PTAB

IPR2025-00929

Geotab Inc v. Fractus SA

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Portable Device with Multiple Antennas
  • Brief Description: The ’458 patent discloses a wireless portable device, such as a cellphone or laptop, comprising a ground plane and two antennas. A first antenna is configured for mobile communication services (e.g., cellular), while a second antenna is configured for wireless connectivity (e.g., WLAN, Bluetooth). The patent purports to achieve good isolation by optimizing the placement of these antennas relative to the ground plane.

3. Grounds for Unpatentability

Ground 1A: Claims 1-9 and 12-13 are obvious over Wong in view of Lee

  • Prior Art Relied Upon: Wong (a 2005 journal article, "Isolation between GSM/DCS and WLAN Antennas in a PDA Phone"), and Lee (a 2004 journal article, "Quad-Band Internal Monopole Mobile-Phone Antenna").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wong disclosed a personal digital assistant (PDA) phone with all the core elements of claim 1: a ground plane, a first dual-band (GSM/DCS) cellular antenna, and a second WLAN antenna. Wong studied how to optimize antenna isolation by varying the WLAN antenna's position. However, Wong’s cellular antenna only covered European frequency bands. Lee disclosed a quad-band cellular antenna designed for a mobile phone that operated on four major frequency bands, covering both European and North American standards (AMPS/GSM850, GSM900, DCS1800, and PCS1900). The proposed combination substituted Lee’s superior quad-band antenna for Wong’s dual-band antenna in Wong's device.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Wong and Lee to create a PDA phone with broader cellular compatibility. It was known that different regions used different cellular frequencies, making a multi-band device desirable for international use. A POSA would have seen Lee’s quad-band antenna as a natural and predictable upgrade to Wong’s dual-band antenna to achieve operability in both North America and Europe. The references were highly compatible, as Lee's antenna was designed for a ground plane of the exact same dimensions as Wong's.
    • Expectation of Success: A POSA would have had a high expectation of success. Both antennas were designed for internal use in handheld devices, and Lee’s antenna was shown to work effectively with a ground plane identical to Wong’s. The combination involved substituting a known type of component (a cellular antenna) with an improved version for its intended purpose, yielding the predictable result of expanded frequency coverage.

Ground 2: Claims 1-10 and 12-13 are obvious over Gaucher

  • Prior Art Relied Upon: Gaucher (Application # 2006/0082503).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Gaucher, including its incorporated reference Gaucher848, disclosed a laptop computer with all the elements of the challenged claims. Gaucher taught a portable device with a metal support frame for the display that functioned as a ground plane. It explicitly taught mounting a first multiband WWAN (cellular) antenna and a second multib-band WLAN antenna to this frame. Gaucher’s WWAN antenna was described as a quad-band antenna covering the four most popular cellular bands, meeting the "at least three frequency bands" limitation of claim 1. Its WLAN antenna was a tri-band antenna operating in standard WLAN frequencies (e.g., 2.4 GHz and 5 GHz bands).
    • Motivation to Combine: The motivation was inherent in Gaucher itself, which identified the problem of laptops needing both WLAN and WWAN connectivity for users "on the road and away from the hot spot locations." Gaucher expressly taught combining these antenna technologies in a single laptop to increase mobility and user connectivity.
    • Expectation of Success: Success was predictable, as Gaucher described a complete, integrated system and explained its benefits. Further, commercial products with both WLAN and WWAN capabilities, like the Dialogue Flybook, were already on the market before the patent's priority date, confirming the feasibility and known advantages of such a combination.

Ground 3: Claims 14-18 are obvious over Zhao

  • Prior Art Relied Upon: Zhao (Application # 2009/0002248).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zhao disclosed a mobile handset with a PCB ground plane, a first dual-band PIFA GSM antenna (first antenna), and a second quarter-wavelength slot UWB antenna (second antenna). This met the core limitations of independent claim 14, which required at least two cellular frequency bands and at least one different wireless connectivity band. Zhao’s GSM antenna operated at 0.9 GHz and 1.8 GHz, and its UWB antenna operated from 3.1 GHz to 4.9 GHz. Zhao taught placing the antennas at opposite corners of the PCB to maximize separation and improve isolation, directly teaching the antenna placement limitations of claims 14 and 15.
    • Motivation to Combine: The motivation was contained entirely within Zhao, which described integrating these specific antennas onto a single PCB for a mobile handset to provide both cellular and UWB functionality. Zhao’s entire purpose was to describe this integrated design.
    • Expectation of Success: A POSA would expect success because Zhao provided a detailed design, including specific antenna types and placements on a conventional mobile handset PCB, and analyzed its performance characteristics.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be unwarranted. They cited the Director’s March 26, 2025 Memorandum concerning Interim Processes for PTAB Workload Management, stating that under these new processes, the determination of discretionary denial would occur in separate briefing after the filing date is accorded. Petitioner also stipulated that if the IPR is instituted, it would not pursue any ground in co-pending litigation that was raised or reasonably could have been raised in the petition.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 and 12-19 of the ’458 patent as unpatentable.