PTAB

IPR2025-00935

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 in Basic Service Set Overlapping with Another Basic Service Set
  • Brief Description: The ’163 patent describes a wireless communication terminal that classifies received data frames as either Intra-Basic Service Set (BSS) or Inter-BSS based on a BSS color identifier. The terminal is configured to not use the BSS color for operations when it receives signaling information indicating that such operations are disallowed.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Lee - Claims 1, 7, 9, and 15 are obvious over Lee.

  • Prior Art Relied Upon: Lee (Application # 2017/0223731).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee disclosed a wireless station (STA) performing a Clear Channel Assessment (CCA) operation, which is a spatial reuse operation. The STA in Lee adjusted its CCA level based on a "coloring bit" (the claimed BSS color) in a received frame (PPDU) to determine if the frame was from its own BSS. Crucially, Lee also taught a "coloring disable bit" in the PPDU, which served as signaling information. When this disable bit was present, the STA would not perform the CCA level change, irrespective of the coloring bit's value. Petitioner contended this directly maps to the claim limitations of receiving signaling information and, in response, not using the BSS color for an operation.
    • Key Aspects: This ground asserted that Lee alone taught the core inventive concept of disabling a BSS color-based operation via explicit signaling.

Ground 1B: Obviousness over Lee and Stacey - Claims 2-3, 6, 10-11, and 14 are obvious over Lee in view of Stacey.

  • Prior Art Relied Upon: Lee (Application # 2017/0223731) and Stacey (Proposed TGax Draft Specification, IEEE 802.11-16/0024r1 (Mar. 2, 2016)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee supplied the primary teaching of disabling a BSS color-based operation via a "coloring disable bit." Stacey was introduced to teach the specific operational details found in the dependent claims. Stacey disclosed a system with two distinct Network Allocation Vectors (NAVs)—an Intra-BSS NAV and a regular (Basic) NAV—set using BSS color. It also taught using a TXOP Duration field and a MAC frame duration field to set these NAVs, as claimed. Furthermore, Stacey taught entering a power-saving "doze state" until the end of a received Intra-BSS PPDU, mapping to the power-save limitations.
    • Motivation to Combine: A POSITA would combine Lee's disable functionality with Stacey's BSS color-based operations to create a more robust system. Since both references address the developing IEEE 802.11ax standard, a POSITA would have been motivated to incorporate a known disabling mechanism (from Lee) into a system with standard BSS color-based features (from Stacey) to handle scenarios like BSS color collisions where such operations should be suspended.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination involved applying a known technique (Lee's disable bit) to a known system (Stacey's BSS color-based operations) to achieve the predictable result of selectively disabling those operations.

Ground 2A: Obviousness over Choudhury - Claims 1, 7, 8, 9, 15, and 16 are obvious over Choudhury.

  • Prior Art Relied Upon: Choudhury (European Pat. App. Pub. No. 2930997).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Choudhury, like Lee, taught the core concept of the independent claims. Choudhury described a wireless networking station using a "COLOR field" (BSS color) for channel access determinations. It explicitly taught that a reserved value of '0000' in the COLOR field served as signaling information to indicate high interference. Upon receiving this value, other stations were "required to defer channel access," which is equivalent to not performing a BSS color-based spatial reuse operation. This mapped directly to the limitations of claim 1. Petitioner further argued that Choudhury's disclosure that the '0000' value signifies this state rendered claims 8 and 16, which require a predetermined value of 0, obvious.
    • Key Aspects: This ground provided an alternative primary reference that allegedly disclosed all limitations of the independent claims and certain dependent claims without needing a combination.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Lee in view of Zhou (for BSS color collision detection), Lee in view of Choudhury (for using a predetermined value of 0), Choudhury in view of Stacey (similar to Lee/Stacey combination), and Choudhury in view of Zhou.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. The petition noted the existence of co-pending district court litigation and a Fintiv stipulation. Petitioner stated its intent to use the bifurcated briefing process outlined in the March 26, 2025, Stewart Memorandum to rebut any discretionary denial arguments raised by the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of the ’163 patent as unpatentable under 35 U.S.C. §103.