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IPR2025-00897

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device for Multi-Antenna Transmission in UE and Base Station
  • Brief Description: The ’527 patent discloses methods for managing multi-antenna transmissions in Multiple-Input Multiple-Output (MIMO) wireless systems. The technology aims to reduce signaling overhead by associating a time resource pool with an antenna port group, allowing user equipment (UE) to more efficiently determine resource locations and antenna virtualization vectors for receiving signals.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kim, Dahlman, and Kim-966 - Claims 1-20 are obvious over Kim, Dahlman, and Kim-966.

  • Prior Art Relied Upon: Kim (Application # 2013/0182594), Dahlman (a 2014 textbook titled 4G: LTE/LTE-Advanced for Mobile Broadband), and Kim-966 (Application # 2015/0162966).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of these references teaches every limitation of the challenged claims. Kim disclosed the foundational MIMO system, teaching the transmission of a "first radio signal" (a Channel State Information-Reference Signal, or CSI-RS) from a base station to a UE using multiple (K) antenna port groups to improve channel quality. This established the basic framework of independent claims 1, 6, 11, and 16. However, Kim did not explicitly detail how to manage the mapping of logical antenna ports to physical antennas, a key source of overhead.

    • To address this, Petitioner asserted a POSITA would look to Kim-966, which specifically taught using an "antenna virtualization matrix" (comprising one or more "antenna virtualization vectors") to efficiently map a set of M logical CSI-RS antenna ports to a larger set of N physical antennas. Petitioner argued this directly supplied the "first antenna virtualization vector" and "second antenna virtualization vector" limitations associated with the antenna port group, as recited in claims 1, 6, 11, and 16. Kim-966 explained that this matrix is configured for each UE and communicated via control information, making the vectors "available" to the UE.

    • Petitioner used the Dahlman textbook to provide the well-established technological context of the LTE-Advanced architecture in which a POSITA would have operated. Dahlman described standard concepts such as using control signaling (a "first signaling," like a System Information Block or SIB) to inform the UE of resource allocations. This signaling determines a "first time resource pool" by assigning specific subframes for uplink or downlink, often in a discontinuous manner for Time Division Duplexing (TDD) configurations, thereby teaching the corresponding claim limitations. Dahlman also explained how a subset of a time resource pool, such as specific OFDM symbols within a subframe, constitutes a "time resource sub-pool."

    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to combine these references to solve the known problem of excessive signaling overhead in massive MIMO systems. A POSITA implementing Kim’s system, which uses many antenna ports, would have naturally sought to integrate the known efficiency-improving technique of antenna virtualization taught by Kim-966. The Dahlman textbook provided the standard, ubiquitous LTE framework, representing the background knowledge and predictable environment in which a POSITA would combine these compatible technologies. The combination was argued to be a predictable implementation of known elements to achieve an expected result.

    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because all three references operate within the same compatible 3GPP LTE-Advanced technical framework. Combining Kim's CSI-RS transmission scheme with Kim-966's virtualization matrix within the standard architecture described by Dahlman was a straightforward application of known techniques to achieve the predictable benefits of improved channel estimation and reduced overhead.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial of institution is unwarranted. Petitioner stated its intent to utilize the bifurcated briefing process, as outlined in the March 26, 2025, Stewart Memorandum, to rebut any arguments for discretionary denial that the Patent Owner might present.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 10,944,527 as unpatentable under 35 U.S.C. §103.