PTAB

IPR2025-00928

Geotab Inc v. Fractus SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-band Antennas for Mobile Devices
  • Brief Description: The ’365 patent describes physically compact, multi-band monopole antennas for mobile communication devices like cellular phones. The invention focuses on achieving miniaturization by shaping antenna arms into complex, space-filling geometries, which are characterized in the claims as being a "grid-dimension curve."

3. Grounds for Unpatentability

Ground 1: Obviousness over Tran and Teng - Claims 1-42 and 44-45 are obvious over Tran in view of Teng.

  • Prior Art Relied Upon: Tran (Patent 6,184,833) and Teng (a 2002 article in Microwave and Optical Technology Letters).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tran disclosed the basic framework of a mobile communication device, including a housing, a printed circuit board (PCB) with a ground plane, and communication circuitry. Tran taught the use of internal, multi-band antennas to make devices smaller and more robust. Petitioner contended that Teng disclosed the key inventive concept: a compact, low-profile, multi-band antenna for mobile phones. Teng’s antenna consisted of multiple radiating arms (“branch strips”) connected to a common conductor, folded into a compact, rectangular-box-like structure. Critically, Petitioner asserted that the meandering, space-filling shape of Teng’s radiating arms met the limitations of a “grid-dimension curve” as recited in the challenged claims, providing detailed calculations to support a grid dimension greater than one. Petitioner mapped Teng’s multiple branches to the claimed first and second radiating arms connected to a common conductor.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Tran and Teng for several reasons. First, a POSA would replace Tran's larger internal antenna with Teng's smaller, more compact antenna to further Tran's stated goal of miniaturization and improved aesthetics. Second, Teng explicitly taught that its antenna was designed for use in "multi-band mobile phones," directly inviting its integration into a device like Tran's. Third, the combination would yield the predictable result of a mobile phone with expanded frequency band capabilities (e.g., adding GSM and DCS bands from Teng to the PCS band in Tran), increasing the device's utility across different geographic regions (e.g., North America and Europe).
    • Expectation of Success: A POSA would have had a reasonable expectation of success in combining these elements. The integration involved applying known techniques to combine a mobile phone chassis (Tran) with an antenna designed for that exact application (Teng). Both references taught mounting the antenna on a PCB substrate within the device housing, making the combination straightforward.

4. Key Claim Construction Positions

  • Petitioner argued that the term “grid-dimension curve” is central to all challenged claims and dedicated significant analysis to its construction.
  • Patent Owner's Proposed Construction: In related litigation, Patent Owner construed "grid-dimension curve" as: "[1] A curve which is not self-similar, [2] which possesses a geometry having a grid dimension that is greater than one (1), and, [3] if the curve has any periodicity, the period is defined by a non-periodic curve that includes at least ten connected segments..."
  • Petitioner's Position: Petitioner contended the Patent Owner’s construction was flawed, particularly the "ten connected segments" requirement. However, Petitioner argued that even under this incorrect construction, the meandering antenna shape in Teng satisfied all requirements. Petitioner proposed its own construction based on the ’365 patent's specification, defining the term as "a curve geometry having a grid dimension that is greater than one," where the grid dimension is calculated using a specific six-step method and formula disclosed in the patent. Petitioner provided detailed calculations showing that portions of Teng's antenna meet this construction with a grid dimension of 2.0.

5. Arguments Regarding Discretionary Denial

  • Petitioner stipulated that if an inter partes review (IPR) is instituted, it will not pursue in the parallel Texas litigation any invalidity ground raised or that reasonably could have been raised in the IPR. This stipulation under Sotera Wireless, Inc. v. Masimo Corp. weighs against a discretionary denial under the Fintiv factors.
  • Petitioner also noted its reliance on the Director’s March 26, 2025 Memorandum concerning interim processes for PTAB workload management and reserved its right to fully brief the issue of discretionary denial should the Patent Owner raise it.

6. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-42 and 44-45 of the ’365 patent as unpatentable.