PTAB

IPR2025-00901

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device for Wireless Communication
  • Brief Description: The ’721 patent discloses an uplink transmission scheme in a wireless communication system. The technology aims to reduce collisions in grant-free transmissions by using a first wireless signal (e.g., on a Random Access Channel or RACH) to determine the transmission properties of a second wireless signal (e.g., on a Physical Uplink Shared Channel or PUSCH), such as its timing, resource allocation, and whether it is transmitted.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lee, Freda, and Ly - Claims 1-20 are obvious over Lee in view of Freda and Ly.

  • Prior Art Relied Upon: Lee (Application # 2017/0019930), Freda (Application # 2019/0320467), and Ly (Application # 2018/0097590).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Lee, Freda, and Ly discloses all limitations of the challenged claims. Lee was asserted to teach the foundational 2-step random access procedure where a user equipment (UE) transmits a RACH preamble (the "first wireless signal") followed by an RRC message on a PUSCH (the "second wireless signal"). Lee discloses that the timing and resource allocation for the PUSCH transmission are determined based on the RACH preamble to avoid collisions in a grant-free system.

    • Petitioner asserted Freda supplements Lee by teaching specific "association rules" to implement this adaptive resource allocation, namely using configurable time and frequency "offsets" between the preamble and data transmissions. The combined teachings of Lee and Freda disclose using the first signal (RACH preamble) to determine a time interval ("first time interval" derived from Freda's time offset), which is then used to determine the specific wireless resource for the second signal from a set of candidate resources. For example, the time offset determines a subframe, and a frequency offset determines a specific resource block within that subframe.

    • For the limitation of using the first signal to determine whether the second signal is transmitted, Petitioner pointed to Lee's disclosure of a collision-avoidance mechanism. In Lee, when multiple UEs compete for limited resources, UEs with lower-priority preamble sequences "abandon" their PUSCH transmission if no resources are available, thereby using the preamble to determine if the transmission occurs.

    • Finally, Petitioner argued that Ly supplies the notoriously well-known teaching that the RACH preamble (the "first sequence") is a Zadoff-Chu (ZC) sequence, a standard choice for improving communication reliability.

    • Motivation to Combine: A POSITA would combine Lee and Freda because both address the identical technical problem of reducing collisions in grant-free 2-step RACH procedures. Freda provides specific, compatible, and predictable implementation details (configurable time/frequency offsets) for Lee's broader adaptive resource allocation framework, representing a known technique to improve a similar device. A POSITA would have been motivated to incorporate Ly's teaching of using a ZC sequence for the RACH preamble as a standard, well-known design choice to improve the reliability and performance of the Lee-Freda system.

    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success. The combination involved integrating compatible systems addressing the same problem, applying known techniques (Freda's offsets) to a known system (Lee's 2-step RACH), and using a standard component (Ly's ZC sequence) to achieve the predictable results of improved resource management and communication reliability.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It noted its intent to use the bifurcated briefing process contemplated by the March 26, 2025, Stewart Memorandum to rebut any contentions to the contrary that might be offered by the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’721 patent as unpatentable.