PTAB

IPR2025-01026

Geotab Inc v. Fractus SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Antennas, Wireless Devices, and Methods of Manufacturing Antennas
  • Brief Description: The ’677 patent relates to antennas for multifunction wireless devices. The invention purports to provide design parameters, termed “complexity factors” (F21 and F32), that characterize the three-dimensional shape of an antenna to optimize its efficiency and performance across multiple frequency bands.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dou and Ciais-Quadband - Claims 1-9 are obvious over Dou in view of Ciais-Quadband.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773) and Ciais-Quadband (an April 2004 IEEE article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dou taught a wireless handheld device with an internal diversity antenna architecture, including a ground plane and locations for first and second antennas, but explicitly stated that "any type of suitable internal antenna" could be used. Ciais-Quadband disclosed a miniature, internal, quad-band Planar Inverted-F Antenna (PIFA) designed for mobile handsets. Petitioner asserted that implementing Dou’s device using the Ciais-Quadband antenna for the first and second antennas met all limitations of claims 1-9. Specifically, Petitioner provided detailed calculations to show that the Ciais-Quadband antenna’s contour satisfied the claimed “complexity factor” limitations of claim 1, with a calculated F21 of 1.31 (claimed: ≥1.20) and F32 of 1.57 (claimed: <1.75).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references because Dou expressly left the choice of a specific "suitable" antenna to the designer, and Ciais-Quadband’s antenna was designed for the very mobile applications described in Dou. The combination represented a predictable use of prior art elements according to their established functions.
    • Expectation of Success: A POSA would have a reasonable expectation of success because Ciais-Quadband’s antenna was designed for internal use in mobile phones, was a type of PIFA antenna contemplated by Dou, and its placement was consistent with Dou’s teachings.

Ground 2: Obviousness over Dou, Ciais-Quadband, and Nakano - Claims 1-20 are obvious over Dou in view of Ciais-Quadband and Nakano.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773), Ciais-Quadband (an April 2004 IEEE article), and Nakano (an August 2005 IEEE article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 by adding Nakano, which disclosed a dual-frequency (2.45 GHz and 5.2 GHz) WLAN antenna for use inside mobile handsets. Petitioner argued that a POSA would implement Dou's device using Ciais-Quadband for two primary antennas and Nakano as a third antenna to provide expanded WLAN capability. This combination allegedly met all limitations of claims 1-20. The addition of Nakano’s dual-band antenna satisfied limitations in claims 10-20 requiring a third antenna providing wireless connectivity in at least two frequency bands. Petitioner also provided calculations showing the Nakano antenna contour met the required complexity factors (F21=1.49, F32=1.46).
    • Motivation to Combine: A POSA would add Nakano’s antenna to the Dou/Ciais-Quadband device to meet the increasing market demand for expanded wireless communications, specifically by adding 5.2 GHz WLAN capability (IEEE 802.11a) in addition to the 2.4 GHz band.
    • Expectation of Success: Success was expected because combining multiple antennas in a single device was conventional, and Nakano’s antenna was designed for internal use in mobile handsets like those described by Dou.

Ground 3: Anticipation/Obviousness over Baliarda-543 - Claims 1-5 and 12-20 are anticipated by and/or obvious over Baliarda-543.

  • Prior Art Relied Upon: Baliarda-543 (Application # 2008/0018543).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that claims 1-5 and 12-20 were not entitled to priority before April 7, 2014. This was because the original 2006 priority application lacked written description support for the full scope of a "4G communication standard," as this term is construed to include LTE, which was not defined until years after the priority filing. This priority date shift rendered Baliarda-543—a published version of a parent application in the ’677 patent’s family—as prior art under 35 U.S.C. §102(a)(1). Because Baliarda-543 shared a materially identical specification with the ’677 patent, it disclosed all elements of these claims, thereby anticipating them or, at minimum, rendering them obvious.
    • Key Aspects: This ground’s success hinges on invalidating the ’677 patent’s claim to its 2006 priority date for claims reciting a "4G communication standard."

4. Key Claim Construction Positions

  • “complexity factor,” “F21,” “F32”: Petitioner asserted these terms have no ordinary meaning and are defined by the patent’s specification as the numerical result of a specific mathematical calculation. The calculation involves overlaying three specifically formulated grids (G1, G2, G3) on an “antenna contour” and counting the cells that intersect the contour. This construction is central to all obviousness arguments.
  • “4G communication standard”: Petitioner argued that, based on the Patent Owner’s own litigation positions, this term should be construed to be met by standards such as LTE and WiFi. This construction is critical for both the obviousness analysis in Grounds 1 and 2 and the priority date challenge in Ground 3.
  • “perimeter”: Petitioner argued the Board should adopt the construction from related litigation: “boundary of an object,” excluding any notion of following the shape of the radiating element and extending it as necessary to complete the boundary.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that there is no basis for discretionary denial. It cited the Director’s March 26, 2025 Memorandum concerning Interim Processes for PTAB Workload Management and stated its intent to respond to any discretionary denial arguments from the Patent Owner in subsequent briefing as allowed under the new process.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’677 patent as unpatentable.