PTAB

IPR2025-00906

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Scheduling Activation and Release
  • Brief Description: The ’434 patent relates to methods for a wireless device to validate Downlink Control Information (DCI) used to activate or release communication resources. The core technology involves a conditional validation logic where the validation process changes depending on whether certain bits in the received DCI indicate a specific configuration index.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-6, 9-15, and 18-20 are obvious over the "3GPP-Combination"

  • Prior Art Relied Upon: 3GPP-38.213 (a 3GPP technical specification), 3GPP-38.213-CR (a draft change request to 3GPP-38.213), and 3GPP-38.212-CR (a related draft change request).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combined teachings of these 3GPP standards documents render the challenged claims obvious. The central argument focused on independent claims 1 and 12, which recite a conditional DCI validation method. The references allegedly disclose two distinct scenarios for DCI validation: (1) when a User Equipment (UE) has multiple configurations, the HARQ process number field (first bits) indicates a specific configuration index, and validation relies only on the redundancy version field (second bits); and (2) when a UE has a single configuration, the HARQ process number field does not indicate an index, and validation relies on both fields. Petitioner asserted this directly maps to the conditional validation logic recited in limitations [1.3.1]/[12.3.1] and [1.3.2]/[12.3.2] of the challenged claims.
    • Motivation to Combine: A POSITA would combine these references because 3GPP-38.213-CR and 3GPP-38.212-CR are explicit "Draft Change Requests" intended to modify, clarify, and enhance the base 3GPP-38.213 standard. A person skilled in the art implementing the standard would naturally consult such change requests to understand its full operation and forthcoming features.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the teachings. The documents all relate to the same 5G-NR technical standard, were discussed within the same 3GPP working groups, and were intended to work together to define a cohesive system for DCI validation.

Ground 2: Claim 3 is obvious over the 3GPP-Combination in view of R2-1913143

  • Prior Art Relied Upon: The 3GPP-Combination (3GPP-38.213, 3GPP-38.213-CR, 3GPP-38.212-CR) and R2-1913143 (a 3GPP discussion document).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 3, which adds the limitation of transmitting a "confirmation control element." Petitioner argued that while the primary 3GPP-Combination teaches the activation and deactivation of resources, R2-1913143 explicitly discloses a "Confirmation MAC CE" (Medium Access Control Control Element). This MAC CE uses a bitmap field to efficiently report the activation or deactivation status of multiple configured grants, thereby providing the missing element of claim 3.
    • Motivation to Combine: A POSITA would combine R2-1913143 with the 3GPP-Combination to solve known problems in the art. R2-1913143 was proposed to achieve significant benefits, including resource savings, reduced UE processing, and preventing misalignment between the UE and the network when managing multiple grants—all desirable goals for a network designer.
    • Expectation of Success: Success would be expected as R2-1913143 was a specific proposal aimed at improving the functionality of the systems described in the primary 3GPP references.

Ground 3: Claims 7, 8, 16, and 17 are obvious over the 3GPP-Combination in view of 3GPP-38.331-CR

  • Prior Art Relied Upon: The 3GPP-Combination (3GPP-38.213, 3GPP-38.213-CR, 3GPP-38.212-CR) and 3GPP-38.331-CR (a draft change request).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted dependent claims requiring the receipt of "bandwidth part configuration parameters." Petitioner contended that 3GPP-38.331-CR, another draft change request, explicitly adds support for managing multiple configured grants within a single Bandwidth Part (BWP). It allegedly discloses the specific information elements (IEs), such as BWP-UplinkDedicated and BWP-DownlinkDedicated, that contain the claimed bandwidth part parameters for the plurality of configurations.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the teachings of 3GPP-38.331-CR to enhance the base standard for ultra-reliable and low latency communication (URLLC), which was the stated purpose of the change request. This provided a clear reason to add its functionality to the system defined by the primary references.
    • Expectation of Success: A POSITA would have expected success in this combination, as it involved integrating a proposed standards enhancement into the existing, related standards framework to improve network performance.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It further stated its intent to utilize the bifurcated briefing process, as contemplated by the March 26, 2025, Stewart Memorandum, to rebut any arguments for denial that may be offered by the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 10,965,434 as unpatentable under 35 U.S.C. §103.