PTAB

IPR2025-00903

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 User Equipment (UE) and Base Station
  • Brief Description: The ’110 patent is directed to methods and devices for multi-antenna transmission in Multiple-Input Multiple-Output (MIMO) systems. It purports to solve problems of signaling overhead in massive MIMO systems by associating a time resource pool with an antenna port group, enabling a UE to efficiently determine the location of resources and the antenna virtualization vectors used for receiving signals.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kim, Dahlman, and Kim-966 - Claims 1-20 are obvious over Kim in view of 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 a MIMO system where a base station transmits Channel State Information Reference Signals (CSI-RS) to UEs using multiple antenna port groups to minimize overhead. Kim-966 addressed the same problem by teaching the use of an "antenna virtualization matrix," containing virtualization vectors, to map a smaller set of logical CSI-RS antenna ports to a larger set of physical antennas, thereby improving efficiency. Dahlman, a textbook on the subject, described the well-established LTE/LTE-Advanced framework, including the time-frequency grid, the use of control signaling (e.g., System Information Blocks or SIBs), and MIMO architecture, providing the standard context in which a person of ordinary skill in the art (POSITA) would implement the techniques of Kim and Kim-966.
    • Petitioner asserted that Kim taught the core method of a UE receiving a radio signal (CSI-RS) transmitted by K antenna port groups (claim 1). For example, Kim’s Figure 2 showed a CSI-RS transmission using four antenna ports divided into two groups. The "first signaling" of claim 1 was argued to be the control information, such as a SIB described by Dahlman, which is used to allocate resources like a "first time resource pool" (a collection of subframes). The "antenna virtualization vector" limitation was met by Kim-966, which explicitly taught using an antenna virtualization matrix (comprising vectors) to map the logical antenna ports of Kim to physical antennas for transmission. Petitioner contended that this virtualization vector would be associated with Kim's antenna port groups and made available to the UE via configuration information, as taught by Kim-966.
    • Motivation to Combine: Petitioner presented several motivations for a POSITA to combine the references. The primary motivation was to improve the efficiency of the massive MIMO system described in Kim by applying the known virtualization techniques of Kim-966, all within the standard, analogous LTE architecture detailed in Dahlman. A POSITA would have recognized that Kim’s system, with its large number of antennas, would benefit from Kim-966’s method for managing antenna ports and reducing overhead. The combination was not arbitrary but driven by the functional necessity of implementing advanced MIMO techniques within the standard architecture, leading to the predictable outcome of improved channel estimation and system performance. Further motivations included addressing the known challenge of backward compatibility and responding to market demand for more efficient, scalable MIMO systems.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because all three references operated within the same, compatible LTE-Advanced framework and addressed complementary aspects of MIMO system design. Kim and Kim-966 disclosed similar infrastructures and aimed to solve the same technical problem of signaling overhead. Therefore, implementing Kim-966's established virtualization techniques into Kim's system, as guided by the standard practices in Dahlman, would predictably yield an improved, more efficient system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It noted its intent to use the bifurcated briefing process introduced by the USPTO in March 2025 to rebut any contrary contentions from the Patent Owner regarding discretionary denial.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’110 patent as unpatentable.