PTAB

IPR2025-00910

Apple Inc v. Apex Beam Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Beam Failure and Consistent Listen Before Talk Failure Recovery
  • Brief Description: The ’128 patent describes methods for a wireless device to manage and recover from concurrent communication failures. The invention purports to resolve conflicts between a beam failure recovery (BFR) process and a consistent listen-before-talk (LBT) failure recovery process by stopping the first random access process for BFR, switching bandwidth parts (BWPs), and initiating a second random access process for LBT failure recovery.

3. Grounds for Unpatentability

Ground 1: Claims 1-19 are obvious over Cirik.

  • Prior Art Relied Upon: Cirik (Application # 2021/0100031).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cirik discloses all limitations of the challenged claims. Cirik teaches a method for handling conflicts between BFR and LBT failure recovery procedures. Specifically, Cirik describes initiating a first random access (RA) process for BFR and, upon detecting a consistent LBT failure, stopping or suspending the ongoing BFR procedure to initiate a new RA process for LBT failure recovery. Petitioner asserted that Cirik also discloses switching between BWPs for various reasons, including initiating an RA process, and teaches that the LBT recovery can involve a two-step or four-step RA process, as required by dependent claims.
    • Motivation to Combine: This ground is based on a single reference.
    • Expectation of Success: This ground is based on a single reference.

Ground 2: Claims 1-19 are obvious over Cirik in view of Wu or InterDigital.

  • Prior Art Relied Upon: Cirik (Application # 2021/0100031), Wu (Application # 2022/0110153), and InterDigital (a 3GPP standards proposal, R2-1914882).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that to the extent Cirik does not explicitly teach switching from a first BWP to a second BWP to initiate the LBT failure recovery process, this step was well-known in the art, as shown by Wu and InterDigital. Wu taught switching to a different BWP in response to continuous LBT failures to perform a new RA procedure. InterDigital proposed that upon BWP switching caused by consistent LBT failure, the device must stop any ongoing RA procedure and initiate a new one. The combination of Cirik with either Wu or InterDigital renders the claimed BWP switching step obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Cirik with Wu or InterDigital to implement an efficient and standardized method for failure recovery. Wu was motivated by the efficiency of BWP switching over a full connection re-establishment. InterDigital was motivated by the need to reset preamble and power ramping counters, which was a known best practice agreed upon by the relevant 3GPP standards working group before the patent’s critical date.
    • Expectation of Success: A POSITA would have a high expectation of success, as this combination involved applying a known, predictable technique (BWP switching for LBT recovery) to a known system (Cirik's failure recovery framework) to achieve predictable benefits.

Ground 3: Claims 1, 10, and 16-19 are obvious over Wu in view of InterDigital.

  • Prior Art Relied Upon: Wu (Application # 2022/0110153) and InterDigital (a 3GPP standards proposal, R2-1914882).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Wu discloses the same scenario as the ’128 patent, where a continuous LBT failure is detected on a first BWP during an ongoing BFR procedure. Wu teaches switching to a second BWP to initiate a new RA procedure for the LBT failure. However, Wu does not explicitly state whether to preempt the ongoing BFR procedure. InterDigital provides this missing detail, teaching that upon BWP switching due to LBT failure, the device "shall stop any ongoing RA procedure" and initiate a new one.
    • Motivation to Combine: A POSITA implementing Wu's system would have been faced with two clear choices: wait for the BFR process to complete or preempt it. InterDigital taught the advantages of preemption—specifically, ensuring the preamble and power ramping counters are reset for the new RA procedure. This provides predictable device behavior and was the standard approach adopted by 3GPP.
    • Expectation of Success: A POSITA would have reasonably expected success in combining these references because it represented a straightforward application of a known technique (InterDigital's preemption logic) to a known problem scenario (Wu's concurrent failure state) to achieve the predictable result of a robust and standardized recovery process.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 2-9 and 11-15 based on the combination of Wu, InterDigital, and Cirik, arguing that Cirik provided further details on RA procedure types and logical channel prioritization to supplement the Wu-InterDigital system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. Petitioner stated its intent to use the bifurcated briefing process outlined in 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 1-19 of the ’128 patent as unpatentable under 35 U.S.C. §103.