PTAB

IPR2025-01496

Apple Inc v. Cobblestone Wireless LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: User-Focusing Technique for Wireless Communication Systems
  • Brief Description: The ’347 patent discloses a pre-distortion technique for wireless systems. The method involves a receiver performing a channel estimation based on a first signal to obtain path parameter information, sending this estimation back to the transmitter, which then pre-distorts a second signal in the time, frequency, and spatial domains before transmission to compensate for channel effects.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hardacker - Claims 1, 6, 8, 14-15, and 19 are obvious over Hardacker.

  • Prior Art Relied Upon: Hardacker (Application # 2010/0159855A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hardacker teaches the core concept of the ’347 patent: shifting the burden of distortion compensation from a receiver to a transmitter. Hardacker discloses a bidirectional communication system where a receiving device measures channel distortion from a first signal, determines the parameters of that distortion (e.g., multi-path, amplitude, phase), and relays this information back to the transmitting device. The transmitting device then uses this information to pre-distort a subsequent signal to counteract the channel effects. Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have understood that Hardacker’s disclosure of compensating for various "types of distortion" (e.g., multi-path, amplitude, frequency, phase) inherently teaches pre-distortion in the time, frequency, and spatial domains as claimed.

Ground 2: Obviousness over Hardacker and Medbo - Claims 2-4, 6, 9-12, 16, and 20-23 are obvious over Hardacker in view of Medbo.

  • Prior Art Relied Upon: Hardacker (Application # 2010/0159855A1) and Medbo (Application # 2014/0010274A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Hardacker provides the foundational pre-distortion framework, while Medbo supplies the specific, advanced channel estimation techniques required by the dependent claims. Medbo discloses high-resolution channel estimation methods for determining specific wave parameters, including propagation delay, direction of arrival/departure, complex amplitude, and polarization status. Medbo explicitly teaches using well-known estimation algorithms such as Maximum Likelihood (ML), Space Alternating Generalized Expectation (SAGE), and Richter's Maximum (RiMAX) Likelihood method, which Petitioner argued maps directly to the techniques recited in claims 4, 11, and 22.
    • Motivation to Combine: A POSITA would combine Medbo’s advanced channel estimation with Hardacker’s pre-distortion system to improve the system’s accuracy and effectiveness. Hardacker’s method creates a clear design need for precise channel information, and Medbo provides a predictable, known solution for obtaining such detailed parameters. The combination represents a direct application of an advanced measurement technique to improve a known compensation system.
    • Expectation of Success: A POSITA would have reasonably expected success in integrating Medbo’s detailed channel estimation into Hardacker’s system, as it involved applying known estimation principles to enhance the performance of a pre-distortion feedback loop, a predictable path to achieving improved signal quality and system reliability.

Ground 3: Obviousness over Wallace - Claims 1-2, 8, 12, 15-17, 19-20, and 23 are obvious over Wallace.

  • Prior Art Relied Upon: Wallace (Patent # 6,473,467).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Wallace teaches a method for preconditioning transmissions in a Multiple Input/Multiple Output (MIMO) system based on channel characteristics fed back from a receiver. Wallace discloses transmitting pilot signals, measuring the channel state information (CSI) at the receiver—including amplitude and phase characteristics descriptive of the transmission paths—and reporting this CSI back to the transmitter. The transmitter then uses this information to precondition subsequent data transmissions to achieve antenna (spatial), frequency, and temporal diversity. Petitioner asserted this process directly maps to the ’347 patent’s claimed method of obtaining channel estimation from a first signal and using it to pre-distort a second signal across the time, frequency, and spatial domains.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 2-4, 16, and 20-22 based on Wallace in view of Medbo, relying on a similar motivation-to-combine theory as presented in Ground 2.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It noted its intent to utilize the bifurcated briefing process contemplated in the March 26, 2025, Stewart Memorandum to rebut any contentions raised by the Patent Owner regarding discretionary denial.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6, 8-12, 14-17, and 19-23 of the ’347 patent as unpatentable.