PTAB

IPR2025-00904

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 ’904 patent describes a technique for improving transmission quality in a multi-antenna wireless system. The system involves a base station obtaining a proportional relationship among reception qualities corresponding to multiple beams to generate a more accurate serving beam for a user equipment (UE).

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Kim in view of Chen.

  • Prior Art Relied Upon: Kim (Application # 2015/0036612) and Chen (WO 2015/131494).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Kim and Chen taught every limitation of the challenged claims. Kim disclosed a wireless communication system where a UE performs Reference Signal Received Power (RSRP) measurement reporting for multiple-input multiple-output (MIMO) systems. A base station in Kim transmitted Channel State Information-Reference Signals (CSI-RSs) from a set of antenna ports (the claimed K antenna port groups), and the UE reported back on a subset of those signals (the claimed K1 antenna port groups) whose RSRP ratio exceeded a predetermined threshold. This reporting included both indexes of the best CSI-RSs and their RSRP estimation results, which Kim defined as a ratio of that signal's power to the best signal's power, satisfying the claimed first proportional sequence that corresponds to a ratio(ratios). Kim’s system used Radio Resource Control (RRC) signaling from the base station to the UE to provide CSI-RS configuration information, which constituted the claimed first signaling used to determine the antenna port groups.

    • Petitioner asserted that to the extent Kim did not explicitly teach that the base station signals the RSRP ratio threshold to the UE, Chen supplied this teaching. Chen described a similar channel information feedback method where a UE selects pilot ports based on received signal quality. Crucially, Chen taught that the selection was based on a "power threshold configured by the base station," which could be a "relative threshold" based on a "power ratio." This directly corresponded to the claimed limitation that the first signaling is used to determine a target threshold. The combination, therefore, taught a UE receiving RRC signaling to configure antenna port groups and a relative power threshold (Kim and Chen), receiving a wireless signal in the form of CSI-RSs from those ports (Kim), and transmitting back measurement information based on that threshold (Kim). Petitioner contended this combination rendered independent claims 1 (UE method), 6 (base station method), 11 (UE apparatus), and 16 (base station apparatus) obvious, as well as all dependent claims.

    • Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would combine Kim and Chen to achieve predictable benefits. A POSITA implementing Kim’s MIMO system would have been motivated to incorporate Chen’s teaching of a base-station-configured relative power threshold to facilitate seamless operational control and dynamic adjustment. Kim already taught using RRC signaling to send various parameters to the UE, making it an obvious and operationally convenient mechanism to also transmit the power threshold taught by Chen. This would improve overall system performance and consistency by allowing the base station to dynamically manage how UEs select and report channel quality, which is particularly beneficial in mobile communications. The combination involved applying a known technique (base station configuring a relative power threshold) to a known system (Kim's MIMO system) to improve its function.

    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because the combination involved the predictable use of prior art elements according to their established functions. Implementing a configurable power threshold via RRC signaling was a known technique for managing UE reporting, and its integration into Kim’s existing RRC signaling framework would predictably yield enhanced control over the system without altering the fundamental operations of Kim's MIMO system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. Petitioner stated its intent to use the bifurcated briefing process outlined in the March 26, 2025, Stewart Memorandum to rebut any contentions regarding discretionary denial that the Patent Owner might raise.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) for claims 1-20 of the ’904 patent and cancellation of those claims as unpatentable.