PTAB

IPR2025-01190

Samsung Electronics Co Ltd v. Hannibal IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: 5G Wireless Communications and Beam Operations
  • Brief Description: The ’661 patent relates to methods for a User Equipment (UE) in a 5G wireless system to perform beam operations. The invention is directed at resolving ambiguity in beam switching by applying a Quasi Co-Location (QCL) assumption from a specific Control Resource Set (CORESET) — the one with the lowest ID among all monitored CORESETs — when a scheduling offset is below a certain threshold.

3. Grounds for Unpatentability

Ground 1: Claims 1-16 are obvious over Guo in view of Intel.

  • Prior Art Relied Upon: Guo (Application # 2018/0343653) and Intel (a 3GPP contribution document, R1-1810751).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Guo, which describes a 5G-compliant UE, discloses most elements of the challenged claims, including monitoring CORESETs, receiving Downlink Control Information (DCI) with a scheduling offset, and applying QCL assumptions to handle beam switching for receiving a Downlink Reference Signal (DL RS). However, Petitioner contended that Guo, like the 5G Standard it implements, applies a default QCL based on the CORESET with the lowest ID among all configured CORESETs (both monitored and non-monitored). Intel, a proposal to the 5G standards body, was argued to supply the missing element by expressly teaching the use of the default beam associated with the monitored CORESET having the lowest ID. The combination of Guo's standard-compliant UE with Intel's specific improvement was alleged to render the claimed invention obvious.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Guo and Intel for several reasons. First, Intel’s proposal was presented as an improvement to the 5G Standard that Guo implements, offering a "better" and more accurate method for determining the default beam. Second, the 5G Standard implemented by Guo already required a "default QCL assumption" in short-offset scenarios but did not specify it; Intel provided this missing specification. Third, Intel's teaching directly addressed the beam-switching difficulty problem that Guo itself identified, making it a natural solution.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved a direct incorporation of Intel’s specific, targeted improvement into Guo’s existing 5G framework. The proposed modification was a predictable software change that comported with the design principles already present in Guo and the underlying 5G Standard.

Ground 2: Claims 1-16 are obvious over the 5G-Standard in view of Intel.

  • Prior Art Relied Upon: 5G-Standard (3GPP TS 38.214 v15.3.0) and Intel (a 3GPP contribution document, R1-1810751).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground is similar to Ground 1 but uses the 5G-Standard itself as the primary reference. Petitioner argued the 5G-Standard explicitly disclosed the foundational elements, including the procedure for a UE to apply a "default QCL assumption" to receive an aperiodic CSI-RS when the scheduling offset is smaller than a reported threshold. The standard specified using the CORESET with the "lowest CORESET-ID" for this purpose. As with Guo, the 5G-Standard’s rule applied to the lowest ID among all configured CORESETs. Petitioner contended that Intel’s proposal to refine this rule—by limiting the selection to only monitored CORESETs—was an obvious improvement to the existing standard.
    • Motivation to Combine: Petitioner argued a POSITA would combine the 5G-Standard with Intel because Intel's proposal was created for the express purpose of improving the 5G-Standard. Both documents address the exact same technical scenario (applying a default QCL for aperiodic CSI-RS when the scheduling offset is small). Intel offered a more accurate and less ambiguous solution to a known issue, which would have motivated a POSITA to integrate its teachings into the standard framework.
    • Expectation of Success: There was a high expectation of success because implementing Intel's proposal into the 5G-Standard framework required only ordinary skill. The combination was a direct application of Intel's logic, which was designed to be compatible with the standard, and could be implemented via routine software modifications.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of Patent 11,641,661 as unpatentable.