PTAB

IPR2025-01208

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 ’143 patent discloses a wireless networking system that uses a processing layer with "virtual MAC" and "virtual PHY" interfaces to manage and allocate bandwidth from multiple wireless transceivers. The system evaluates the bandwidth requirements of various applications and allocates resources from the transceivers to meet those needs.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chincholi and Riggert - Claims 1-30

  • 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 ’143 patent, including a wireless networking device with multiple transceivers, each with actual MAC and PHY interfaces. Chincholi’s “Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer” was asserted to be a processing interface positioned above the actual MAC/PHY layers that aggregates available bandwidth to meet application data stream requirements. This OMMA layer functions as the claimed "virtual MAC interface" by transparently distributing packets between an IP layer and multiple radio access technologies (RATs). Petitioner contended that while Chincholi disclosed the virtual MAC, it did not explicitly detail virtual PHY interfaces. Riggert was introduced to supply this element, as it taught a "bondable virtual interface" that provides a virtualized, flexible interface to the actual PHY interfaces to improve throughput in multi-transceiver networks.
    • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would combine Riggert’s virtual PHY interface with Chincholi’s OMMA layer system. Both references address the same problem of increasing bandwidth efficiency in 802.11 multi-transceiver networks. A POSITA would see the benefit of adding Riggert's flexible virtual PHY to Chincholi's system to create a universal interface that could seamlessly operate with a wider variety of recipient devices using different 802.11 standards.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because implementing Riggert’s virtualized PHY would be a straightforward extension of Chincholi’s existing architecture. Since Chincholi already contemplated the virtualization of the MAC function at its OMMA layer, adding a virtualized PHY interface would be a logical and predictable improvement.

Ground 2: Obviousness over Chincholi, Riggert, and Choi - Claims 19-29

  • Prior Art Relied Upon: Chincholi (WO 2013/126859), Riggert (Application # 2011/0320625), and Choi (Patent 7,206,840).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Chincholi and Riggert from Ground 1, adding Choi to address the specific limitations of claims 19 and 20. These claims recite identifying and switching to a new portion of bandwidth if the currently used portion becomes unavailable or if a better portion is identified. Petitioner argued that the Chincholi/Riggert combination taught monitoring and responding to bandwidth availability, but Choi provided explicit teachings on this dynamic frequency selection. Choi disclosed a method for addressing interference in WLAN networks by measuring frequency channel characteristics (e.g., Received Signal Strength Indication (RSSI), Clear Channel Assessment (CCA)) and dynamically selecting a new channel with minimum interference when the current one becomes unavailable or degraded.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to incorporate Choi's dynamic channel selection teachings into the Chincholi/Riggert system to enhance its performance and robustness. The Chincholi/Riggert combination already identified available bandwidth, and Choi taught a well-known, complementary technique for efficiently managing channel selection to minimize interference and optimize performance. This would allow the combined system to more flexibly and efficiently utilize available bandwidth, a known goal in the art.
    • Expectation of Success: Petitioner asserted the combination would be successful because the teachings were complementary and addressed different aspects of a common system. Chincholi/Riggert provided the high-level multi-transceiver aggregation framework, while Choi provided a specific, known method for low-level channel management within that framework, which would not present technical challenges to implement.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’143 patent as unpatentable.