PTAB

IPR2025-00887

OnePlus Technology Shenzhen Co Ltd v. Pantech Corp

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Performing Random Access in Wireless Communication System
  • Brief Description: The ’372 patent relates to a method and apparatus for managing random access procedures in multicarrier wireless systems. The technology involves configuring multiple component carriers (CCs) into an uplink (UL) timing group and then setting a single "delegate CC" to obtain and update the timing advance (TA) value for all carriers within that group.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tenny and Huawei - Claims 1 and 8 are obvious over Tenny in view of Huawei.

  • Prior Art Relied Upon: Tenny (Application # 2011/0158116) and Huawei (3GPP Proposal R2-100110).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tenny disclosed all elements of independent claims 1 and 8 except for the specific criteria used to select the delegate CC. Tenny taught grouping CCs with similar uplink timings into a "timing group" and using a single "carrier candidate" from that group to acquire timing updates for all CCs in the group. The specific method of selecting this carrier candidate in Tenny (e.g., via a hash function) differed from the patent’s claims.
    • Motivation to Combine: Huawei was presented as addressing the same problem of reducing overhead in multicarrier systems by suggesting a method to share a single TA value. Specifically, Huawei proposed choosing the UL CC with the lowest frequency to perform the Random Access Channel (RACH) procedure for a group of CCs sharing an identical TA value. Petitioner contended a POSITA would combine Huawei’s simple and specific delegate CC selection criterion with Tenny’s broader framework to achieve predictable results and minimize signaling overhead.
    • Expectation of Success: Both references operated in the same technical field (LTE-A multicarrier systems) and addressed the same fundamental problem of timing synchronization. Petitioner argued that substituting Huawei's simple selection rule into Tenny's system would be a straightforward modification yielding the predictable benefit of a consistent and efficient delegate CC selection process.

Ground 2: Obviousness over Tenny, Huawei, and Zhang - Claims 2 and 9 are obvious over Tenny in view of Huawei and further in view of Zhang.

  • Prior Art Relied Upon: Tenny (Application # 2011/0158116), Huawei (3GPP Proposal R2-100110), and Zhang (Application # 2010/0303039).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1. Dependent claims 2 and 9 add limitations requiring "determining whether a CC that is added or removed exists" and "reconfiguring the UL timing group based on the determined CC." Petitioner contended that Zhang taught these specific reconfiguration steps by disclosing a CC-specific reconfiguration mechanism that allows a user device to add, remove, or replace CCs as it moves between coverage areas to maintain optimal data rates.
    • Motivation to Combine: While Tenny and Huawei addressed initial timing group setup and maintenance, they were largely silent on dynamic reconfiguration during events like handovers. Zhang was argued to explicitly solve this problem. A POSITA would be motivated to incorporate Zhang's established reconfiguration scheme into the Tenny/Huawei system to handle dynamic network conditions and user mobility, which are critical aspects of wireless system design.
    • Expectation of Success: Petitioner asserted that integrating a known handover and reconfiguration solution (Zhang) into a system for managing timing groups (Tenny/Huawei) was a predictable design choice to create a more robust and comprehensive communication system.

Ground 3: Obviousness over Tenny, Huawei, and Wang - Claims 3, 4, 10, and 11 are obvious over Tenny in view of Huawei and further in view of Wang.

  • Prior Art Relied Upon: Tenny (Application # 2011/0158116), Huawei (3GPP Proposal R2-100110), and Wang (Patent 9,426,765).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground also built upon the base combination of Tenny and Huawei. The challenged dependent claims add limitations related to the specific mechanics of the random access procedure. Claim 3 required obtaining the TA value from a random access response message, and claim 4 required sensing a condition for updating the TA value, such as the expiration of a time alignment timer. Petitioner argued Wang taught these features by disclosing that a Random Access Response (RAR) message transmits the TA value and that a UE initiates a random access procedure when its time alignment timer expires.
    • Motivation to Combine: Tenny described "performing a random access procedure" at a high level without detailing its sub-steps. A POSITA would look to other art like Wang for well-known, specific implementations of that procedure. Wang provided known triggers (e.g., timer expiration) and messaging details (e.g., using an RAR message) that would have been recognized as conventional and effective ways to implement the system generally described by Tenny.
    • Expectation of Success: Supplementing Tenny's general disclosure with the specific, conventional procedural details from Wang was argued to be a straightforward implementation with a high expectation of success.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4 for claims 7 and 14) based on Tenny, Huawei, and Nokia, arguing Nokia taught selecting a primary cell (PCell) as the delegate CC.

4. Key Claim Construction Positions

  • Petitioner proposed that two terms in independent apparatus claim 8 should be construed as means-plus-function limitations under 35 U.S.C. §112, paragraph 6.
    • "a[n] uplink timing group configuring unit...": Petitioner proposed the function is to "configure an uplink (UL) timing group..." and the corresponding structure is the hardware of the User Equipment (UE) that implements this function.
    • "a delegate CC setting unit...": Petitioner proposed the function is to "set a CC satisfying... as a delegate CC" and the corresponding structure is the hardware of the UE that implements this function.

5. Arguments Regarding Discretionary Denial

  • To address potential discretionary denial under the Fintiv factors due to a parallel district court case, Petitioner stipulated that, if this IPR is instituted, it will not pursue in the co-pending litigation any invalidity ground that it raised or reasonably could have raised in the IPR. This stipulation was presented to simplify the Board's Fintiv analysis and weigh in favor of institution.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 7-11, and 14 of Patent 8,995,372 as unpatentable under 35 U.S.C. §103.