Apple Inc v. Apex Beam Technologies LLC

1. Case Identification

• Case #: IPR2025-00909
• Patent #: 10,986,695
• Filed: April 25, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Alireza Babaei
• Challenged Claims: 1-20

2. Patent Overview

• Title: Uplink Cancellation Indication Signaling
• Brief Description: The ’695 patent discloses methods for enhancing uplink cancellation indication technologies in wireless communication systems, particularly when a serving cell is configured with both a normal uplink (NUL) carrier and a supplementary uplink (SUL) carrier.

3. Grounds for Unpatentability

Ground 1A: Claims 1-20 are obvious over Ying in view of Yang.

• Prior Art Relied Upon: Ying (Patent 11,930,485) and Yang (Application # 2020/0359447A1).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Ying taught a method for a wireless device to receive uplink pre-emption (cancellation) configuration parameters, including a radio network temporary identifier (RNTI) and a positionInDCI parameter indicating a starting bit position for the cancellation indication within the Downlink Control Information (DCI) payload. However, Ying primarily focused on a single carrier type. Yang allegedly supplied the missing element by teaching the use of a single DCI to convey cancellation indications for both NUL and SUL carriers by configuring separate blocks within the DCI for each carrier type. The combination allegedly rendered it obvious to apply Ying's specific parameterization (positionInDCI) to define starting positions for both the NUL and SUL cancellation indications within a single DCI, as taught by Yang.
  • Motivation to Combine: A POSITA would combine Ying and Yang to improve communication efficiency in networks using both NUL and SUL carriers. Using a single, compact DCI to coordinate both carriers, as suggested by the combination, would reduce signaling overhead and simplify the decoding process at the wireless device. These were known objectives in the field for improving communication capacity and speed.
  • Expectation of Success: Petitioner asserted a high expectation of success because both references addressed the same technical problem of uplink cancellation in modern wireless networks. The combination represented a predictable application of Ying’s parameterization method to Yang’s dual-carrier framework, yielding no unexpected results.

Ground 1B: Claims 1-20 are obvious over Ying.

• Prior Art Relied Upon: Ying (Patent 11,930,485).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground argued that Ying alone rendered the claims obvious. Petitioner contended that Ying expressly disclosed User Equipment (UE) configured with both NUL and SUL capabilities, citing listings within Ying that include a "UL/SUL indicator." Based on this disclosure, a POSITA would have found it obvious to apply Ying’s disclosed cancellation signaling method—including the positionInDCI parameter—to manage cancellations for both NUL and SUL carriers without needing to consult Yang. The argument was that Ying contained all the necessary components, and it would have been an obvious design choice to create a second starting position parameter for the SUL carrier, mirroring the disclosed parameter for the NUL carrier.
  • Motivation to Combine: The motivation was to apply the teachings of Ying comprehensively to a system that Ying itself contemplated (a UE with both NUL and SUL carriers). The goal was to achieve the same benefits of improved communication capacity and efficiency that Ying described, but across both available uplink carrier types.
  • Expectation of Success: Success would be expected as this approach involved integrating complementary teachings from within a single reference, all related to the same technology. It was presented as a simple design choice rather than an inventive step.

Ground 2: Claims 1-20 are obvious over Kim in view of Boroujeni.

• Prior Art Relied Upon: Kim (WO 2019/194589A1) and Boroujeni (Application # 2022/0217736A1).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner alleged Kim taught using a single DCI to convey uplink cancellation indications for both conventional (NUL) and SUL carriers by including two separate bitmaps: bitmap #1 for the NUL carrier and bitmap #2 for the SUL carrier. Boroujeni was argued to supply the specific parameterization for implementing Kim’s system, teaching the use of parameters like servingCellId and positionInDCI to configure the location of fields within a DCI format. The combination of Kim and Boroujeni allegedly made it obvious to use Boroujeni’s positionInDCI parameter to define the respective starting positions for Kim’s NUL and SUL bitmaps within a single, efficient DCI.
  • Motivation to Combine: A POSITA would combine the references to parameterize the information taught by Kim using the specific configuration method taught by Boroujeni. This would improve communication efficiency by creating a compact DCI structure where the locations of the NUL and SUL bitmaps were consistently indexed. This approach would reduce overhead and simplify decoding for terminals, especially those served by multiple cells, by explicitly identifying the serving cell and the location of cancellation data within the control message.
  • Expectation of Success: The combination was presented as nothing more than integrating complementary teachings from analogous art to achieve a predictable, more efficient result. Both references related to coordinating cancellation indications, and applying Boroujeni’s known parameterization technique to Kim’s bitmap structure was a straightforward implementation choice.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’695 patent as unpatentable.