PTAB

IPR2025-01027

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 ’200 patent relates to antennas for wireless devices. The invention purports to provide design parameters, termed "complexity factors" (F21 and F32), which characterize the three-dimensional shape of an antenna to optimize its efficiency and performance.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dou and Jing - Claims 1-15, 17, and 19-20 are obvious over Dou in view of Jing.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773) and Jing (a 2005 IEEE conference proceeding).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dou teaches a wireless device with an internal diversity antenna architecture, including first and second antennas, but leaves the specific antenna design to a person of ordinary skill in the art (POSA). Jing discloses a compact, multiband planar monopole antenna designed for internal use in mobile handsets that operates in frequency bands (DCS, PCS, UMTS, WLAN) relevant to Dou’s device. Petitioner contended that Jing's antenna meets all geometric and performance limitations of the challenged claims, including the claimed "complexity factor" values. Through detailed calculations based on the ’200 patent’s own methodology, Petitioner asserted that Jing's antenna contour has a complexity factor F21 of 1.43 (claimed: ≥1.20) and F32 of 1.70 (claimed: ≥1.35).
    • Motivation to Combine: A POSA would combine Dou and Jing because Jing provides a known, suitable internal antenna for the wireless device described in Dou. Jing’s antenna was designed for mobile handsets, operates in relevant communication standards (e.g., UMTS, WiFi) mentioned by Dou, and represents a predictable implementation choice for a POSA seeking to select an antenna for Dou’s system.
    • Expectation of Success: A POSA would have had a reasonable expectation of success in combining the references. Both relate to internal antennas for mobile devices, and implementing Jing’s well-characterized antenna within Dou’s architecture would involve applying known design principles with predictable results.

Ground 2: Anticipation/Obviousness over Baliarda-543 - Claims 1-20 are anticipated by or obvious over Baliarda-543.

  • Prior Art Relied Upon: Baliarda-543 (Application # 2008/0018543).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground hinges on a priority date argument. Petitioner asserted that claims 1-20 are not entitled to the 2006 filing date of their parent application because the parent lacks written description support for the full scope of a "4G communication standard," which Petitioner argued must include LTE to cover the patent owner's litigation positions. At the 2006 filing date, LTE standards and their associated frequency bands (such as LTE Band 12, which was later allocated from spectrum used for television broadcasting) had not yet been defined. Therefore, a POSA in 2006 could not have envisioned or possessed an antenna configured for LTE operation. Petitioner argued the earliest effective filing date is April 7, 2014. This makes Baliarda-543—the 2008 publication of the parent application—prior art under 35 U.S.C. §102. Because the specification of Baliarda-543 is materially identical to that of the ’200 patent, it discloses species within every challenged claim, thereby anticipating or rendering them obvious.

4. Key Claim Construction Positions

  • "complexity factor," "F21," "F32": Petitioner argued these terms have no plain and ordinary meaning and are explicitly defined by the patent specification. The values are the numerical result of a specific mathematical calculation. This calculation involves overlaying a series of three specifically-formulated grids (G1, G2, G3) on an "antenna rectangle," counting the number of grid cells that include a point of the "antenna contour" at different resolutions (N1, N2, N3), and inputting these counts into the claimed formulas.
  • "4G communication standard": Petitioner asserted that because the specification does not use this exact term, its meaning is informed by the patent’s equation of "4G services" with standards like HSDPA, WiFi, and WiMAX, and by the Patent Owner's litigation position that LTE meets the limitation. Petitioner’s arguments proceeded under the Patent Owner’s asserted construction, contending the prior art meets it.
  • "perimeter": Petitioner argued for applying the construction from a prior district court litigation: "boundary of an object," which collaterally estops the Patent Owner from arguing for a different construction.

5. Key Technical Contentions (Beyond Claim Construction)

  • Lack of Written Description for LTE: A central contention for Ground 2 was that the 2006 priority application could not provide written description for an antenna operating with LTE. Petitioner argued that in 2006, the technical specifications, frequency bands, and protocols for LTE were undefined and constituted an "open issue" in the field. Therefore, an inventor could not have possessed the full scope of the claimed invention encompassing future LTE technology, invalidating the priority claim and making the parent publication available as prior art.

6. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted, citing the Director’s March 26, 2025 Memorandum on PTAB Workload Management. Petitioner also stipulated under the framework of Sotera Wireless, Inc. v. Masimo Corp. that if the IPR is instituted, it will not pursue in the parallel Texas litigation any ground that was raised or reasonably could have been raised in the petition.

7. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-20 of the ’200 patent as unpatentable.