PTAB

IPR2025-00896

Apple Inc v. Apex Beam Technologies LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device Used for Wireless Communication in UE and Base Station
  • Brief Description: The ’081 patent describes methods for wireless communication where a User Equipment (UE) receives a data signal ("first radio signal") and a control signal ("second radio signal"). The system uses different multi-antenna reception beams for different portions of the data signal, switching from a default beam to a target beam at a specific "first time point" within a time unit.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are obvious over Chen in view of 3GPP

  • Prior Art Relied Upon: Chen (Patent 11,039,470) and 3GPP (a collection of 3rd Generation Partnership Project LTE Release 14 Technical Specifications, including TS 36.201, TS 36.211, TS 36.212, and TS 36.213).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen taught the core inventive concept: a method for symbol-level beam switching within a single time slot. Chen disclosed a base station transmitting a control message ("second message") followed by a data message ("first message") to a UE. The control message contained beam indication information. The data message was split into two parts; the first part was decoded using a default beam, while the second part was decoded using a new target beam indicated in the control message. The transition point between these parts constituted the claimed "first time point." Petitioner asserted that 3GPP supplied the standard implementation details for an LTE system that Chen, by design, omitted. Specifically, 3GPP taught that the data signal would be generated from a "first bit block" and would comprise a positive integer (G) of multicarrier symbols (e.g., OFDM symbols), thus satisfying the remaining limitations of independent claims 1, 5, 9, and 11.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) implementing Chen’s beam-switching method, which explicitly stated its applicability to 3GPP-LTE systems, would have been motivated to consult the 3GPP standards. This consultation would be necessary to implement fundamental, standardized features like signal generation from bit blocks and the use of OFDM multicarrier symbols for constructing and transmitting messages over a compliant wireless link.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining these teachings. The 3GPP specifications provided well-known, established, and standardized techniques essential for creating and transmitting radio signals in any LTE system, including one implementing Chen's method.

Ground 2: Claims 1-12 are obvious over Chen in view of Dahlman

  • Prior Art Relied Upon: Chen (Patent 11,039,470) and Dahlman (a 2016 textbook titled 4G LTE-Advanced Pro and The Road to 5G).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument, with Dahlman serving as the source for fundamental LTE principles instead of the 3GPP standards. Petitioner again relied on Chen to teach the primary beam-switching procedure. Dahlman, as an authoritative textbook, was argued to provide the foundational knowledge a POSITA would use to implement Chen's method. This included describing how radio signals are formed from bit blocks (transport blocks), the use of a positive integer number of multicarrier OFDM symbols in a time slot, and that a control message (Chen's "second message") would contain Downlink Control Information (DCI) for determining the time-domain resources of the data symbols.
    • Motivation to Combine: Petitioner contended that because Chen focused on the specific problem of symbol-level beam switching, it was silent on the basic mechanics of LTE downlink signaling. A POSITA seeking to implement Chen's technique would have turned to a standard pedagogical resource like Dahlman to understand and apply these fundamental aspects. The motivation was to fill the gaps in Chen's disclosure with the well-established, conventional procedures described in Dahlman.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because Dahlman described well-known and established techniques for creating radio signals in LTE. Combining these standard techniques with Chen's specific beam-switching improvement was presented as a predictable and straightforward integration of known elements.

4. Key Claim Construction Positions

  • Petitioner argued that no terms required construction and that the plain and ordinary meaning should apply. However, in anticipation of Patent Owner's arguments from a prior IPR, Petitioner contested the construction of "the second radio signal is used for determining a time-domain resource occupied by the G multicarrier symbols."
  • Petitioner argued that Patent Owner's proposal to add the words "each of" before "the G multicarrier symbols" was an improper attempt to inject a narrowing limitation into the claim. Petitioner contended this construction was inconsistent with the patent's own embodiments and would exclude them.

5. Arguments Regarding Discretionary Denial

  • Petitioner asserted that discretionary denial would be unwarranted. It explicitly stated its intent to utilize the bifurcated briefing process introduced by the USPTO's Stewart Memorandum to rebut any discretionary denial contentions that the Patent Owner might raise.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-12 of Patent 10,912,081 as unpatentable.