Apple Inc v. Apex Beam Technologies LLC

1. Case Identification

• Case #: IPR2025-00911
• Patent #: 11,637,615
• Filed: April 25, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Alireza Babaei
• Challenged Claims: 1-16

2. Patent Overview

• Title: Random Access and Consistent LBT Failure Recovery
• Brief Description: The ’615 patent describes techniques for managing conflicts between beam failure recovery and consistent listen-before-talk (LBT) failure recovery processes in wireless communication systems, such as 5G New Radio (NR). The claimed method involves stopping a first random access process for beam failure recovery upon detecting a consistent LBT failure, switching to a new bandwidth part (BWP), initiating a second random access process for LBT failure recovery, and then initiating a third random access process to resume beam failure recovery.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cirik - Claims 1-16 are obvious over Cirik.

• Prior Art Relied Upon: Cirik (Application # 2021/0100031).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Cirik, which addresses both beam failure and LBT failure recovery, discloses all elements of the challenged claims. Cirik taught initiating a beam failure recovery procedure (a first random access process) upon detecting beam failure. It further taught that upon detecting an LBT failure during this process, the device may "stop" or "suspend" the beam failure recovery procedure and initiate an LBT failure recovery procedure (a second random access process). Cirik also disclosed switching BWPs when a random access procedure is initiated. Finally, Petitioner asserted Cirik taught resuming the suspended beam failure recovery procedure (a third random access process) after the LBT recovery is completed.
  • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner argued that all claimed features were present in Cirik, making the claims obvious under 35 U.S.C. §103. Any minor differences would have been obvious modifications to a person of ordinary skill in the art (POSITA).
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in implementing the claimed method, as Cirik explicitly described the sequence of detecting failures, suspending one recovery process, initiating another, and later resuming the first.

Ground 2: Obviousness over Cirik in view of Wu and/or InterDigital - Claims 1-16 are obvious over Cirik in view of Wu and/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 expressly disclose certain features, such as switching BWPs specifically to initiate the second random access process for LBT failure recovery, Wu and InterDigital provided these teachings. Wu taught switching to a second BWP in response to continuous LBT failures. InterDigital, a 3GPP standards proposal, explicitly taught that upon BWP switching caused by consistent LBT failure, the device "shall stop any ongoing RA procedure and initiate a new RA procedure."
  • Motivation to Combine (for §103 grounds): A POSITA would combine these references as they all address the same technical problem of failure recovery in 5G NR systems. A POSITA would look to references like Wu and InterDigital to implement the general framework of Cirik, seeking known techniques for BWP switching during failure recovery. InterDigital's teaching to reset preamble and power ramping counters provided a specific technical reason to initiate a new random access procedure on a new BWP, a benefit that would motivate its combination with Cirik.
  • Expectation of Success (for §103 grounds): Success was expected because the combination involved applying a known technique (BWP switching for LBT recovery from Wu/InterDigital) to a known system (Cirik's failure recovery framework) to achieve predictable results, such as improved recovery efficiency.

Ground 3: Obviousness over Wu in view of InterDigital - Claims 1-2, 4-7, 9-10, 12-14, and 16 are obvious over Wu and 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 described the core scenario of the ’615 patent, where a consistent LBT failure is detected during an ongoing random access process for beam failure recovery (BFR). Wu taught switching to a second BWP to handle the LBT failure but left implementation details to a POSITA. InterDigital provided the missing detail, explicitly teaching that the preferred option is to "stop the ongoing RA procedure and immediately initiate a new RA procedure for consistent/continuous LBT failure recovery." The combination of Wu's scenario and InterDigital's explicit instruction rendered the claimed sequence of stopping the first process and starting the second obvious.
  • Motivation to Combine (for §103 grounds): A POSITA implementing Wu's system would face a choice: wait for the BFR process to finish or preempt it. The POSITA would consult analogous art like InterDigital, which directly addressed this choice and recommended stopping the ongoing process to ensure preamble and power counters are reset and to handle the more immediate LBT failure. This provided a clear motivation to combine the teachings.
  • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success, as the combination represented a straightforward application of a technique from a standards proposal (InterDigital) to a known system (Wu) to solve a known problem with predictable results.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-16 based on the combination of Wu, InterDigital, and Cirik, arguing that a POSITA would integrate Cirik's teachings on specific recovery protocols and parameter configurations into the Wu/InterDigital framework to create a complete, operable system.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial is unwarranted. It noted its intent to use the bifurcated briefing process contemplated in the March 26, 2025 Stewart Memorandum to rebut any contentions for discretionary denial raised by the Patent Owner.

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-16 of the ’615 patent as unpatentable.