PTAB

IPR2025-01205

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 Device and Method
  • Brief Description: The ’976 patent describes a wireless networking device architecture for evaluating application bandwidth requirements against the available bandwidth of multiple wireless transceivers. The system uses a processing interface with "virtual MAC" and "virtual PHY" layers situated between an application layer and the actual hardware (MAC/PHY) layers to allocate transceiver resources efficiently.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Chincholi (WO 2013/126859), Riggert (Application # 2011/0320625), and Clegg (Patent 9,055,592).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Chincholi, Riggert, and Clegg taught all limitations of the challenged claims. Chincholi was asserted to disclose the fundamental architecture of the ’976 patent: a wireless networking device with multiple transceivers, each with its own actual MAC and PHY interfaces, suitable for use in an 802.11 network. Chincholi’s “Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer” was argued to be the claimed "processing interface," which sits above the hardware layers to aggregate bandwidth and manage data streams from applications. Petitioner contended this OMMA layer and its constituent modules met the limitations for the claimed "virtual MAC interface," including its "decision block" (Chincholi's IP QoS Scheduler), "processing block" (MAC Resource Reservation module), and "ultra-streaming block" (Traffic Shaping Module).

    • The combination with Riggert was argued to supply the claimed "virtual PHY interfaces." While Chincholi taught feeding back bandwidth information to its OMMA layer, Riggert explicitly taught a "bondable virtual interface" that provides a flexible, virtualized layer over the actual PHY hardware. Petitioner argued it would have been obvious to implement Riggert's virtual PHYs into Chincholi’s system to collect feedback from the individual transceivers and provide it to the OMMA layer, thereby creating the claimed virtual PHY interfaces containing "RF blocks" that report on resource availability.

    • Finally, Clegg was asserted to teach limitations related to identifying and using only the available portions of a bandwidth channel. Clegg disclosed evaluating interference on a carrier-by-carrier basis and "notching out" specific subcarriers with high interference. This taught the claimed steps of evaluating whether resources are unavailable and then using a subset of frequencies corresponding only to the available resources to transmit a data stream. This logic was applied to independent claims 1, 14, 18, 21, 23, 25, and 29, with Petitioner arguing the core teachings covered the variations in these claims, such as aggregating bandwidth for simultaneous transmission or reception.

    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine these references to achieve predictable benefits. A POSITA would combine Chincholi with Riggert to improve the flexibility of Chincholi’s system. Adding Riggert's virtualized PHY interface would allow Chincholi's architecture to more easily accommodate and interface with wireless devices operating on different generations of 802.11 standards. Subsequently, a POSITA would incorporate Clegg’s teachings to further enhance the bandwidth efficiency of the combined Chincholi/Riggert system. Clegg provided a known technique to mitigate carrier-specific interference, allowing the system to more flexibly and efficiently utilize available spectrum by using non-contiguous portions of a channel that Chincholi already taught could be aggregated.

    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in making this combination. The proposed modifications were presented as straightforward implementations of known principles to improve a known system. Implementing Riggert's virtualized PHY was a logical extension of the virtualized MAC concept already present in Chincholi's OMMA layer, and Clegg's interference mitigation was a well-understood technique in the 802.11 field.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-30 of the ’976 patent as unpatentable under 35 U.S.C. §103.