PTAB

IPR2025-00908

Apple Inc v. Apex Beam Technologies LLC

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1. Case Identification

  • Case Number: IPR2025-00908
  • Patent #: 11,108,639
  • Filed: May 5, 2025
  • Petitioner(s): Apple Inc.
  • Patent Owner(s): Alireza Babaei
  • Challenged Claims: 1-20

2. Patent Overview

  • Title: Wireless Device Feedback for Semi-Persistent Scheduling Release
  • Brief Description: The ’639 patent relates to wireless device feedback for semi-persistent scheduling (SPS) release in LTE and 5G NR networks. The technology involves a wireless device receiving Radio Resource Control (RRC) messages to establish multiple SPS configurations and then receiving a single Downlink Control Information (DCI) message to trigger the joint deactivation of those configurations, followed by transmitting a single acknowledgment.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Application # 2023/0084754 ("Fakoorian-1") and WIPO PCT App. Pub. No. WO 2021/064961A1 ("Takahashi").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fakoorian-1 discloses the core concept of the ’639 patent: jointly releasing multiple SPS configurations using a single DCI message to reduce network overhead. Fakoorian-1 teaches that a user equipment (UE) receives an RRC message to establish multiple SPS configurations and later receives a single DCI, with a bit sequence in the HARQ process number field, to indicate which set of configurations to jointly release. The UE then transmits an acknowledgment. Petitioner contended that Takahashi supplies the missing details regarding HARQ feedback codebooks. Takahashi describes configuring multiple SPSs and determining the HARQ-ACK codebook size and content based on higher-layer RRC parameters, including using the same codebook for feedback related to multiple SPS configurations.
    • Motivation to Combine: A POSITA would combine Fakoorian-1 and Takahashi to achieve the known benefits articulated in both references. Specifically, a POSITA would implement Fakoorian-1’s efficient joint-release mechanism and integrate Takahashi’s detailed teachings on HARQ codebook management to ensure appropriate and efficient feedback when multiple SPSs are jointly released, thereby decreasing network overhead and improving resource utilization.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references operate in the same field of 3GPP wireless communication, address the same problem of managing multiple SPS configurations, and propose compatible solutions. Combining them involved applying known techniques (Takahashi's HARQ management) to a known system (Fakoorian-1's joint release) to achieve predictable results.

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

  • Prior Art Relied Upon: Patent 11,464,001 ("Fakoorian-2").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fakoorian-2, by itself, renders all challenged claims obvious. Fakoorian-2 describes a system for joint activation and release of multiple SPS configurations for a given bandwidth part (BWP) using a single message. It explicitly teaches configuring SPS resources via RRC signaling and using a single DCI message—which includes an existing field like a HARQ process number—to indicate which SPS configurations are to be jointly released. Fakoorian-2 further discloses that the UE transmits a HARQ-ACK in a codebook to acknowledge the release. Petitioner argued that Fakoorian-2's disclosure of using a CS-RNTI associated with multiple configurations teaches a "state" mapped to multiple configurations, and its teaching that multiple configurations can share parameters implies they can share the same HARQ codebook identifier.

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

  • Prior Art Relied Upon: Patent 11,464,001 ("Fakoorian-2") and WIPO PCT App. Pub. No. WO 2021/064961A1 ("Takahashi").
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative combination, arguing that even if Fakoorian-2 alone does not render every limitation obvious, any gaps are filled by Takahashi. The core argument mirrors Ground 1: Fakoorian-2 provides the foundational system for joint release of multiple SPS configurations via a single DCI. Takahashi supplements this by teaching explicit methods for managing HARQ feedback for multiple SPSs, including using RRC parameters to define a single HARQ-ACK codebook for multiple SPS configurations. For example, Takahashi teaches that parameters of each SPS setting (e.g., periodicity) can be the same and that the UE determines which HARQ-ACK codebook to use based on RRC parameters.
    • Motivation to Combine: The motivation was identical to that in Ground 1. A POSITA implementing the joint-release system of Fakoorian-2 would consult Takahashi to incorporate its efficient and flexible HARQ feedback mechanisms, such as using one codebook for acknowledgements for multiple SPS configurations to reduce overhead and complexity.
    • Expectation of Success: As both references are analogous art addressing the same technical challenges in 3GPP systems, a POSITA would have a reasonable expectation of successfully combining their teachings. The combination was presented as a predictable integration of known technologies to achieve improved performance.

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 March 2025 Stewart Memorandum to rebut any contentions for discretionary denial that the Patent Owner might raise. The petition also lists co-pending district court litigation involving the ’639 patent.

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 under 35 U.S.C. §103.