Apple Inc v. Apex Beam Technologies LLC

1. Case Identification

• Case #: IPR2025-00895
• Patent #: 10,568,113
• Filed: May 2, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Xiaobo Zhang
• Challenged Claims: 1-20

2. Patent Overview

• Title: Method and Device in UE and Base Station Used for Wireless Communication
• Brief Description: The ’113 patent describes a method for beam failure recovery in a wireless communication system. The method involves a User Equipment (UE) detecting a triggering condition based on a target radio signal, then transmitting a first beam recovery request on a first channel (e.g., PUCCH) followed by a second beam recovery request on a second channel (e.g., PRACH), and subsequently monitoring for a response from the base station within defined, overlapping time windows.

3. Grounds for Unpatentability

Ground 1: Obviousness over Xia and Xia in view of Jover - Claims 1-20 are obvious over Xia, and alternatively, over Xia in view of Jover.

• Prior Art Relied Upon: Xia (Patent 10,779,350) and Jover (Application # 2015/0141026).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Xia teaches all limitations of the challenged claims. Xia describes a beam failure recovery method where a UE detects a beam failure and transmits a first beam failure recovery request (BFRQ) on a PUCCH (the claimed "first radio signal" on a "first channel"), followed by a second BFRQ on a PRACH (the "second radio signal" on a "second channel"). The UE then monitors for a beam failure recovery response (BFRP) from the base station (the "third radio signal"). Petitioner mapped the claimed "first," "second," and "third" time windows, including their overlapping nature, directly to the timing diagrams and descriptions provided in Xia.
  • Motivation to Combine (for §103 grounds): For the combination ground, Petitioner asserted that Xia teaches triggering the BFRQs upon detection of a communication failure. Jover provides specific, well-known details for implementing such detection, such as using a Bit Error Rate (BER) measurement that is higher than a threshold. A person of ordinary skill in the art (POSITA) would combine Jover with Xia to improve the accuracy and reliability of the beam failure determination, as Jover's specific triggering condition is a known and predictable solution to the general problem addressed by Xia.
  • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as both references concern detecting communication failures in wireless systems. Implementing a known metric like BER from Jover into the beam recovery scheme of Xia was argued to be a straightforward application of known techniques to achieve a predictable result.
  • Key Aspects: The core of this ground focused on the claim limitation requiring a "target measurement value, when higher than a target threshold is used for triggering" the transmissions. Petitioner argued that while Xia makes this obvious as a simple design choice (e.g., using BER instead of SNR), Jover explicitly discloses using a BER measurement that is higher than a 1% threshold to trigger a corrective beam procedure.

Ground 2: Obviousness over 3GPP-LTE - Claims 1, 3-4, 6, and 8-9 are obvious over 3GPP-LTE.

• Prior Art Relied Upon: 3GPP-LTE (a collection of publicly available 3rd Generation Partnership Project Long Term Evolution technical specifications, including TS 36.321, TS 36.133, and others).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that the standard Contention-Based Random Access Procedure (CBRAP) defined in the 3GPP-LTE specifications inherently teaches the claimed method. The "first radio signal" was mapped to the Random Access (RA) Preamble (Msg1) sent on the PRACH ("first channel"). The "second radio signal" was mapped to the scheduled uplink transmission (Msg3) sent on the PUSCH ("second channel"). The "third radio signal" was the contention resolution message (Msg4) monitored by the UE. The trigger for this entire process is the detection of radio link failure, where the UE's measurement of a cell-specific reference signal (CRS) indicates link quality is worse than a defined threshold (Qout), satisfying the "higher than a target threshold" limitation.
  • Motivation to Combine (for §103 grounds): Not applicable, as this ground relies on a single prior art system (3GPP-LTE). A POSITA would have understood the collection of 3GPP Technical Specifications (TS) as a single, interrelated standard meant to be read together to implement procedures like CBRAP.

Ground 3: Obviousness over 3GPP-LTE in view of Yi - Claims 11, 13-14, 16, & 18-19 are obvious over 3GPP-LTE in view of Yi.

• Prior Art Relied Upon: 3GPP-LTE (as above) and Yi (Application # 2017/0215207).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground extended the arguments from Ground 2 to cover the apparatus claims. Petitioner argued that while 3GPP-LTE describes the CBRAP method, the Yi reference provides the explicit hardware structure for a UE and base station (eNB) designed to perform that exact procedure. Yi discloses a UE with an RF module containing a receiver and transmitter, a processor, and memory, and describes these components as implementing the CBRAP steps.
  • Motivation to Combine (for §103 grounds): A POSITA seeking to build a device compliant with the 3GPP-LTE standard would be motivated to consult prior art like Yi for known and conventional hardware implementations. Yi expressly states its applicability to LTE systems and provides the necessary modules (e.g., receiver and transmitter modules) to carry out the CBRAP functions described in the 3GPP-LTE standard.
  • Expectation of Success (for §103 grounds): Success would be expected because the combination merely involved implementing a standardized procedure (from 3GPP-LTE) using a conventional hardware architecture (from Yi) that was explicitly designed for that purpose, which is a predictable integration of known elements.

4. Key Claim Construction Positions

• Petitioner argued that no special claim constructions were necessary and that all terms should be given their plain and ordinary meaning.
• Petitioner specifically contended that the Patent Owner's previously proposed constructions for "first time window," "second time window," and "third time window" were improper attempts to import limitations from the specification into the claims. For example, Petitioner argued the claims do not require receipt of the third radio signal, only monitoring for it. Petitioner asserted the prior art renders the claims obvious even under the Patent Owner's proposed constructions.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’113 patent as unpatentable.