PTAB
IPR2025-01187
Samsung Electronics Co Ltd v. Hannibal IP LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2025-01187
- Patent #: 11,057,896
- Filed: July 29, 2025
- Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
- Patent Owner(s): Hannibal IP, LLC
- Challenged Claims: 1-19
2. Patent Overview
- Title: 5G Wireless Communication Method for Beam Management
- Brief Description: The ’896 patent relates to methods and devices for managing downlink communications in 5G wireless systems. The technology addresses ambiguity in "beam switching" by applying a Quasi Co-Location (QCL) assumption from a specific Control Resource Set (CORESET)—the one with the lowest CORESET Identity (ID) among all monitored CORESETs—to receive subsequent signals like an aperiodic Channel Status Information-Reference Signal (CSI-RS) or a Physical Downlink Shared Channel (PDSCH), particularly when the scheduling offset is below a threshold.
3. Grounds for Unpatentability
Ground 1: Claims 1-9 and 11-19 are obvious over Guo in view of Intel.
- Prior Art Relied Upon: Guo (Application # 2018/0343653) and Intel (3GPP TSG RAN WG1 Meeting #94bis R1-1810751).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Guo disclosed a User Equipment (UE) consistent with the 5G-Standard, which used a default QCL assumption based on the CORESET with the lowest ID among all configured CORESETs (both monitored and non-monitored). However, Guo did not explicitly limit this selection to only monitored CORESETs. Intel, a technical proposal to the 3GPP standards body, allegedly supplied this missing element by expressly teaching the use of the default beam from the monitored CORESET with the lowest ID for CSI acquisition. Petitioner asserted that combining Guo's standard 5G UE with Intel's proposed improvement satisfies the limitations of independent claim 1, which requires applying a QCL assumption from the "first CORESET" (defined as the monitored CORESET with the lowest ID) to receive a CSI-RS.
- Motivation to Combine: A POSITA would combine Guo and Intel to improve the performance and accuracy of the UE. Intel explicitly stated its method is "better" because it allows the CSI-RS to convey more accurate channel conditions for the PDSCH. Furthermore, Intel’s proposal was designed to resolve a known ambiguity in the 5G Standard (which Guo implements) concerning beam selection when scheduling offsets are small, a problem Guo itself acknowledged.
- Expectation of Success: A POSITA would have a high expectation of success because the combination involved integrating a specific, targeted improvement (Intel) into a standard-compliant system (Guo). As Intel was a formal proposal to the 5G standards engineering community, its compatibility and functionality within a 5G system were well-understood and predictable.
Ground 2: Claim 10 is obvious over Guo in view of ZTE.
- Prior Art Relied Upon: Guo (Application # 2018/0343653) and ZTE (3GPP TSG RAN WG1 Meeting #94 R1-1808197).
- Core Argument for this Ground:
- Prior Art Mapping: This ground follows a similar logic to Ground 1 but targets claim 10, which relates to receiving a PDSCH instead of a CSI-RS. Petitioner argued Guo disclosed the foundational 5G UE but not the specific claimed method of selecting the default QCL assumption from only monitored CORESETs. ZTE, another proposal to the 5G standard-setting body, allegedly taught this exact step for PDSCH reception. ZTE proposed that when the time offset is smaller than a threshold, the UE obtains the QCL parameter from the CORESET with the lowest ID that is associated with a search space "monitored by the UE." The combination of Guo's UE with ZTE's specific instruction allegedly renders claim 10 obvious.
- Motivation to Combine: A POSITA would combine the references to enhance the accuracy of Guo’s UE when scheduling a PDSCH with a short offset. The 5G standards community was actively working to clarify this procedure, and ZTE’s proposal provided a clear benefit by avoiding the technical difficulty of examining non-monitored search spaces. This made the system more efficient and reliable, providing a strong motivation for its adoption.
- Expectation of Success: Success was reasonably expected because ZTE's proposal was a direct improvement to the 5G Standard that Guo's UE was designed to follow. Implementing the logic—limiting the CORESET search to monitored sets—was described as a straightforward software update within the skill of a POSITA.
Ground 3: Claims 1-9 and 11-19 are obvious over 5G-Standard in view of Intel.
- Prior Art Relied Upon: 5G-Standard (3GPP TS 38.214 v15.3.0) and Intel (3GPP TSG RAN WG1 Meeting #94bis R1-1810751).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that the primary reference, 5G-Standard, disclosed the general rule that a UE should apply a "default QCL assumption" when the scheduling offset for a CSI-RS is smaller than a threshold. However, the standard itself did not specify how to determine this default QCL. Intel’s proposal directly addressed this gap by teaching that the default beam should follow the TCI state (which defines the QCL) of the monitored CORESET with the lowest ID. This combination provides a complete mapping to the limitations of claims 1 and 11.
- Motivation to Combine: A POSITA would have been motivated to combine the references because Intel provided a specific, elegant solution to an open question in the 5G-Standard. The combination resolves ambiguity and improves the accuracy of channel state reporting. The very purpose of the Intel proposal was to clarify and improve the existing standard, making the motivation to combine inherent.
- Expectation of Success: A POSITA would have a high expectation of success in combining a proposed clarification (Intel) with the standard it was intended to clarify (5G-Standard). The implementation was a predictable software modification.
- Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 10 based on 5G-Standard in view of ZTE, relying on a similar rationale where ZTE provided the specific implementation for the general rule disclosed in the 5G-Standard.
4. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’896 patent as unpatentable.
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