PTAB

IPR2025-00907

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: VALIDATION OF DOWNLINK CONTROL INFORMATION
  • Brief Description: The ’944 patent describes a method and wireless device for validating Downlink Control Information (DCI). The validation process depends on the content of the DCI; specifically, whether a Hybrid Automatic Repeat Request (HARQ) process number field indicates a configuration index and the format of the DCI.

3. Grounds for Unpatentability

Ground 1: Obviousness over 3GPP Combination - Claims 1-20 are obvious over 3GPP-213 in view of 3GPP-213-CR and 3GPP-212-CR

  • Prior Art Relied Upon: 3GPP-213 (3GPP TS 38.213 v15.7.0), 3GPP-213-CR (3GPP 38.213 Draft Change Request), and 3GPP-212-CR (3GPP 38.212 Draft Change Request).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these interoperable 3GPP standards documents taught all limitations of the challenged claims. 3GPP-213, the base standard, disclosed a baseline procedure for a User Equipment (UE) to validate DCI for scheduling activation or release, requiring the HARQ process number and Redundancy Version (RV) fields to be set to all zeros. The change request, 3GPP-213-CR, modified this by introducing procedures for when a UE is provided with multiple configurations. In such cases, the HARQ process number field indicates a configuration index, and validation is based only on the RV field, not the HARQ field. This directly maps to the mutually exclusive conditional validation steps in independent claims 1 and 11 (e.g., validating based on comparing the HARQ field vs. not validating based on it). The second change request, 3GPP-212-CR, provided the necessary details for the new DCI formats (0_2 and 1_2) referenced in 3GPP-213-CR, including their configurable HARQ and RV fields, thereby teaching the claimed "first configuration parameter" and "second configuration parameter."
    • Motivation to Combine: A POSITA would combine these references because 3GPP-213-CR and 3GPP-212-CR were explicitly designated as "Draft Change Requests" intended to modify and inform the base 3GPP-213 standard. They were part of the same standards development process for 5G-NR networks and were designed to work together.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the teachings, as the documents were created by the same 3GPP working group to define a single, coherent communication standard.

Ground 2: Obviousness over Zhang - Claims 1-20 are obvious over Zhang

  • Prior Art Relied Upon: Zhang (Patent 11,178,598).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Zhang alone rendered the claims obvious. Zhang taught a method for DCI validation for scheduling activation or release, specifying that validation is achieved if all fields, including the HARQ process number and RV fields, are set to specific values (e.g., all ‘0’s and ‘00’ respectively). Petitioner argued that the claimed step of "comparing" the HARQ field with a "first sequence" of bits (e.g., all zeros) was an obvious and fundamental way for a POSITA to implement the check required by Zhang. Zhang further disclosed using a configuration parameter (ConfiguredGrantConfig IE) to set the HARQ Process ID, which met the "first configuration parameter" limitation.
    • Motivation to Combine (for §103 grounds): Not applicable (single reference anticipation/obviousness).
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing the comparison, as determining if two values match is a basic, routine operation in the art.

Ground 3: Obviousness over Zhang in view of 3GPP-213-CR - Claims 1-20 are obvious over Zhang in view of 3GPP-213-CR

  • Prior Art Relied Upon: Zhang (Patent 11,178,598) and 3GPP-213-CR (3GPP 38.213 Draft Change Request).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplemented Zhang’s teachings with 3GPP-213-CR to explicitly address the claim limitations related to multiple configurations. While Zhang taught the primary validation method (analogous to the first conditional branch of claim 1), 3GPP-213-CR expressly disclosed the alternative scenario where the HARQ process number field is used to indicate a configuration index. In this scenario, 3GPP-213-CR taught that DCI validation is not based on the HARQ process number but on other fields like the RV field. This combination directly mapped to the mutually exclusive validation paths recited in the claims (e.g., limitations [1.2.3] and [1.2.5]).
    • Motivation to Combine: A POSITA would combine these references because Zhang explicitly incorporated aspects of the base 3GPP-38.213 standard. 3GPP-213-CR was a "Draft Change Request" to that very standard. It would have been routine for a POSITA implementing the system in Zhang to look to and incorporate proposed updates to the underlying standard to enhance functionality, such as handling multiple configurations.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as both Zhang and 3GPP-213-CR were in the same field of endeavor—physical layer control procedures for 5G-NR networks—and addressed the same DCI validation problem.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial was unwarranted and stated its intent to utilize the bifurcated briefing process contemplated by the March 26, 2025, Stewart Memorandum to rebut any contrary contentions from the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’944 patent as unpatentable.