PTAB

IPR2025-01209

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 ’414 patent discloses a method for improving the performance of a wireless networking device by using a processing interface to manage and allocate bandwidth from multiple wireless transceivers. The system uses virtual MAC and PHY layers to dynamically satisfy an application's bandwidth requirements by aggregating resources from transceivers operating on different frequency bands.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chincholi and Riggert - Claims 1-2 and 13-30 are obvious over Chincholi in view of Riggert.

  • Prior Art Relied Upon: Chincholi (International Publication No. 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 ’414 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 the claimed “processing interface,” which sits above the actual MAC/PHY layers to aggregate bandwidth from different radio access technologies (RATs) to meet application data stream requirements. This OMMA layer functions as a virtual MAC interface by transparently distributing packets across the multiple transceivers. Petitioner contended that Chincholi failed to explicitly disclose virtual PHY interfaces. Riggert was asserted to cure this deficiency by teaching a “bondable virtual interface” that provides a virtualized, flexible interface to the actual PHY layers, allowing multiple physical interfaces to be combined to improve data throughput.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Riggert’s virtual PHY interface with Chincholi’s system to increase flexibility and improve performance. Because Chincholi already disclosed a virtualized MAC function in its OMMA layer, a POSITA would have found it a logical and predictable step to also virtualize the PHY layer as taught by Riggert. This combination would create a universal interface, allowing Chincholi’s system to operate seamlessly with a wider variety of recipient devices that use different generations of 802.11 standards.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references address increasing bandwidth efficiency in multi-transceiver 802.11 networks. Implementing Riggert's virtualized PHY interfaces was presented as a straightforward modification to Chincholi’s architecture, given that Chincholi already established the concept of virtualization at the MAC layer.

Ground 2: Obviousness over Chincholi, Riggert, and Choi - Claims 3-12 are obvious over Chincholi in view of Riggert and Choi.

  • 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 builds upon the combined Chincholi/Riggert system from Ground 1 and adds the teachings of Choi to address limitations in claims 3-12 related to dynamically responding to changes in bandwidth availability. Petitioner argued that claim 3, for instance, requires the processing interface to identify and select a new portion of bandwidth when an existing portion becomes unavailable. While Chincholi taught monitoring RAT capabilities and available resources, Choi was asserted to provide specific, well-known techniques for dynamic frequency selection in 802.11 networks. Choi taught monitoring channel quality via metrics like Received Signal Strength Indication (RSSI) and Clear Channel Assessment (CCA), and upon detecting poor channel quality (i.e., unavailability), selecting and switching to a new channel with a better signal quality.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Choi’s teachings to enhance the Chincholi/Riggert system. The base combination already identified available bandwidth, but Choi provided a more robust and efficient methodology for dynamically managing channel selection to minimize interference and optimize performance. Choi’s techniques for measuring channel characteristics and switching to a channel with minimum interference would have been seen as a complementary improvement to the bandwidth aggregation and management functions of the Chincholi/Riggert system.
    • Expectation of Success: The combination was asserted to be predictable with a high expectation of success. All three references operate in the same field of 802.11 wireless networking. Choi’s teachings represent a known solution to the common problem of channel interference and degradation, providing a specific implementation for a function (dynamic channel switching) that would naturally be desired to optimize a multi-RAT system like that disclosed by Chincholi and Riggert.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’414 patent as unpatentable under 35 U.S.C. §103.