PTAB

IPR2025-01206

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

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of improving the performance of a wireless networking device
  • Brief Description: The ’105 patent describes methods for improving wireless network performance by using a processing interface positioned between an application layer and the actual physical (PHY) and media access control (MAC) layers. This processing interface employs virtual MAC and virtual PHY layers to evaluate application bandwidth requirements against transceiver resource availability and dynamically allocate resources from multiple transceivers to satisfy those requirements.

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 discloses every limitation of the challenged claims. Chincholi was asserted to teach the core architecture of the ’105 patent: a wireless networking device with multiple transceivers, each with its own actual MAC and PHY interfaces, managed by a centralized aggregation layer (the "OMMA layer") that functions as the claimed processing interface. This OMMA layer receives application data streams, connects to the actual MAC/PHY layers, and manages data traffic across multiple Radio Access Technologies (RATs) to improve performance.

    • To meet the limitations related to "virtual PHY interfaces" (claim 1[e]), Petitioner contended a POSITA would modify Chincholi with the teachings of Riggert. Riggert explicitly discloses a "bondable virtual interface" that virtualizes the physical layer to flexibly combine multiple physical transceivers, which directly corresponds to the claimed virtual PHY interface.

    • To meet limitations regarding evaluating unavailable resources and using only a subset of available frequencies (claims 1[i] and 1[j]), Petitioner relied on Clegg. Clegg teaches techniques for mitigating carrier-specific interference in 802.11 systems by evaluating the entire available spectrum on a carrier-by-carrier basis to identify interference. It then "notches out" unavailable subcarriers and forms a "cluster of carriers" from the remaining, available frequencies for communication. This was argued to be a direct teaching of evaluating whether resources are unavailable and then using a subset of those that are not.

    • For the limitation requiring that utilization by one device does not prevent others from using remaining bandwidth (claim 1[k]), Petitioner argued Chincholi discloses the use of Orthogonal Frequency Division Multiple Access (OFDMA). OFDMA is a known technique that divides available bandwidth into orthogonal subcarriers that can be allocated to different users simultaneously without interference, thus meeting the claim element. Petitioner mapped the limitations of the dependent claims to more specific disclosures within the combined teachings of the three references.

    • Motivation to Combine: Petitioner asserted a POSITA would combine these references to solve known problems in the field. A POSITA would have been motivated to modify Chincholi’s system, which already virtualizes the MAC layer via its OMMA, by incorporating Riggert’s virtual PHY interface. This combination would create a more flexible and reconfigurable system capable of accommodating various wireless devices operating on different 802.11 standards, a recognized benefit. The motivation to further add Clegg’s teachings stemmed from the desire to enhance Chincholi’s resource monitoring capabilities. By incorporating Clegg's method of mitigating carrier-specific interference, the combined system could more efficiently utilize available bandwidth, a primary goal in wireless networking. All three references address the same field of endeavor—increasing throughput and efficiency in multi-transceiver wireless networks.

    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success in making this combination. Integrating Riggert's virtual PHY layer was presented as a straightforward extension of the virtualization already present in Chincholi's OMMA layer. Similarly, incorporating Clegg’s interference mitigation techniques was described as implementing a known method to improve a known system, which would not have presented a technical challenge. The combination simply applied established principles to achieve predictable results and known benefits.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’105 patent as unpatentable under 35 U.S.C. §103.