PTAB

IPR2025-00934

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

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Communication Method And Wireless Communication Terminal For Signaling Multi-User Packet
  • Brief Description: The ’210 patent discloses methods and terminals for wireless communication within standards like IEEE 802.11ax. The technology centers on signaling in High-Efficiency Multi-User Multiple-Input Multiple-Output (HE MU-MIMO) transmissions, specifically how a terminal identifies the format of a control field (HE-SIG-B) based on the number of users indicated in a preceding control field (HE-SIG-A).

3. Grounds for Unpatentability

Ground 1: Obviousness over 802.11ax_D1.0 and Bharadwaj

  • Ground 1A: Claims 6-9 are obvious over 802.11ax_D1.0

    • Prior Art Relied Upon: IEEE P802.11ax/D1.0 Draft Standard (Nov. 2016) (“802.11ax_D1.0”).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner argued that the 802.11ax_D1.0 draft standard, publicly available before the patent’s critical date, explicitly teaches the method of independent claim 6. It describes a High Efficiency Multi-User Physical Layer Protocol Data Unit (HE MU PPDU) containing both HE-SIG-A and HE-SIG-B fields. 802.11ax_D1.0 allegedly teaches using a “SIGB Compression” field in HE-SIG-A to indicate a full bandwidth MU-MIMO transmission. When this field is set, a separate subfield in HE-SIG-A (“Number of MU-MIMO Users”) indicates the number of participating stations. The value of this subfield determines the format of the user-specific field within HE-SIG-B. Specifically, a different format is used depending on whether a single user (non-MU-MIMO allocation) or two or more users (MU-MIMO allocation) are indicated, thus disclosing the core limitations of claim 6. Dependent claims 7-9 are allegedly obvious as they recite further details of these distinct user field formats (e.g., Spatial Configuration Field (SCF) for MU-MIMO, Number of Space Time Streams (NSTS) for non-MU-MIMO), which are also described in 802.11ax_D1.0.

  • Ground 1B: Claims 1-5 are obvious over 802.11ax_D1.0 in view of Bharadwaj

    • Prior Art Relied Upon: 802.11ax_D1.0 and Bharadwaj (Application # 2017/0181130).
    • Core Argument for this Ground:
      • Prior Art Mapping: This ground targets the apparatus claims 1-5. Petitioner asserted that 802.11ax_D1.0 teaches the signaling method as described in Ground 1A. Bharadwaj, which describes a wireless terminal for an 802.11ax-compliant network, supplies the conventional hardware context. Bharadwaj explicitly discloses a wireless terminal comprising a communication unit (transceiver) and a processor configured to receive and decode HE MU PPDUs, thereby teaching the structural limitations of independent claim 1.
      • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of 802.11ax_D1.0 and Bharadwaj because the former provides the standardized protocol and the latter provides a compatible hardware implementation for that exact protocol. Bharadwaj’s express purpose is to operate in an 802.11ax network, making the combination a straightforward implementation of the standard on a suitable device.
      • Expectation of Success: A POSITA would have a high expectation of success in combining the protocol of 802.11ax_D1.0 with the terminal architecture of Bharadwaj to yield a predictable and operable device.

Ground 2: Claims 1-9 are obvious over Bharadwaj in view of Sun

  • Prior Art Relied Upon: Bharadwaj (Application # 2017/0181130) and Sun (Application # 2016/0204912).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination independently renders all challenged claims obvious. Bharadwaj teaches the fundamental concept of a wireless system that differentiates between single-user (SU) and multi-user (MU) MIMO allocations based on information in the HE-SIG-A field. While Bharadwaj details the user field format for MU-MIMO allocations (using a spatial configuration field), it does not explicitly define the format for SU allocations. Sun, which addresses the same technical problem in 802.11ax systems, remedies this by teaching two distinct HE-SIG-B user block structures: one for MU-MIMO and one for SU (non-MU-MIMO), with the SU format including an NSTS field.
    • Motivation to Combine: A POSITA seeking to build a complete system based on Bharadwaj’s framework would recognize the need for a defined user field format for the SU case. Sun provides a direct, compatible solution for this missing detail within the same field of endeavor (802.11ax preamble design). The combination would merely complete Bharadwaj’s contemplated system with a known format from Sun to support both SU and MU allocations, a predictable design choice.
    • Expectation of Success: Success would be expected because both references describe compatible 802.11ax techniques for downlink MU-MIMO transmissions, and combining them simply involves implementing a known user field format (from Sun) into a system that already anticipates its use (Bharadwaj).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. The petition notes the existence of co-pending district court litigation involving the ’210 patent and references a `Fintiv` stipulation filed concurrently. Petitioner also stated its intent to use the bifurcated briefing process established by the PTAB to rebut any arguments for discretionary denial raised by the Patent Owner.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-9 of the ’210 patent as unpatentable under 35 U.S.C. §103.