PTAB

IPR2025-01221

Apple Inc v. Advanced Coding Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Device and Method for Judging Communication Quality and Program Used for the Judgment
  • Brief Description: The ’891 patent describes a system for judging communication quality in a digital transmission. The technology involves encoding voice data, separating bits by importance, interleaving the most important bits with predetermined "protective" bits, and modulating the resulting bit pairs into symbols for transmission. A receiver then judges channel quality by counting errors in the received protective bits and can modify the output data if quality is poor.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yamane-Mizuki-Matsumoto - Claims 1, 3, 8, and 9 are obvious over Yamane in view of Mizuki and Matsumoto.

  • Prior Art Relied Upon: Yamane (JP Publication No. JPH05260021A), Mizuki (Patent 6,512,748), and Matsumoto (Patent 5,425,053).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Yamane taught a receiver that judges communication channel quality by comparing a received sequence of known, redundant bits against a stored sequence to count errors. Based on the error count, Yamane selected an appropriate "error control method," such as rejecting the signal. While Yamane disclosed the quality-judging framework, it was silent on the modulation scheme. Mizuki remedied this by teaching a Frequency-Shift Keying (FSK) modulation scheme where data bits are paired with redundant bits of a predetermined value to form two-bit symbols, maximizing signal separation and improving error resilience. To complete the system, Matsumoto taught the specific receiver implementation for judging such multilevel symbols by comparing measured signal levels against a set of threshold "judgment levels."
    • Motivation to Combine: A POSITA would combine Yamane with Mizuki to implement Yamane’s quality-judging system with a specific, robust, and well-known modulation technique that was known to reduce transmission errors. Because neither Yamane nor Mizuki detailed how to demodulate and judge the resulting multilevel symbols, a POSITA would have naturally turned to a reference like Matsumoto, which explicitly taught how to build a receiver to perform this function.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating known techniques (FSK modulation, threshold-based symbol judging) into a known system (error checking via redundant bits) to achieve the predictable result of a functional and robust communication system.

Ground 2: Obviousness over Yamane-Mizuki-Matsumoto-Lagerqvist - Claims 1, 3-9 are obvious over Yamane, Mizuki, and Matsumoto in view of Lagerqvist.

  • Prior Art Relied Upon: Yamane, Mizuki, Matsumoto, and Lagerqvist (Patent 5,502,713).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the base combination of Yamane, Mizuki, and Matsumoto, adding Lagerqvist to provide specific and sophisticated implementations of the "data changing means" required by the claims. Yamane's "error control method" was basic (e.g., signal rejection). Lagerqvist, in the context of a voice decoder, taught more nuanced error concealment methods using a state machine. When a voice data frame was judged "bad," Lagerqvist’s system would perform predetermined changes such as replacing the bad frame with data from a previous good frame (mapping to claim 4), progressively attenuating the data over several consecutive bad frames (mapping to claims 6-7), or completely muting the signal (mapping to claims 3 and 5).
    • Motivation to Combine: A POSITA implementing the base combination for voice communications would find Yamane's simple data rejection method inadequate. The POSITA would be motivated to incorporate Lagerqvist's advanced error concealment techniques to improve the user experience by smoothly concealing low-quality audio through gradual attenuation rather than creating jarring gaps of silence.
    • Expectation of Success: Applying Lagerqvist's known voice error concealment techniques to the base communication system was a straightforward application of a known solution to a known problem that would predictably improve speech quality.

Ground 3: Obviousness over Yamane-Mizuki-Matsumoto-Kaplan - Claim 2 is obvious over Yamane, Mizuki, and Matsumoto in view of Kaplan.

  • Prior Art Relied Upon: Yamane, Mizuki, Matsumoto, and Kaplan (Application # 2004/0203941).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 2, which added a "means for externally obtaining a parameter that defines at least a portion of the condition" for changing the data. The primary combination did not explicitly teach how to set the parameters for this condition (e.g., the error-bit threshold). Kaplan taught that mobile devices can be configured or provisioned by externally obtaining parameters through user interfaces like a keypad, over-the-air updates, or cable connections. This directly maps to the claimed "means for externally obtaining a parameter."
    • Motivation to Combine: A POSITA building the communication device of the primary combination would recognize the need for a mechanism to configure its operational parameters. It would be a simple and logical design step to incorporate a standard, known method for external configuration, as taught by Kaplan, to allow for flexibility and optimization of the device's performance based on different operating conditions.
    • Expectation of Success: Such external configuration interfaces were conventional and ubiquitous in the art before the patent's critical date, ensuring a POSITA would have a reasonable expectation of success in integrating this feature.

4. Key Claim Construction Positions

  • "data to be transmitted": Petitioner argued this term, recited in the context of a "communication quality judging device" (i.e., a receiver), should be construed to mean "data that was to be transmitted by a transmitter and that has been received by a receiver." This construction is critical because the claimed functions—judging communication quality and changing data based on that judgment—are performed at the receiver on a signal that has already been transmitted and received.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-9 of the ’891 patent as unpatentable.