PTAB

IPR2025-00988

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 ’281 patent relates to a method for wireless communication using a discontinuous (punctured) channel. The invention focuses on signaling non-contiguous channel allocation information using a combination of fields within a received wireless packet, specifically the High-Efficiency Signal A (HE-SIG-A) and High-Efficiency Signal B (HE-SIG-B) fields.

3. Grounds for Unpatentability

Ground 1: Obviousness over Josiam - Claims 1-5, 7-12, and 14 are obvious over Josiam.

  • Prior Art Relied Upon: Josiam (Application # 2017/0006608).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Josiam teaches all limitations of the independent claims, particularly the core concept of splitting the signaling for unused (punctured) channels across both the HE-SIG-A and HE-SIG-B fields. Josiam allegedly discloses that a bandwidth field in HE-SIG-A indicates unused channel segments, while a resource unit (RU) signaling field in HE-SIG-B provides additional signaling about the use or disuse of other channel segments. This was asserted to map directly to the claim limitation requiring the HE-SIG-A field to indicate initial channel puncturing information and the HE-SIG-B field to indicate additional puncturing information.

Ground 2: Obviousness over Bharadwaj in view of Li - Claims 1-3, 7-10, and 14 are obvious over Bharadwaj in view of Li.

  • Prior Art Relied Upon: Bharadwaj (Application # 2017/0181129) and Li (Application # 2017/0041171).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine Li’s method of using a single, indexed bandwidth field in HE-SIG-A to indicate both overall bandwidth and a subset of puncturing configurations with Bharadwaj’s teaching of using a "special or dedicated RU allocation bit sequence" in HE-SIG-B to indicate additional puncturing. Li’s indexed approach for HE-SIG-A was argued to provide the claimed "channel information to be punctured within the bandwidth," while Bharadwaj's special sequence in HE-SIG-B was argued to provide the "additional puncturing information."
    • Motivation to Combine: A POSITA would combine these teachings to create a more efficient and predictable signaling method. Petitioner argued that this combination would save valuable space in the HE-SIG-A field, a known design constraint, while still providing the necessary flexibility to signal various puncturing scenarios as taught by the references.
    • Expectation of Success: Success would be expected because the combination involved using known techniques (Li's indexing, Bharadwaj's special RU sequence) to perform their respective and known functions, leading to a predictable improvement in signaling efficiency.

Ground 3: Obviousness over Bharadwaj-Li in view of Chen - Claims 1-5, 7-12, and 14 are obvious over the combination of Bharadwaj and Li, further in view of Chen.

  • Prior Art Relied Upon: Bharadwaj (Application # 2017/0181129), Li (Application # 2017/0041171), and Chen (Application # 2016/0330058).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built on the Bharadwaj-Li combination by adding Chen's teaching of using a "null station ID" (or a blank/unassigned ID) in a user-specific field of HE-SIG-B to explicitly indicate an unassigned resource unit. This provides a specific mechanism for obtaining "information of an unassigned resource unit" via a subfield of HE-SIG-B, as recited in claims 1, 4, 8, and 11.
    • Motivation to Combine: Petitioner argued a POSITA would incorporate Chen's method into the Bharadwaj-Li framework to gain more flexibility in managing RU allocation. Using a null STA ID is a well-known, predictable solution for indicating unassigned RUs without disrupting the overall preamble structure, which is particularly useful for handling edge RUs adjacent to a punctured channel to ensure compliance with spectral mask requirements.
    • Expectation of Success: A POSITA would have a high expectation of success, as this involved applying a known technique (null ID for unassigned resources) to a known system (the Bharadwaj-Li preamble structure) to solve a known and recurring problem (signaling unassigned edge RUs).

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 1-7 and 13 as obvious over Josiam in view of Kim; claims 6 and 13 as obvious over Bharadwaj-Li in view of Kim; and claims 6 and 13 as obvious over Bharadwaj-Li-Kim in view of Chen. These grounds relied on similar theories of combining known signaling techniques to achieve predictable results.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention was that the challenged claims are not entitled to a priority date earlier than May 14, 2016. Petitioner argued that the patent’s pre-5/14/2016 priority applications fail to disclose the key limitation of using both the HE-SIG-A bandwidth field for initial puncturing information and the HE-SIG-B resource allocation field for additional puncturing information. This position, if accepted, makes references like Josiam and Kim, which have later priority dates, available as prior art against the challenged claims.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It further stated its intent to utilize the bifurcated briefing process contemplated by the PTAB to rebut any discretionary denial contentions offered by the Patent Owner.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 10,687,281 as unpatentable.