PTAB

IPR2025-00933

Samsung Electronics Co Ltd v. Wilus Institute Of Standards Technology Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: WIRELESS COMMUNICATION METHOD AND WIRELESS COMMUNICATION TERMINAL, WHICH USE DISCONTINUOUS CHANNEL
  • Brief Description: The ’595 patent describes methods and terminals for wireless communication, specifically for signaling resource unit (RU) allocation information in High Efficiency (HE) wireless packets. The invention focuses on indicating the allocation status of a center 26-tone RU when a packet is transmitted in a bandwidth of 80MHz or more.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Josiam - Claims 1-12

  • Prior Art Relied Upon: Josiam (Application # US2016/0330300A1)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Josiam, which relates to signaling and addressing in WLAN systems, teaches every limitation of the challenged claims. Josiam allegedly disclosed receiving a wireless packet (an HE PPDU) with HE-SIG-A and HE-SIG-B fields. It described signaling bandwidth information in the HE-SIG-A field, which determines the structure of the HE-SIG-B field. Josiam further taught obtaining information about unassigned RUs from a "common field" subfield within HE-SIG-B, using either an RU allocation index or a specific indication bit for a center 26-tone RU ("C26 resource unit"). Petitioner contended that Josiam explicitly taught using a 1-bit indicator (the "C26 field") to signal whether the center 26-tone RU is allocated in 80MHz or greater PPDUs, but not in 20MHz or 40MHz PPDUs, thereby meeting the key limitations of independent claims 1 and 7.
    • Motivation to Combine (for §103 grounds): This ground was asserted against a single reference.
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Ground 1B: Obviousness over Josiam in view of Seok - Claims 1-6

  • Prior Art Relied Upon: Josiam (Application # US2016/0330300A1) and Seok (Application # US2016/0174200A1)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on the teachings of Josiam as detailed in Ground 1A for the method steps. Seok was added to explicitly teach the apparatus limitations of claims 1-6, specifically the "processor" configured to perform the claimed methods. Seok described a WLAN device including a "baseband processor" capable of performing baseband signal processing, including receiving and decoding HE MU PPDUs.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Josiam’s signaling methods with Seok’s hardware implementation to create an operational device. Seok provided known hardware (a processor) and software elements expressly designed for the HE-WLAN environment in which Josiam’s methods operate, making the combination a predictable integration of known techniques.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in combining the references because it involved using a standard processor architecture (from Seok) to execute the specific signaling and decoding logic (from Josiam).

Ground 2: Obviousness over Chen in view of Wu - Claims 1-12

  • Prior Art Relied Upon: Chen (Application # US2016/0330058A1) and Wu (Application # US2017/0070998A1)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen taught a method for explicitly indicating a non-allocated RU using a bitmap in the common part of the HE-SIG-B field. Wu taught a practical structure for HE-SIG-B in wider bandwidths, splitting the signaling information between two separate content channels that correspond to alternating 20MHz segments of the total bandwidth. The combination allegedly met the claim limitations by using Chen's non-allocation bitmap within Wu's two-channel HE-SIG-B structure. Specifically, for the center 26-tone RU in an 80MHz transmission, Wu taught a separate one-bit indicator to signal its use, as it falls between the two primary content channels. This one-bit indicator from Wu corresponded to the claimed "C26 field," and its use was limited to 80MHz or greater bandwidths, as smaller bandwidths do not have a center RU.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references to solve a known problem: efficiently signaling RU allocation across a wide bandwidth while also handling the special case of the center 26-tone RU. Wu's two-channel approach was a known, efficient structure for reducing overhead, and it was adopted into the draft 802.11ax standard. A POSITA would have been motivated to apply Chen's method for indicating non-allocated RUs within Wu's standardized channel structure and supplement it with Wu's specific solution for the problematic center 26-tone RU.
    • Expectation of Success (for §103 grounds): The combination involved applying a known signaling method (Chen) to a known channel structure (Wu) to achieve predictable results. Given that the standards body had already adopted Wu's channel approach and was still determining how to signal non-allocation, combining these teachings represented a natural and foreseeable design choice.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be unwarranted. It stated its intent to utilize the bifurcated briefing process outlined in the March 26, 2025 Stewart Memorandum to rebut any contentions to the contrary if offered by the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’595 patent as unpatentable.