PTAB

IPR2025-00908

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Device Feedback for Semi-Persistent Scheduling Release
  • Brief Description: The ’639 patent describes methods for managing wireless communications, specifically for a user device to handle the joint deactivation or release of multiple semi-persistent scheduling (SPS) configurations. The technology focuses on providing an efficient acknowledgment feedback mechanism when multiple configurations are released simultaneously via a single downlink control information (DCI) message.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Fakoorian-1 in view of Takahashi.

  • Prior Art Relied Upon: Fakoorian-1 (Application # 2023/0084754) and Takahashi (WO 2021/064961).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fakoorian-1 teaches the core concept of the ’639 patent: jointly releasing multiple downlink SPS configurations using a single DCI message to reduce network overhead. Fakoorian-1 discloses using a bit sequence in a DCI field, such as the Hybrid Automatic Repeat Request (HARQ) process number field, to indicate which set of SPS configurations should be released. A user equipment (UE) then transmits a single acknowledgment for the joint release. Petitioner argued that Takahashi supplements Fakoorian-1 by teaching specific techniques for managing HARQ feedback when multiple SPSs are active. Crucially, Takahashi discloses configuring HARQ-ACK codebooks via higher-layer Radio Resource Control (RRC) signaling and teaches that feedback for multiple SPS configurations can be included in a single HARQ-ACK codebook, thus using the same codebook identifier for multiple configurations.
    • Motivation to Combine: A POSITA would combine these references to enhance the efficiency of Fakoorian-1’s joint release system. Fakoorian-1 addresses reducing DCI overhead for the release command, while Takahashi addresses optimizing the corresponding acknowledgment feedback. Combining them would create a more efficient system by applying Takahashi's advanced HARQ codebook management to Fakoorian-1's joint release mechanism, achieving known benefits of reduced resource consumption and more flexible control.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references operate in the same technical field (5G NR/LTE wireless standards) and address analogous problems using standard RRC and DCI signaling. Implementing Takahashi’s RRC-based codebook configuration within Fakoorian-1’s framework would be a predictable integration of known techniques.

Ground 2: Claims 1-20 are obvious over Fakoorian-2.

  • Prior Art Relied Upon: Fakoorian-2 (Patent 11,464,001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fakoorian-2, by itself, renders all challenged claims obvious. Fakoorian-2 teaches a system for the joint release of multiple SPS configurations using a single DCI message containing a bit sequence in an existing field (e.g., HARQ process number) to indicate the configurations to be released. This bit sequence corresponds to a state mapped to multiple configurations. Fakoorian-2 also discloses that the UE transmits a HARQ-ACK message to jointly acknowledge the released configurations. Petitioner contended that Fakoorian-2’s teaching that a UE "may multiplex the HARQ feedback information for the first and second SPS configurations" with one codebook implies the use of the same HARQ codebook identifier for both, thus meeting the key limitation of claim 1.

Ground 3: Claims 1-20 are obvious over Fakoorian-2 in view of Takahashi.

  • Prior Art Relied Upon: Fakoorian-2 (Patent 11,464,001) and Takahashi (WO 2021/064961).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground serves as an alternative to Ground 2. Petitioner argued that Fakoorian-2 provides the foundational system for joint SPS release. Takahashi is added to explicitly teach the claim limitation requiring a first and second HARQ codebook identifier to be the same. While Petitioner believes Fakoorian-2 inherently teaches this, Takahashi explicitly discloses that "more than one set of HARQ-ACK information for multiple SPSs" can be "included in one HARQ-ACK codebook." Takahashi further teaches using RRC signaling to configure parameters that determine which codebook to use. Therefore, the combination explicitly discloses receiving RRC messages that configure two SPS configurations to use the same HARQ codebook identifier.
    • Motivation to Combine: A POSITA implementing Fakoorian-2’s joint release system would be motivated to consult Takahashi to optimize the corresponding HARQ feedback mechanism. Takahashi directly addresses the problem of providing efficient feedback for multiple SPSs. A POSITA would combine Takahashi’s explicit teaching of using a single codebook with Fakoorian-2’s system to achieve the benefit of reduced network overhead for both the control signaling and the feedback.
    • Expectation of Success: The combination would yield predictable results, as it involves applying Takahashi’s specific HARQ feedback solution to the exact problem context described in Fakoorian-2. Both references are analogous art within the 3GPP standards framework.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. The petition noted the existence of co-pending litigation but contended that review should proceed, referencing the USPTO's interim processes for institution outlined in the March 2025 Stewart Memorandum, which Petitioner intends to utilize.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-20 of Patent 11,108,639 as unpatentable.