PTAB

IPR2025-01207

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

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Improving Circuitry Performance in Wireless Networking
  • Brief Description: The ’933 patent relates to methods for improving the performance of wireless networking circuitry. The invention describes using a processing layer, positioned between an application layer and the actual MAC and PHY layers, which employs virtual MAC and PHY interfaces to evaluate application bandwidth requirements and dynamically allocate resources from multiple wireless transceivers to meet those needs.

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). Petitioner noted that none of these references were considered by the examiner during the prosecution of the ’933 patent, which was allowed without rejection under a Track One request.
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued the combination of Chincholi, Riggert, and Clegg teaches every limitation of the challenged claims. Chincholi, the primary reference, was asserted to disclose the core architecture of the ’933 patent: a wireless networking device with multiple transceivers, each with its own actual MAC and PHY interfaces. Chincholi’s “Opportunistic Multiple-Medium Access Control (MAC) Aggregation layer” (OMMA) was identified as the claimed "processing interface" that sits above the actual MAC/PHY layers. This OMMA layer aggregates available bandwidth from the transceivers to meet application data stream requirements, thereby functioning as the claimed "virtual MAC interface" that transparently manages traffic for higher-level applications.

      To meet the "virtual PHY interface" limitation, Petitioner relied on Riggert. Riggert was argued to teach a "bondable virtual interface" that provides a virtualized, flexible interface to actual PHY layers in a multi-transceiver system. This allows for easy substitution and generic use across different physical interfaces, such as those conforming to different 802.11 standards. Petitioner asserted that adding Riggert’s virtual PHY interfaces to Chincholi’s OMMA controller would be a natural and obvious improvement.

      To address limitations related to evaluating resource unavailability and using only available frequencies, Petitioner introduced Clegg. Clegg was argued to teach techniques for mitigating carrier-specific interference in 802.11 systems. It discloses evaluating the available spectrum on a carrier-by-carrier basis and creating a "channel map" to select a cluster of available carriers for communication, effectively "notching out" subcarriers that suffer from high interference. This directly teaches the claimed steps of evaluating whether resources are unavailable and using a subset of frequencies corresponding only to the available resources.

    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to achieve a more flexible and efficient system. A POSITA would combine Riggert's virtual PHY interface with Chincholi’s OMMA layer to improve Chincholi's system by providing a universal interface that allows seamless operation with a wider variety of recipient devices operating on different 802.11 standards. The motivation to add Clegg was to further improve the resulting system’s bandwidth efficiency. A POSITA would combine Clegg’s teachings on carrier-specific interference mitigation to allow the Chincholi/Riggert system to more flexibly and efficiently utilize available channels that may experience such interference, a known problem in the field.

    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success in making this combination. Because Chincholi already taught the virtualization of the MAC function in its OMMA layer, implementing Riggert's virtualized PHY interfaces would have been a straightforward and predictable enhancement. Similarly, since all three references operate in the same field of 802.11 wireless networking and address the common goal of increasing throughput, integrating Clegg's known interference mitigation techniques into the Chincholi/Riggert framework would present no significant technical challenge and would be expected to yield the predictable benefit of improved performance in real-world environments with interference.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of Patent 12,015,933 as unpatentable under 35 U.S.C. §103.