PTAB

IPR2025-01204

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 ’591 patent discloses a wireless networking system featuring multiple transceivers and a processing layer. This processing layer utilizes virtual Medium Access Control (MAC) and Physical (PHY) interfaces to evaluate application bandwidth requirements against the available bandwidth of the transceivers and to allocate resources accordingly.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chincholi and Riggert - Claims 1-26 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 teaches the foundational architecture of the ’591 patent, including a wireless networking device with multiple Radio Access Technology (RAT) interfaces, each comprising actual MAC and PHY layers and an associated transceiver. Chincholi’s “Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer” was asserted to be a processing interface that functions as the claimed “virtual MAC interface” because it sits above the actual MACs and transparently aggregates their bandwidth to serve application data streams (IP flows). While Chincholi discloses this virtual MAC, it lacks an explicit disclosure of virtual PHY interfaces. Petitioner contended that Riggert remedies this deficiency by teaching a “bondable virtual interface,” which is a virtualized PHY interface designed to provide a flexible and generic interface to multiple, potentially different, actual PHY layers.
    • Petitioner asserted that combining Riggert’s virtual PHY with Chincholi’s OMMA layer would result in the claimed invention. The combined system would have virtual PHY interfaces that feed bandwidth availability information—a function Chincholi’s OMMA layer already performs—back to the virtual MAC. Chincholi was argued to further disclose the remaining limitations of independent claim 1, such as creating associations with recipient devices, identifying available bandwidth portions, evaluating them against application requirements, and preparing data streams for simultaneous transmission across multiple transceivers. Dependent claims were mapped to Chincholi’s disclosures of access points (claim 2), handheld devices (claim 3), use of IEEE 802.11 standards (claims 4-5), dynamic reallocation of resources when a transceiver becomes unavailable (claims 7-9), and management of multiple application flows (claim 10).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Riggert’s teachings with Chincholi’s system to enhance its flexibility and performance. Petitioner argued that since Chincholi already discloses a partially virtualized architecture with its OMMA (virtual MAC) layer, it would have been a logical and predictable step to implement Riggert’s virtualized PHY interface to create a more robust and adaptable system. This combination would be particularly advantageous for accommodating devices operating on different generations of the 802.11 standard, a benefit explicitly mentioned by Riggert. Both references are in the same technical field of improving bandwidth efficiency and throughput in multi-transceiver wireless networks, strengthening the motivation to combine their teachings.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success in this combination. The integration of Riggert's virtual PHY interface was presented as a complementary improvement to Chincholi’s existing architecture, not a complex or unpredictable undertaking. Given that Chincholi already contemplates MAC-level virtualization and feedback-based resource management, adding a standardized virtual PHY layer would be a straightforward engineering task.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-26 of Patent 11,818,591 as unpatentable under 35 U.S.C. §103.