PTAB

IPR2025-01497

Apple Inc v. Cobblestone Wireless LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: WIRELESS COMMUNICATION SYSTEMS AND METHODS
  • Brief Description: The ’802 patent discloses a wireless communication system and method intended to overcome the capacity limitations of systems that transmit on a single center frequency. It proposes simultaneously transmitting multiple signals over a single communication channel by using one transmitter to send first information across a first frequency range and second information across a second, different frequency range, thereby increasing the total data throughput.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rofougaran - Claims 1-4, 6-8, 10, 13, 17, and 21 are obvious over Rofougaran.

  • Prior Art Relied Upon: Rofougaran (Application # 2007/0127590).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rofougaran discloses a system for multi-mode communication that renders the challenged method and system claims obvious. The petition focused heavily on Rofougaran's FIG. 2, which illustrates a system that receives a first baseband signal and a second baseband signal. A "Spectral Placement Module" spectrally shifts the first signal by a frequency fs, creating a new frequency spectrum distinct from the second signal's spectrum. A "Signal Combiner" then generates a composite signal comprising both the shifted first signal and the original second signal. This composite signal is then upconverted by an "upconverter" and transmitted by an "RF Xmit Stage" including an antenna. Petitioner asserted this process directly maps to the limitations of independent claims 1, 10, and 17, which require simultaneously transmitting first and second information across distinct frequency ranges using the same wireless transmitter. For dependent claims, Petitioner contended Rofougaran’s RF transmission stage explicitly includes a power amplifier, meeting claim 3. Further, the frequency spectrum diagrams in Rofougaran were alleged to show the frequency difference between the two signal components is greater than the sum of one-half of their respective ranges, satisfying claim 2. Petitioner also argued Rofougaran taught limitations of various dependent claims, as it explicitly discloses that the two baseband signals may correspond to different communication protocols (satisfying claim 6) or could be generated dependently for a single communication, such as transmitting the same data for frequency diversity (satisfying claims 7 and 8).
    • Key Aspects: A central pillar of the argument was that a POSITA would find it obvious to combine teachings from Rofougaran’s different embodiments. For example, to address claims requiring digital signal inputs (e.g., claim 10), Petitioner argued it would be obvious to incorporate the digital-to-analog converters (DACs) from Rofougaran’s FIG. 6 into the architecture of FIG. 7, as Rofougaran taught that its various systems could share characteristics.

Ground 2: Obviousness over Rofougaran and Shearer - Claims 9 and 23 are obvious over Rofougaran in view of Shearer.

  • Prior Art Relied Upon: Rofougaran (Application # 2007/0127590) and Shearer (Patent 7,742,388).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claims 9 and 23, which add limitations specifying that the transmitted information comprises a plurality of Orthogonal Frequency-Division Multiplexing (OFDM) symbols transmitted in successive time slots. Petitioner argued that Rofougaran provides the primary architecture for combining and transmitting different signals, including IEEE 802.11 signals which utilize OFDM, but does not specify the temporal structure of the transmission. Shearer was introduced to supply this missing detail. Shearer discloses techniques to increase the data rate of 802.11 transmissions by combining multiple OFDM packets. Specifically, Shearer’s FIG. 7 illustrates combining two 20 MHz 802.11a/g OFDM packets into a single 40 MHz structure for transmission. Critically, Petitioner pointed to Shearer’s FIG. 19, which explicitly depicts a "time slot" for transmitting a set of combined OFDM packets. This teaching, when applied to Rofougaran's system, allegedly results in the claimed method: transmitting a first OFDM symbol (from the first information stream) and a second OFDM symbol (from the second) during a first time slot, followed by a third and fourth symbol during a second time slot.
    • Motivation to Combine: Petitioner asserted that a POSITA tasked with implementing Rofougaran's system for the 802.11 protocols explicitly mentioned by Rofougaran would be motivated to consult a reference like Shearer. Shearer addresses the specific problem of how to structure and transmit 802.11 OFDM symbols for higher throughput. The motivation would be to apply Shearer’s well-understood time-slotting technique to Rofougaran’s compatible signal-combining framework to create an operational and efficient system.
    • Expectation of Success: The combination was presented as a predictable integration. A POSITA would have a high expectation of success in applying Shearer’s specific data structuring method (OFDM time slots) to Rofougaran’s general transmission architecture, as both operate in the same technical field and address the common goal of enhancing wireless data transmission.

4. Arguments Regarding Discretionary Denial

  • Acknowledging several pending civil actions involving the ’802 patent, Petitioner argued that discretionary denial is nonetheless unwarranted. The petition stated its intent to use the PTAB’s bifurcated briefing process, as outlined in the March 2025 Stewart Memorandum, to rebut any arguments for discretionary denial that might be raised by the Patent Owner based on the parallel litigation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-10, 13, 17, 21, and 23 of the ’802 patent as unpatentable.