PTAB

IPR2025-01203

Samsung Electronics Co Ltd v. XiFi Networks R&D Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Networking System
  • Brief Description: The ’337 patent relates to a method for improving the performance of a wireless networking device by evaluating application bandwidth requirements against the available bandwidth of multiple transceivers. The system uses a processing layer, situated between an application layer and the actual MAC and PHY layers, to allocate transceiver resources to satisfy application requirements.

3. Grounds for Unpatentability

Ground 1: Claims 1-30 are obvious over Chincholi in view of Riggert

  • Prior Art Relied Upon: Chincholi (WO 2013/126859) and Riggert (Application # 2011/0320625).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Chincholi taught the core architecture of the ’337 patent. Chincholi disclosed a multi-transceiver wireless device with multiple Radio Access Technology (RAT) interfaces, each having its own actual MAC and PHY layers. Above these layers, Chincholi taught an "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer," which Petitioner asserted functioned as the claimed "processing interface." This OMMA layer received feedback on bandwidth availability from each RAT to manage and route data streams from one or more applications, thereby improving performance.

    • Petitioner contended that Chincholi’s OMMA layer inherently disclosed the claimed "virtual MAC interface." The OMMA layer aggregated multiple actual MAC interfaces and transparently distributed data packets between the IP layer and the various RATs, effectively appearing as a single, virtualized MAC interface to the higher-level application layer. The petition mapped specific functional modules within Chincholi’s OMMA layer (e.g., IP QoS Scheduler, MAC Resource Reservation module, Traffic Shaping module) to the claimed "decision," "processing," and "ultra-streaming" blocks of the virtual MAC interface.

    • While Chincholi taught a virtual MAC, Petitioner asserted it did not explicitly disclose "virtual PHY interfaces" that feed bandwidth information back to the virtual MAC. To supply this element, Petitioner turned to Riggert. Riggert taught techniques for improving throughput in multi-transceiver networks by using a "bondable virtual interface," which provided a virtualized, flexible interface to the actual PHY layers. This virtual PHY allowed different physical interfaces to be combined and used generically by the system.

    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Riggert's virtual PHY interface with Chincholi's system to increase flexibility and efficiency. Chincholi already disclosed a system that could operate with various 802.11 standards (e.g., 802.11n, 802.11ac). Riggert’s virtualized PHY interface was particularly beneficial for accommodating different generations of communication standards. Since Chincholi already virtualized the MAC layer with its OMMA layer, a POSITA would find it a logical and advantageous step to also virtualize the PHY interfaces using Riggert's teachings. This modification would allow Chincholi’s OMMA layer to interface more seamlessly with a wider variety of RATs without requiring static, limited interfaces. The combined system would use Riggert’s virtual PHY interfaces to collect the bandwidth feedback metrics that Chincholi’s OMMA layer already used for its traffic shaping decisions.

    • Expectation of Success: A POSITA would have a reasonable expectation of success in making this combination. Both references were in the same field of increasing bandwidth and throughput in multi-transceiver wireless networks, and both addressed 802.11 systems. Implementing Riggert's virtual PHY interfaces into Chincholi's OMMA controller would be a straightforward integration, as it would simply provide a more flexible mechanism for collecting the feedback data that Chincholi's system was already designed to use. The result would be a system where the processing interface (Chincholi's OMMA layer) contained both a virtual MAC and virtual PHY interfaces (from Riggert) that fed back bandwidth availability, thus rendering the claims of the ’337 patent obvious. The arguments for dependent claims 2-30 were presented as extensions of this primary combination, applying the same core logic to limitations involving additional data streams, dynamic transceiver switching, and further transceivers.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’337 patent as unpatentable under 35 U.S.C. §103.