PTAB

IPR2025-01164

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

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: WIRELESS COMMUNICATION METHOD USING BSS IDENTIFIER AND WIRELESS COMMUNICATION TERMINAL USING SAME
  • Brief Description: The ’262 patent discloses a method and terminal for wireless communication within a Basic Service Set (BSS). The technology centers on how a wireless terminal sets a "BSS color" (a BSS identifier) for a trigger-based Physical Layer Protocol Data Unit (PPDU) it transmits in response to a trigger frame from a base station, based on whether the received trigger frame's format includes a BSS color field.

3. Grounds for Unpatentability

Ground 1: Obviousness over IEEE 802.11ax Draft and Supporting Art - Claims 1-4 are obvious over 802.11ax/D1.0 alone, or in combination with Yang and 802.11-2016.

  • Prior Art Relied Upon: 802.11ax/D1.0 (IEEE Draft P802.11ax/D1.0, Nov. 2016), Yang (Application # 2017/0367129), and 802.11-2016 (IEEE Std 802.11-2016).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the 802.11ax/D1.0 draft standard taught every limitation of the challenged claims. Specifically, it disclosed a station (STA) transmitting a trigger-based PPDU differently depending on the format of the received trigger frame. If the trigger frame was an HE (High Efficiency) PPDU format containing a BSS Color field in its HE-SIG-A physical layer signaling, the STA would set the BSS color for its responsive PPDU based on the color indicated in that field (meeting limitations [1.4] and [4.2]). Conversely, if the trigger frame was a non-HE PPDU format lacking a BSS color field, 802.11ax/D1.0 taught that the STA would set the BSS color for its response based on the "BSS Color subfield of the most recently received HE Operation element for that BSS," which Petitioner asserted is the claimed "active BSS color" (meeting limitations [1.5] and [4.3]). For dependent claims, Petitioner argued 802.11ax/D1.0 taught using a "Color Switch Countdown" based on Target Beacon Transmission Times (TBTTs) for BSS color changes (claim 2) and using a Partial Association ID (AID) field to determine if a PPDU is Intra-BSS or Inter-BSS (claim 3).
    • Motivation to Combine (for §103 grounds): A POSITA would combine 802.11ax/D1.0 with Yang and 802.11-2016 because 802.11ax/D1.0 was a proposed amendment to the base 802.11-2016 standard, making their combination natural for a complete system view. Yang was cited to provide explicit disclosure of conventional components like a processor and transceiver that a POSITA would have inherently understood to be part of any STA implementing the 802.11ax/D1.0 protocols.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as the references were all directed to the same field of WLAN technology and were designed to be complementary parts of the same evolving IEEE 802.11 standard.

Ground 2: Obviousness over Yang in view of IEEE Submissions - Claims 1, 2, and 4 are obvious over Yang in view of 802.11-17/0250r2 and 802.11-16/1415r0.

  • Prior Art Relied Upon: Yang (Application # 2017/0367129), 802.11-17/0250r2 (IEEE submission, Mar. 2017), and 802.11-16/1415r0 (IEEE submission, Nov. 2016).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground asserted that Yang disclosed the foundational elements of the claims, including using a trigger frame to solicit a trigger-based PPDU from a station and the use of a BSS Color subfield in an HE-SIG-A field. Petitioner contended that a POSITA would look to other references to supplement Yang's disclosure, particularly for coordinating BSS color when a trigger frame lacks an explicit BSS color field. The 802.11-17/0250r2 submission was argued to provide this missing detail, teaching the exact behavior claimed: setting the BSS color based on the received HE PPDU's BSS color if present, and otherwise setting it based on the "most recently received HE Operation element." Furthermore, Petitioner argued Yang's method for changing BSS colors was deficient, and a POSITA would incorporate the improved BSS color change procedure from 802.11-16/1415r0, which disclosed using a "BSS Color Change Announcement element" with a "Color Switch Countdown" to synchronize a change to a new BSS color at a specific time, meeting limitations [1.8] and [4.6].
    • Motivation to Combine (for §103 grounds): A POSITA starting with Yang’s system for BSS color management would recognize its deficiencies, such as the need for a "Transitory BSS Color" during changes and a lack of precise timing. The POSITA would be motivated to improve Yang by incorporating the more efficient, standardized procedures detailed in the contemporaneous IEEE submissions (802.11-17/0250r2 and 802.11-16/1415r0) to create a more robust and reliable system.
    • Expectation of Success (for §103 grounds): Success was reasonably expected because all references address the same technical problem—BSS color coordination in 802.11ax networks—and the proposed modifications involved combining known techniques from the same standards-development ecosystem to improve a base system.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 3 based on Yang in view of 802.11-17/0250r2, 802.11-16/1415r0, 802.11ax/D1.0, 802.11-2016, and 802.11-17-0230r1, arguing the combination provided explicit teachings for handling legacy non-HE PPDU formats.

6. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. The petition noted an intent to use the bifurcated briefing process per the Stewart Memorandum and referenced a filed *Fintiv* stipulation to address potential arguments from the Patent Owner regarding co-pending district court litigation.

7. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4 of the ’262 patent as unpatentable.