PTAB

IPR2025-00921

Apple Inc v. Apex Beam Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device in UE and Base Station Used for Wireless Communication
  • Brief Description: The ’113 patent discloses methods and devices for wireless communication, specifically addressing a procedure for a User Equipment (UE) to recover from a beam failure by sending two separate beam recovery requests over two different channels to a base station.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Liu in view of Jover.

  • Prior Art Relied Upon: Liu (Application # 2018/0367374) and Jover (Application # 2015/0141026).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Liu, which was not considered during prosecution, discloses nearly all limitations of the challenged claims. Liu teaches a method for beam failure recovery where a UE transmits multiple beam failure recovery requests (BFRRs) to a base station. Specifically, Petitioner asserted Liu discloses sending a first BFRR (the claimed "first radio signal") on a first channel (e.g., PUCCH) and a second BFRR (the "second radio signal") on a second channel (e.g., PRACH). Liu further discloses monitoring for a BFRR response (the "third radio signal") within a "first time window." Petitioner contended that Liu’s figures and description explicitly teach the complex temporal relationships between the signals and monitoring windows recited in the claims, including the "second time window" and "third time window" having overlapped time domain resources—the very limitations added during prosecution to overcome prior art rejections.

    The only element Petitioner argued Liu does not explicitly disclose is triggering the BFRR transmissions based on a measurement value exceeding a specific threshold. To supply this limitation, Petitioner relied on Jover. Jover teaches detecting a communication impairment (analogous to Liu's beam failure) by comparing a measured value, such as the bit-error rate (BER), against a predetermined threshold (e.g., BER increases beyond 1%). Petitioner argued that combining Jover’s threshold-based trigger with Liu’s beam recovery framework renders the claims obvious. The arguments for independent claims 6, 11, and 16 (directed to a base station and UE device) follow the same logic, asserting that Liu's disclosure of the system's components and operations inherently teaches the corresponding device claims.

    • Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would combine Jover’s teachings with Liu’s method to improve the accuracy and reliability of beam failure determination. Since Liu already teaches triggering BFRRs upon "detection of a beam failure," a POSITA would have looked to known techniques, like those in Jover, to implement a precise, quantitative trigger. Jover provides a specific and well-understood method for determining communication failure, making it an obvious and logical implementation detail to add to Liu’s more general system.

    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in combining the references. Both Liu and Jover operate in the same technical field of wireless communications and address the common problem of detecting and recovering from link failures between a UE and a base station. Implementing Jover's well-known thresholding technique (e.g., monitoring BER) into Liu's system would have been straightforward and would have yielded the predictable result of a more robust and reliable beam failure detection mechanism.

4. Key Claim Construction Positions

  • Petitioner argued that several key claim terms, particularly "first time window," "second time window," "third time window," and "triggering the transmission," do not require construction beyond their plain and ordinary meaning.
  • Petitioner contended that the Patent Owner's previously proposed constructions in related proceedings are improper. Specifically, Petitioner argued that the Patent Owner’s proposals attempt to narrow the claims by improperly importing limitations from the specification, such as changing the act of "monitoring" for a signal to the more restrictive act of "receiving" a signal, which would alter the scope of the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of the ’113 patent as unpatentable.