matrix), performing transform precoding via a Discrete Fourier Transform (DFT) spreading matrix, generating an OFDM signal from the resulting symbols, and explicitly stated this technique reduces the PAPR. Petitioner further mapped Galda’s teachings to dependent claims 2 (use of DFT coefficients), 6 (mapping to physical resource blocks in an uplink shared channel), and 20 (the resulting signal being an SC-FDMA symbol).
    • Motivation to Combine (for §103 grounds): Not applicable for anticipation. For obviousness, Petitioner argued that even if any minor element were not explicitly disclosed, it would have been obvious to a person of ordinary skill in the art (POSITA) to implement Galda’s teachings as claimed, as Galda’s system was designed for the exact purpose described in the patent.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because Galda provided a complete transmitter architecture and explicitly stated that its DFT-based spreading technique would significantly reduce PAPR.

Ground 2: Claims 10-11 are obvious over Galda in view of TS36.211

  • Prior Art Relied Upon: Galda and TS36.211 (3GPP TS 36.211, Evolved Universal Terrestrial Radio Access (E-UTRA); Physical Channels and Modulation, June 2009).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Galda’s transmitter architecture, which generates complex-valued symbols from a data stream, lacked the specific "scrambling a block of bits of one subframe" recited in claim 10. Petitioner argued that TS36.211, an LTE technical specification, explicitly taught this missing element, including scrambling a block of bits within a defined subframe before modulation using a pseudo-noise code (claim 11).
    • Motivation to Combine (for §103 grounds): A POSITA would combine TS36.211's standard scrambling technique with Galda's transmitter to gain known benefits. These benefits included further reducing PAPR by avoiding long runs of identical bits and randomizing the bit stream to improve forward error correction, both of which were well-known advantages of scrambling in OFDM systems.
    • Expectation of Success (for §103 grounds): Success was expected because scrambling was a "common practice" in modems and its application to an OFDM system like Galda's was a straightforward implementation of a standard technique to achieve predictable improvements.

Ground 3: Claims 1-3, 6-7, 10-11, and 20 are obvious over Kaiser in view of Bury

  • Prior Art Relied Upon: Kaiser (Stefan Kaiser, Multi-Carrier CDMA Mobile Radio Systems, Jan. 1998) and Bury (Andres Bury & Jurgen Linder, Comparison of Amplitude Distributions for Hadamard Spreading and Fourier Spreading, IEEE Global Telecommunications Conference, Nov. 2000).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Kaiser taught a multi-carrier OFDM transmitter that disclosed most claim elements, including dividing symbols into sets, transform precoding, and generating an OFDM signal. However, Kaiser used Walsh-Hadamard codes for spreading. Bury evaluated different spreading codes and concluded that using DFT-based "Fourier spreading" was "the best choice" for improving PAPR in systems like Kaiser's. This combination supplied the claimed use of DFT-based codes.
    • Motivation to Combine (for §103 grounds): A POSITA would have been explicitly motivated to replace Kaiser’s Walsh-Hadamard spreading with Bury’s DFT spreading because Bury directly compared the two techniques in the same technical context and demonstrated the superiority of DFT spreading for reducing PAPR. This represented the simple substitution of a known, superior element for an older one to improve performance.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success because Bury’s teachings were directly applicable to Kaiser's system, and implementing a DFT required only well-understood mathematical techniques.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Galda or Kaiser with Dowling (Patent 6,597,745) to argue for implementing the methods in a processor-and-memory-based apparatus, and further combinations involving Bury and TS36.211.

4. Key Technical Contentions (Beyond Claim Construction)

  • Effective Filing Date and Post-AIA Status: A central contention of the petition was that the ’568 patent was not entitled to its claimed priority date before May 13, 2014, making it a post-America Invents Act (AIA) patent. Petitioner argued that the patent’s priority chain was broken because intervening applications in the family substantively rewrote the disclosure to focus on a different invention ("cooperative networking") and failed to incorporate the original disclosure by reference. This break in continuity, Petitioner argued, reset the effective filing date and made post-AIA prior art and law applicable to the challenge.

5. Arguments Regarding Discretionary Denial

  • Fintiv Factors: Petitioner argued that discretionary denial under Fintiv would be inappropriate. Key reasons included that Petitioner would seek a stay in the parallel district court litigation, the court's trial date was over a year away and uncertain, and investment in the parallel case was minimal as it remained in early stages. Petitioner also offered a stipulation not to pursue the same grounds in district court if the IPR was instituted, and argued the compelling merits of the petition, based on prior art not considered during prosecution, weighed heavily in favor of institution.
  • §325(d) Factors: Petitioner contended that denial under §325(d) was unwarranted because the primary prior art references central to its grounds, particularly Galda and Kaiser, were never cited, considered, or discussed by the Examiner during the prosecution of the ’568 patent or its predecessors.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6, 10-11, 20, 24-26, 29, 32-34, 44, and 47 of Patent 10,389,568 as unpatentable.