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IPR2025-01270

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

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Improving Wireless Networking System Performance
  • Brief Description: The ’177 patent is directed to methods for improving the performance of a wireless networking device by using a processing interface to manage and allocate bandwidth from multiple wireless transceivers based on an application's bandwidth requirements.

3. Grounds for Unpatentability

Ground 1: Claims 1-26 are obvious over Chincholi in view of Clegg.

  • Prior Art Relied Upon: Chincholi (International Publication No. WO 2013/126859) and Clegg (Patent 9,055,592).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chincholi teaches the core architecture of the ’177 patent. Chincholi discloses a wireless networking device with multiple transceivers, each with its own actual MAC and PHY interfaces, operating on different frequency bands. Critically, Chincholi describes an "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer" that functions as the claimed "processing interface." This OMMA layer sits above the actual MAC/PHY layers and is connected to an application's IP layer.
      • Petitioner asserted that Chincholi’s OMMA layer is a "virtual MAC interface" because it aggregates multiple underlying MAC interfaces and transparently presents a single interface to the IP layer. The functional blocks within the OMMA layer—such as the IP QoS Scheduler, MAC Resource Reservation module, and Traffic Shaping Module—were argued to directly correspond to the claimed "decision block," "processing block," and "ultra-streaming block" of the virtual MAC interface.
      • Chincholi was also argued to teach a "resource monitoring interface." The OMMA layer's controller receives feedback metrics (e.g., channel quality, available resources) from each transceiver's Radio Access Technology (RAT), which constitutes feeding bandwidth availability information back to the virtual MAC interface for packet routing decisions.
      • While Chincholi discloses aggregating bandwidth from different transceivers, Petitioner contended that Clegg supplies the teaching of evaluating and avoiding unavailable resources within a given channel. Clegg teaches a system that evaluates interference on a carrier-by-carrier basis and creates a "cluster of carriers" for communication using only the sub-channels that are not unavailable due to interference. Petitioner argued this directly maps to claim limitations requiring evaluation of whether resources are "unavailable" and then using a subset of frequencies corresponding only to available resources.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Clegg's interference mitigation technique into Chincholi's bandwidth aggregation system to improve overall performance and efficiency. Chincholi provides a system for dynamic bandwidth allocation across multiple RATs, a primary goal of which is to maximize throughput. Clegg provides a known and complementary method for increasing bandwidth efficiency within any given 802.11 channel by avoiding carrier-specific interference. A POSITA would have recognized that incorporating Clegg's teachings would allow the Chincholi system to more flexibly and efficiently utilize channels that might otherwise be considered degraded or unusable, a clear and predictable improvement.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success in combining the references. Both Chincholi and Clegg operate in the field of 802.11 wireless networking and address the common problem of increasing bandwidth efficiency. The combination involves applying Clegg’s technique for fine-grained resource selection within a channel to Chincholi’s broader framework for allocating those channels, which Petitioner argued would be a straightforward implementation without technical challenges.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-26 of the ’177 patent as unpatentable.